Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 868

Joint MOTION for Extension of Time to File Response/Reply as to 845 MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) (Joint Motion for Extension of Time to File A Reply and Surreply to Yahoo!'s Renewed Motion for Judgment as a Matter of Law Regarding Invalidity) by Bedrock Computer Technologies, LLC, Yahoo! Inc.. (Attachments: # 1 Text of Proposed Order)(Doan, Jennifer)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, PLAINTIFF VS. YAHOO!, INC., DEFENDANT § § § § § CIVIL ACTION NO. 6:09-cv-269-LED-JDL § § JURY TRIAL DEMANDED § § JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY TO YAHOO!’S RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW REGARDING INVALIDITY Plaintiff Bedrock Computer Technologies, LLC (“Bedrock”) and Defendant Yahoo! Inc. (“Yahoo!”) file this motion to extend the time to file a reply and surreply to Yahoo!’s Renewed Motion for Judgment as a Matter of Law Regarding Invalidity and would respectfully show the Court the following: Yahoo!’s current deadline to file a reply in support of its Renewed Motion for Judgment as a Matter of Law Regarding Invalidity [Dkt. No. 845] is July 11, 2011. Yahoo! requested a short extension, through and including July 15, 2011, to file a reply [Dkt. No. 848]. The Court denied Yahoo!’s motion without prejudice to refilling if the parties agreed on a schedule where all replies and surreplies were filed no later than July 18, 2011 [Dkt. No. 867]. Yahoo! and Bedrock have agreed to extend the date to file a reply through and including July 12, 2011 and have agreed to extend the date to file a surreply through and including July 18, 2011. For the above reasons, Yahoo! and Bedrock respectfully request that the Court enter an order extending Yahoo!’s time to file a reply in support of its Renewed Motion for Judgment as a JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 1 Matter of Law Regarding Invalidity through and including July 12, 2011 and extending Bedrock’s time to file a surreply through and including July 18, 2011. Respectfully submitted, /s/ Robert Christopher Bunt Douglas A. Cawley, Lead Attorney Texas Bar No. 04035500 dcawley@mckoolsmith.com Theodore Stevenson, III Texas Bar No. 19196650 tstevenson@mckoolsmith.com Rosemary T. Snider Texas Bar No. 18796500 rsnider@mckoolsmith.com Scott W. Hejny Texas State Bar No. 24038952 shejny@mckoolsmith.com Jason D. Cassady Texas Bar No. 24045625 jcassady@mckoolsmith.com J. Austin Curry Texas Bar No. 24059636 acurry@mckoolsmith.com Phillip M. Aurentz Texas State Bar No. 24059404 paurentz@mckoolsmith.com McKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone: 214-978-4000 Facsimile: 214-978-4044 Sam F. Baxter Texas Bar No. 01938000 McKOOL SMITH, P.C. sbaxter@mckoolsmith.com 104 E. Houston Street, Suite 300 P.O. Box 0 Marshall, Texas 75670 Telephone: (903) 923-9000 Facsimile: (903) 923-9099 JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 2 Robert M. Parker Texas Bar No. 15498000 Robert Christopher Bunt Texas Bar No. 00787165 PARKER, BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, Texas 75702 Telephone: 903-531-3535 Facsimile: 903-533-9687 E-mail: rmparker@pbatyler.com E-mail: rcbunt@pbatyler.com ATTORNEYS FOR BEDROCK COMPUTER TECHNOLOGIES LLC /s/ Jennifer H. Doan Jennifer H. Doan Texas Bar No. 08809050 J. Scott Andrews Texas Bar No. 24064823 HALTOM & DOAN 6500 Summerhill Road, Suite 100 Texarkana, TX 75503 Telephone: (903) 255-1000 Facsimile: (903) 255-0800 Email: jdoan@haltomdoan.com Email: sandrews@haltomdoan.com Fay Morisseau Christopher D. Bright Cal. Bar No. 206273 MCDERMOTT WILL & EMERY LLP 18191 Von Karman Ave, Ste. 500 Irvine, California 92612 Tel: 949.757.7178 Fax: 949.851.9348 E-mail: cbright@mwe.com E-mail: fmorisseau@mwe.com Yar R. Chaikovsky ychaikovsky@mwe.com John A. Lee jlee@mwe.com MCDERMOTT WILL & EMERY JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 3 275 Middlefield Rd., Suite 100 Menlo Park, CA 94025 Telephone: (650) 815-7400 Facsimile: (650) 815-7401 ATTORNEYS FOR YAHOO!, INC. CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). 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 certified mail, return receipt requested, on this the 8th day of July, 2011. /s/ Jennifer H. Doan Jennifer H. Doan JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 4