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Kyko Global, Inc. v. Prithvi Information Solutions, Ltd.

United States District Court, W.D. Washington

February 2, 2018

KYKO GLOBAL, INC., a Canadian corporation, and KYKO GLOBAL GMBH, a Bahamian corporation, Plaintiffs,
v.
PRITHVI INFORMATION SOLUTIONS, LTD., a Pennsylvania corporation, PRITHVI CATALYTIC, INC., a Delaware corporation, PRITHVI SOLUTIONS, INC., a Delaware corporation, PRITHVI INFORMATION SOLUTIONS INTERNATIONAL, LLC, a Pennsylvania limited liability company, INALYTIX, INC., a Nevada corporation, INTERNATIONAL BUSINESS SOLUTIONS, INC., a North Carolina, corporation, AVANI INVESTMENTS, INC., a Delaware corporation, ANANYA CAPITAL INC., a Delaware corporation, MADHAVI VUPPALAPATI AND ANANDHAN JAGARAMAN, husband and wife and the marital community composed thereof, SATISH VUPPALAPATI, GURU PANDYAR AND JANE DOE PANDYAR, husband and wife and the marital community composed thereof, and SRINIVAS SISTA AND JOHN DOE SISTA, husband and wife and the marital community composed thereof, DCGS, INC., a Pennsylvania company, EPP, INC., a Washington corporation, FINANCIAL OXYGEN, INC., a Washington corporation, HUAWEI LATIN AMERICAN SOLUTIONS, INC., a Florida corporation, L3C, INC., a Washington corporation. Defendants.

          REQUEST FOR JUDICIAL ASSISTANCE TO THE HIGH COURT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION, COURT OF FIRST INSTANCE

          Marsha J. Pechman United States District Judge.

         Pursuant to the Model Letter of Request under The Hague Convention on Taking Evidence Abroad in Civil or Commercial Matters, the Honorable Marsha J. Pechman, United States District Court Judge for the Western District of Washington, hereby makes the following request for judicial assistance to the High Court of the Hong Kong Special Administrative Region, Court of First Instance:

         1. Sender:

         United States District Court for the Western District of Washington Marsha J. Pechman - United States District Court Judge 700 Stewart Street, Suite 2310 Seattle, WA 98101

         2. Chief Secretary for Administration and Central Authority of the Requested State:

         Chief Secretary for Administration Hong Kong Special Administrative Region Government Room 321, 3/F, East Wing Central Government Offices 2 Tim Mei Avenue Admiralty Hong Kong, China

         High Court of the Hong Kong Special Administrative Region, Court of First Instance 38 Queensway, Hong Kong, China

         Sender hereby requests the Chief Secretary for Administration to receive this Letter of Request and to transmit same to the High Court of the Hong Kong Special Administrative Region, Court of First Instance.

         3. Person to Whom the Executed Request is to be Returned:

Duncan Watt Eversheds 21/F, Gloucester Tower The Landmark 15 Queen's Road Central Hong Kong, China, 2186-3200 Local Counsel for Kyko Global Inc. and Kyko Global GmbH

         4. Specification of the Date by Which the Requesting Authority Requires Receipt of the Response to the Letter of Request:

         As soon as the Requested Authority is able to process the Request, and to give continuous and ongoing effect to this Request until the activities identified in this Request are complete. Accordingly, the Requesting Authority requests the Requested Authority to select a date on its own accord which will enable Plaintiffs to have a full opportunity to complete all such activities contained in this Request.

         IN CONFORMITY WITH ARTICLE 3 OF THE CONVENTION, THE UNDERSIGNED APPLICANT HAS THE HONOUR TO SUBMIT THE FOLLOWING REQUEST:

         a. Requesting Judicial Authority (Article 3, a):

         United States District Court for the Western District of Washington

         b. To the Competent Authority of (Article 3, a):

         Hong Kong - High Court of the Hong Kong Special Administrative Region, Court of First Instance.

         c. Names of the Case and Any Identifying Number:

         Kyko Global Inc. and Kyko Global GmbH v. Prithvi Information Solutions Ltd. et al. No. 2:13-CV-1034 MJP

         6. Names and Addresses of the Parties and Their Representatives (Including Representatives in the ...


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