FPX, LLC v. Google, Inc. et al

Filing 47

NOTICE of Disclosure by Turner Broadcasting System, Inc. (Babcock, Charles)

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FPX, LLC v. Google, Inc. et al Doc. 47 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION FPX, LLC d/b/a FIREPOND, Individually and on Behalf of All Others Similarly Situated, Plaintiff, v. GOOGLE INC., YOUTUBE, LLC, AOL LLC, TURNER BROADCASTING SYSTEM, INC., MYSPACE, INC. AND IAC/INTERACTIVECORP, Defendants. Civil Action No. 2:09-cv-00142-TJW CLASS ACTION COMPLAINT JURY TRIAL REQUESTED DEFENDANT TURNER BROADCASTING SYSTEM, INC.'S NOTICE OF DISCLOSURE Defendant Turner Broadcasting System, Inc.1 notifies the Court and all counsel of record that today it disclosed to counsel for Plaintiff the Initial Disclosures required by Federal Rule of Civil Procedure 26(a)(1). These disclosures were served by certified mail return receipt requested. 1 Turner is not a proper defendant concerning the acts complained of in this action and should be dismissed. In serving its Initial Disclosures, Turner does not waive, but rather expressly reserves, its rights. Based on the allegations in the complaint - which are denied - it appears that one of Turner's subsidiaries, CNN Interactive Group, Inc. is the proper defendant. DEFENDANT TURNER BROADCASTING SYSTEM, INC.'S NOTICE OF DISCLOSURE PAGE 1 Dockets.Justia.com Respect fully submitted, /s/ Charles L. Babcock Charles L. "Chip" Babcock Texas State Bar No. 01479500 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-6030 (214) 953-5822- Fax Email: cbabcock@jw.com David T. Moran Texas State Bar No. 14419400 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-6051 (214) 661-6677 - Fax Email: dmoran@jw.com Carl C. Butzer Texas State Bar No. 03545900 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-5902 (214) 661-6609 - Fax Email: cbutzer@jw.com ATTORNEYS FOR DEFENDANTS GOOGLE INC., YOUTUBE, LLC, AOL LLC, TURNER BROADCASTING SYSTEM, INC., MYSPACE, INC., AND IAC/INTERACTIVECORP DEFENDANT TURNER BROADCASTING SYSTEM, INC.'S NOTICE OF DISCLOSURE PAGE 2 CERTIFICATE OF SERVICE I hereby certify that on November 25, 2009, I electronically submitted the foregoing document with the clerk of the court for the U.S. District Court, Eastern District of Texas, using the electronic case files system of the court. The electronic case files system sent a "Notice of Electronic Filing" to individuals who have consented in writing to accept this Notice as service of this document by electronic means. All other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by first class mail today, November 25, 2009. /s/ Charles L. Babcock Charles L. "Chip" Babcock DEFENDANT TURNER BROADCASTING SYSTEM, INC.'S NOTICE OF DISCLOSURE PAGE 3