Mirror Worlds, LLC v. Apple, Inc.

Filing 238

Unopposed MOTION for Extension of Time to File Response/Reply as to 215 SEALED MOTION Mirror Worlds Technologies, Inc.s Motion For Leave To Amend Its Answer And Submit Invalidity Contentions, 206 SEALED MOTION Plaintiff Mirror Worlds LLC's Motion to Compel Production of Foreign Sales Information, the Master Disk and Information Regarding the iPad, 231 SEALED MOTION Mirror Worlds, LLC and Mirror Worlds Technologies, Inc.s Opposition To Apple Inc.s Motion To Compel Documents and Interrogatory Responses, 205 MOTION to Strike the Surprise Expert Reports of John Levy, Ph.D. on the Purported Invalidity and Non-Infringement of U.S. Patent No. 6,613,101, 204 SEALED MOTION TO COMPEL DOCUMENTS AND INTERROGATORY RESPONSES, 232 Response to Motion, by Apple, Inc.. (Attachments: # 1 Text of Proposed Order)(Randall, Jeffrey)

Mirror Worlds, LLC v. Apple, Inc. Doc. 23 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaint iff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. JURY TRIAL DEMANDED Civil Action No. 6:08-cv-88 LED APPLE INC.'S UNOPPOSED MOTION FOR ADDITIONAL TIME TO RESPOND TO DOCKET NOS. 204, 205, 206 AND 215 Apple Inc. ("Apple") respectfully submits this Unopposed Motion for Additional Time To Respond to the following: 1) Mirror Worlds Technologies, Inc.'s Motion for Leave To Amend Its Answer and Submit Invalidity Contentions (Doc. No. 215). Mirror Worlds Technologies, Inc. ("MWT") filed its Motion for Leave To Amend on June 24, 2010. Pursuant to Local Rule CV-7(e), Apple's response is currently due today, July 12, 2010. Apple respectfully requests that the Court grant it three additional days, until July 15, 2010, to file its response. Dockets.Justia.com 2) Mirror Worlds, LLC's Motion To Compel Production of Foreign Sales Information, the Master Disk, and Information Regarding the iPad (Doc. No. 206). Mirror Worlds, LLC ("Mirror Worlds") filed its Motion To Compel on June 15, 2010, after 5:00 p.m Central Time. Pursuant to Local Rule CV-7(e), Apple's response was due on July 6, 2010, but on July 8, 2010, this Court granted an unopposed extension to July 13, 2010 (Doc. No. 237). Apple respectfully requests that the Court grant it two additional days, until July 15, 2010, to file its response. 3) Mirror Worlds, LLC and Mirror Worlds Technologies, Inc.'s Opposition to Apple Inc's Motion To Compel Documents and Interrogatory Responses (Doc. No. 231). Mirror Worlds and MWT filed their Response to the Motion To Compel (Docket No. 204) on July 2, 2010 after 5:00 pm. Pursuant to Local Rule CV-7(f) Apple's reply brief is currently due July 13, 2010. Apple respectfully requests that the Court grant it two addit ional days, until July 15, 2010, to file its reply brief. 4) Mirror Worlds Technologies, Inc.'s Response to Defendant/Counterclaim Plaintiff Apple Inc's Motion To Strike the Surprise Expert Reports of John Levy, Ph.D. on the Purported Invalidity and Non-Infringement of U.S. Patent No. 6,613,101 (Doc. No. 232). MWT Worlds filed its Response to the Motion To Strike (Doc. No. 205) on July 2, 2010 after 5:00 p.m. Central Time. Pursuant to Local Rule CV-7(f) Apple's reply brief is currently due on July 13, 2010. Apple respectfully requests that the Court grant it two addit ional days, until July 15, 2010, to file its reply brief. The purpose for the additional time is to allow the parties to discuss the issues raised by the motions and attempt to resolve some or all of the issues without involving the Court. This Motion for Additional Time is unopposed. On July 9, 2010, S. Christian Platt, counsel for -2- Apple, met and conferred telephonically with Alexander Solo, counsel for Mirror Worlds, who indicated that Mirror Worlds does not oppose this Motion. A proposed order is attached. Dated: July 12, 2010 Respect fully submitted, /s/ Jeffrey G. Randall Jeffrey G. Randall Lead Attorney PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 1117 S. California Avenue Palo Alto, California 94304-1106 Telephone: (650) 320-1850 Facsimile: (650) 320-1950 jeffrandall@paulhast ings.co m Allan M. Soobert PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 875 15th Street, N.W. Washington, DC 20005 Telephone: (202) 551-1822 Facsimile: (202) 551-0222 allansoobert@paulhast ings.co m S. Christian Platt PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 4747 Executive Dr., 12th Floor San Diego, CA 92121 Telephone: (858) 458-3034 Facsimile: (858) 458-3005 christ ianplatt@paulhast ings.co m Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: (903) 757-8449 Facsimile: (903) 758-7397 ema@emafirm.com COUNSEL FOR APPLE INC. -3- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was filed electronically in compliance with Local Rule CV-5 on this 12th day of July, 2010. As of this date, all counsel of record have consented to electronic service and are being served with a copy of this document through the Court's CM/ECF system under Local Rule CV-5(a)(3)(A). /s/ Jeffrey G. Randall Jeffrey G. Randall LEGAL_US_E # 88878151.1 -4-