Mirror Worlds, LLC v. Apple, Inc.

Filing 241

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)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 241 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, 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. The time to respond to this motion has been extended to July 15, 2010 by the Court's Order filed July 13, 2010. (Doc. No. 240.) Apple respectfully requests that the Court grant it five additional days, until July 20, 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). The time to respond to this motion has been extended to July 15, 2010 by the Court's Order filed July 13, 2010. (Doc. No. 240.) Apple respectfully requests that the Court grant it five additional days, until July 20, 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. 204, 231). The time to respond to the opposition to Apple's Motion To Compel has been extended to July 15, 2010 by the Court's Order filed July 13, 2010. (Doc. No. 240.) Apple respectfully requests that the Court grant it five additional days, until July 20, 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. Nos. 205, 232). The time to respond to the opposition to Apple's Motion To Strike was extended to July 15, 2010 by the Court's Order filed July 13, 2010. (Doc. No. 240.) Apple respectfully requests that the Court grant it five additional days, until July 20, 2010, to file its reply brief. During the additional time period already granted by the Court, the parties have successfully resolved a significant number of the issues raised in the above motions. With regard to Mirror Worlds, LLC's Motion To Compel Production of Foreign Sales Information, the Master Disk, and Information Regarding the iPad, the parties have resolved the issues relating to Mirror Worlds, LLC's requests for foreign sales information, a copy of the Master Disk, and information regarding the iPad. With regard to Apple Inc's Motion To Compel Documents and Interrogatory Responses, the parties have resolved the issues relating to Apple's requests for -2- documents relating to the government funding of Lifestreams, TR 1054, and third party software utilized by Lifestreams and Scopeware as well as Apple's request for supplemental interrogatory responses from Mirror Worlds LLC. The purpose of this Motion for Additional Time is to allow the parties to continue to discuss the remaining issues raised by the above motions and attempt to resolve some or all of the issues without involving the Court. This Motion for Additional Time is unopposed. On July 15, 2010, Christian Platt, counsel for Apple, met and conferred telephonically with Alexander Solo and Ian DiBernardo, counsel for Mirror Worlds and MWT, who indicated that they do not oppose this Motion. A proposed order is attached. Dated: July 15, 2010 Respectfully 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@paulhastings.com 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@paulhastings.com 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 christianplatt@paulhastings.com -3- 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. -4- 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 15th 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 # 88901166.2 -5-