Mirror Worlds, LLC v. Apple, Inc.

Filing 267

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 Proposed Order)(Randall, Jeffrey)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 267 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. 206, 215, 231, AND 232 Apple Inc. ("Apple") respectfully submits this Unopposed Motion for Additional Time To Respond to Docket Nos. 206, 215, 231, and 232. As noted in Apple's previous Unopposed Motions for Additional Time (Doc. Nos. 241 and 246), the parties have been working to resolve all outstanding issues in these Motions and have successfully resolved a significant number of the issues. Currently, the parties continue to discuss these issues and expect that they will be able resolve and withdraw these Motions in addition to Mirror Worlds LLC's Motion to Preclude Apple's Amended Invalidity Contentions and To Strike Portions of The Expert Report of Steven Dockets.Justia.com K. Feiner, Ph.D. Regarding Invalidity (Doc. No. 196) and Apple's Motion for Leave to Amend its Invalidity Contentions (Doc. No. 198), which have already been fully briefed. In the interest of narrowing or resolving the issues for the Court, Apple respectfully requests 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.) The time to respond to this Motion has been extended to July 27, 2010 by the Court's Order filed July 21, 2010. (Doc. No. 247.) Apple respectfully requests that the Court grant it six days, until August 2, 2010, to file its response, if necessary. 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 27, 2010 by the Court's Order filed July 21, 2010. (Doc. No. 247.) Apple respectfully requests that the Court grant it six days, until August 2, 2010, to file its response, if necessary. 3) Mirror Worlds, LLC and Mirror Worlds Technologies, Inc.'s Opposition to Apple Inc's Motion To Compel Documents and Interrogatory Responses. (Doc. Nos. 204, 231.) The time to respond to this Opposition has been extended to July 27, 2010 by the Court's Order filed July 21, 2010. (Doc. No. 247.) Apple respectfully requests that the Court grant it six days, until August 2, 2010, to file its reply brief, if necessary. 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 this Opposition has been extended to July 27, 2010 by the Court's Order -2- filed July 21, 2010. (Doc. No. 247.) Apple respectfully requests that the Court grant it six days, until August 2, to file its reply brief, if necessary. This Motion for Additional Time is unopposed. On July 27, 2010, counsel for Apple, Mirror Worlds, and MWT met and conferred telephonically and agreed to continue to attempt to resolve the outstanding issues. A proposed order is attached. Dated: July 27, 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 27th 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 # 89035275.1 -5-