John Beck Amazing Profits, LLC v. Google Inc. et al

Filing 16

RESPONSE to Motion re 14 Opposed MOTION for Leave to File First Amended Class Action Complaint filed by Google Inc., AOL LLC. (Babcock, Charles)

John Beck Amazing Profits, LLC v. Google Inc. et al Doc. 16 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION JOHN BECK AMAZING PROFITS, LLC Individually and on Behalf of All Others Similarly Situated, Plaint iff, v. JURY TRIAL REQUESTED GOOGLE INC. AND AOL LLC Defendants. RESPONSE TO PLAINTIFF'S OPPOSED MOTION FOR LEAVE TO FILE FIRST AMENDED CLASS ACTION COMPLAINT Defendants Google Inc. and AOL LLC ("Defendants") file this Response to Plaintiff's Opposed Motion for Leave to File First Amended Class Action Complaint and would show the Court as follows: After sufficient opportunity to review Plaintiff's Opposed Motion for Leave to File First Amended Class Action Complaint, Defendants have determined that they have no opposition to relief sought therein. Civil Action No. 2:09-cv-000151-TJWCE CLASS ACTION COMPLAINT RESPONSE TO PLAINTIFF'S OPPOSED MOTION FOR LEAVE TO FILE FIRST AMENDED CLASS ACTION COMPLAINT PAGE 1 Dockets.Justia.com Dated: September 24, 2009 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. and AOL LLC RESPONSE TO PLAINTIFF'S OPPOSED MOTION FOR LEAVE TO FILE FIRST AMENDED CLASS ACTION COMPLAINT PAGE 2 CERTIFICATE OF SERVICE I hereby certify that on September 24, 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, September 24, 2009. /s/ Charles L. Babcock________________. Charles L. Babcock RESPONSE TO PLAINTIFF'S OPPOSED MOTION FOR LEAVE TO FILE FIRST AMENDED CLASS ACTION COMPLAINT PAGE 3