I/P Engine, Inc. v. AOL, Inc. et al

Filing 15

MOTION for Extension of Time to File Answer re 1 Complaint, Answer, Plead or Otherwise Respond to Complaint by Target Corporation. (Attachments: # 1 Exhibit A)(Noona, Stephen)

Download PDF
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Norfolk Division I/P ENGINE, INC., Plaintiff, v. Civil Action No. 2:11cv512 (RAJ-FBS) AOL INC., GOOGLE, INC., IAC SEARCH & MEDIA, INC., GANNETT CO., INC. and TARGET CORPORATION Defendants. MOTION FOR EXTENSION OF TIME FOR TARGET CORPORATION TO FILE RESPONSIVE PLEADINGS TO COMPLAINT The defendant Target Corporation (“Target”), by counsel, moves this Court for an extension of time through November 14, 2011, to answer, plead, or otherwise respond to the Complaint filed by I/P Engine, Inc. (“I/P Engine”), and in support thereof states as follows: 1. On September 15, 2011, I/P Engine filed its Complaint for patent infringement against Target. On September 23, 2011, I/P Engine served its Complaint upon Target. 2. Target’s responsive pleadings are not due until October 14, 2011. 3. Target has requested and I/P Engine has agreed to allow Target an extension of time through November 14, 2011, for Target to answer, plead, or otherwise respond to the Complaint filed by I/P Engine. 4. Attached as Exhibit A is a proposed agreed order granting Target an extension of time through November 14, 2011, to answer, plead or otherwise respond to the Complaint filed by I/P Engine. The proposed agreed order is being circulated for endorsement and will be delivered to the Court once it is fully signed. WHEREFORE, Target, by counsel, requests that this Court enter the attached proposed agreed order granting Target an extension of time through November 14, 2011, to answer, plead, or otherwise respond to the Complaint. Dated: October 10, 2011 Respectfully submitted, /s/ Stephen E. Noona Stephen E. Noona Virginia State Bar No. 25367 KAUFMAN & CANOLES, P.C. 150 West Main Street, Suite 2100 Norfolk, VA 23510 Telephone: (757) 624-3000 Facsimile: (757) 624-3169 senoona@kaufcan.com Counsel for Target Corporation 2 CERTIFICATE OF SERVICE I hereby certify that on October 10, 2011, I will electronically file the foregoing with the Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to the following: Jeffrey K. Sherwood Kenneth W. Brothers DICKSTEIN SHAPIRO LLP 1825 Eye Street NW Washington, DC 20006 Telephone: (202) 420-2200 Facsimile: (202) 420-2201 sherwoodj@dicksteinshapiro.com brothersk@dicksteinshapiro.com Counsel for Plaintiff, I/P Engine, Inc. Stephen E. Noona Virginia State Bar No. 25367 KAUFMAN & CANOLES, P.C. 150 W. Main Street, Suite 2100 Norfolk, VA 23510-1665 Telephone: (757) 624-3239 Facsimile: (757) 624-3169 senoona@kaufcan.com Counsel for AOL Inc., Google, Inc. and Gannett Co., Inc. /s/ Stephen E. Noona Stephen E. Noona Virginia State Bar No. 25367 KAUFMAN & CANOLES, P.C. 150 West Main Street, Suite 2100 Norfolk, VA 23510 Telephone: (757) 624-3000 Facsimile: (757) 624-3169 senoona@kaufcan.com Counsel for Target Corporation 11336876_1.DOC 3