Beneficial Innovations, Inc. v. Blockdot, Inc. et al

Filing 51

Consent MOTION for Extension of Time to File Answer re 7 Amended Complaint , Move, or Otherwise by Careerbuilder, LLC. (Attachments: # 1 Text of Proposed Order)(DeVasto, Diane)

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Beneficial Innovations, Inc. v. Blockdot, Inc. et al Doc. 51 Case 2:07-cv-00263-TJW-CE Document 51 Filed 08/21/2007 Page 1 of 2 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC. v. BLOCKDOT, INC.; CAREERBUILDER, LLC; CNET NETWORKS, INC.; DIGG, INC.; EBAUM'S WORLD, INC.; JABEZ NETWORKS, INC.; THE NEW YORK TIMES COMPANY; THE WASHINGTON POST COMPANY; and THE WEATHER CHANNEL INTERACTIVE, INC. C.A. 2:07-CV-263-TJW/CE JURY DEMANDED DEFENDANT CAREERBUILDER, LLC'S SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT Defendant CareerBuilder, LLC ("CareerBuilder"), without waiving any defenses or any matters that might be presented pursuant to FEDERAL RULE OF CIVIL PROCEDURE 12(b) or any other rule or law, files this unopposed motion for extension of time in which to answer, move, or otherwise respond to Plaintiff Beneficial Innovation, Inc.'s ("BI") First Amended Complaint and would respectfully show the Court as follows: CareerBuilder has requested and BI has agreed to an additional extension of CareerBuilder's time to respond in any manner whatsoever including answer, motion, or other pleading of any type to Plaintiff's First Amended Complaint up to and including September 12, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. {A53\7826\0001\W0334408.1 } Dockets.Justia.com Case 2:07-cv-00263-TJW-CE Document 51 Filed 08/21/2007 Page 2 of 2 Dated: August 21, 2007 Respectfully submitted, /s/ Diane V. DeVasto Diane V. DeVasto State Bar No. 05784100 POTTER MINTON A Professional Corporation 110 N. College, Suite 500 (75702) P. O. Box 359 Tyler, Texas 75710 (903) 597-8311 (903) 593-0846 (Facsimile) dianedevasto@potterminton.com David A. Nelson david.nelson@lw.com Kevin C. May kevin.may@lw.com Latham & Watkins LLP Sears Tower, Suite 5800 233 S. Wacker Drive Chicago, IL 60606 (312) 876-7700 (312) 993-9767 (Facsimile) ATTORNEYS FOR DEFENDANT CAREERBUILDER, LLC CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this the 21st day of August 2007. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Diane V. DeVasto Diane V. DeVasto {A53\7826\0001\W0334408.1 }