Lancium LLC v. U.S. Data Mining Group, Inc. — Entry #17: Joint MOTION for Extension of Time to File Answer and Stay all Other Deadlines by Lancium LLC
Case: Lancium LLC v. U.S. Data Mining Group, Inc. txwd · 6:23-cv-00344
filed May 10, 2023
What this document is
Docket entry #17 · filed September 21, 2023
Joint MOTION for Extension of Time to File Answer and Stay all Other Deadlines by Lancium LLC. (Attachments: # (1) Proposed Order)(Ortega, Francisco)
Who is involved
- Lancium LLC
- U.S. Data King Mountain LLC
- U.S. Data Mining Group, Inc.
- U.S. Mining Infrastructure Operations, LLC
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Marathon Digital: its name “Marathon Digital Holdings, Inc.” appears in a filing in this case.
…(“MARA Order Form”), each by and between Marathon Digital Holdings, Inc. (“MARA”) and TZRC KM (the “MARA Lien”);…
- Hut 8: its former name “Hut 8 Mining Corp.” appears in a filing in this case.
…address activities, events or developments that Hut 8 Mining Corp. (“Hut 8”) expects or anticipates will or…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 16, 2026. Federal court filings are public records.
Document text
5 page(s), 7,907 characters, converted from the PDF's text layer · plain text.
Full text
Case 6:23-cv-00344-KC Document 17 Filed 09/21/23 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
EL PASO DIVISION
LANCIUM LLC,
Plaintiff, Case No. 6:23-cv-00344-KC
v.
JURY TRIAL DEMANDED
U.S. DATA MINING GROUP, INC.
(D/B/A US BITCOIN),
U.S. MINING INFRASTRUCTURE
OPERATIONS, LLC, and
U.S. DATA KING MOUNTAIN LLC,
Defendants.
JOINT MOTION TO EXTEND STAY
Plaintiff Lancium LLC and Defendants U.S. Data Mining Group, Inc. (d/b/a US Bitcoin),
U.S. Mining Infrastructure Operations, LLC, and U.S. Data King Mountain LLC (collectively,
“Defendants”) (collectively, the “Parties”) jointly and respectfully move the Court to: (1) extend the
time for Defendants to answer, move, or otherwise respond to Plaintiff’s Complaint until January 15,
2024; and (2) otherwise extend the stay of this case and all other deadlines until January 15, 2024.
Good cause exists for granting this Motion for the following reasons:
1. On July 1, 2023, in order to aid discussions regarding resolution of this matter, the
Parties jointly moved to extend Defendants’ deadline to respond to the complaint until October 2,
2023 and to stay all other deadlines until October 2, 2023. See D.I. 15.
2. On July 5, 2023, the Court granted the Parties’ joint motion and stayed all deadlines
until October 2, 2023. See D.I. 16.
3. During the stay period, the Parties engaged in continued negotiations but have not yet
been able to reach final resolution. Negotiations continue, but have been complicated by, among
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Case 6:23-cv-00344-KC Document 17 Filed 09/21/23 Page 2 of 5
other things, Defendants’ concurrent efforts to consummate a proposed merger transaction. To the
extent that the merger is consummated, the Parties expect to engage in further good faith
negotiations with the goal of bringing these disputes to a consensual resolution.
4. In the interim, the Parties do not wish to expend the Court’s or the Parties’ resources.
Given the scope of this litigation, which involves seven (7) patents, the Parties expect that early
motion practice and claim construction proceedings alone will result in a substantial imposition upon
the Court and significant expenditure by the Parties.
5. In view of the Parties’ expected path to resolution, and the substantial resources and
expense associated with litigating a case of this size and scope, the Parties respectfully request that
the Court enter an order extending the time in which Defendants may respond to Plaintiff’s Complaint
up-to and including January 15, 2024, and otherwise extend the stay of this case and all pending
deadlines until January 15, 2024.
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Case 6:23-cv-00344-KC Document 17 Filed 09/21/23 Page 3 of 5
Dated: September 21, 2023 Respectfully submitted,
/s/
Francisco J. Ortega
Texas Bar No. 24060365
SCOTTHULSE, P.C.
One San Jacinto Plaza
201 E. Main Drive, Suite 1100
El Paso, TX 79901
Telephone: (915) 546-8245
Fax: (915) 546-8333
Email: [email protected]
Jeff H. Ray
Texas Bar No. 16604400
Marisa Y. Ybarra-Williams
Texas Bar No. 24067360
RAY PEÑA MCCHRISTIAN
5822 Cromo Drive, Suite 400
El Paso, TX 79912
Telephone: (915) 832-7200
Fax: (915) 832-7333
Email: [email protected]
Email: [email protected]
Mark C. Nelson
Texas Bar No. 00794361
BARNES & THORNBURG LLP
2121 North Pearl Street, Ste. 700
Dallas, TX 75201
Telephone: (214) 258-4200
Fax: (214) 258-4199
Email: [email protected]
Adam M. Kaufmann (admitted pro hac vice)
BARNES & THORNBURG LLP
One North Wacker Drive, Suite 4400
Chicago, IL 60606
Telephone: (312) 214-8319
Fax: (312) 759-5646
Email: [email protected]
ATTORNEYS FOR PLAINTIFF
LANCIUM LLC
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Case 6:23-cv-00344-KC Document 17 Filed 09/21/23 Page 4 of 5
/s/
Krishnan Padmanabhan
[email protected]
WINSTON & STRAWN LLP
200 Park Avenue
New York, NY 10166-4193
Tel: 212-294-6700
Fax: 212-294-4700
Daniel T. Stabile
[email protected] (Pro Hac Vice)
WINSTON & STRAWN LLP
200 South Biscayne Boulevard
Miami, FL 33131
Tel: (305) 910-0500
Fax: (305) 910-0505
William M. Logan
Texas Bar No. 24106214
[email protected]
WINSTON & STRAWN LLP
800 Capitol Street, Suite 2400
Houston, TX 77002
Tel: (713) 651-2766
Fax: (713) 651-2700
ATTORNEYS FOR DEFENDANTS
U.S. DATA MINING GROUP, INC.,
U.S. MINING INFRASTRUCTURE
OPERATIONS, LLC, AND
U.S. DATA KING MOUNTAIN LLC
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Case 6:23-cv-00344-KC Document 17 Filed 09/21/23 Page 5 of 5
CERTIFICATE OF CONFERENCE
This is to certify that on September 20, 2023 counsel for Plaintiff conferred with counsel for
Defendants regarding the relief requested in this motion.
/s/ Mark C. Nelson
Mark C. Nelson
CERTIFICATE OF SERVICE
The undersigned hereby certifies that all counsel of record who are deemed to have
consented to electronic service are being served with a copy of the foregoing on September 21,
2023, via the Court’s CM/ECF system.
/s/ Mark C. Nelson
Mark C. Nelson
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