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

Filing 6

MOTION for Extension of Time to File Response/Reply as to 1 Complaint, by Google, Inc.. (Attachments: # 1 Exhibit A)(Noona, Stephen)

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 GOOGLE, INC. TO FILE RESPONSIVE PLEADINGS TO COMPLAINT The defendant Google, Inc. (“Google”), 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 Google. On September 23, 2011, I/P Engine served its Complaint upon Google. 2. Google’s responsive pleadings are not due until October 14, 2011. 3. Google has requested and I/P Engine has agreed to allow Google an extension of time through November 14, 2011, for Google 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 Google 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, Google, by counsel, requests that this Court enter the attached proposed agreed order granting Google an extension of time through November 14, 2011, to answer, plead, or otherwise respond to the Complaint. Dated: October 4, 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 Google, Inc. 2 CERTIFICATE OF SERVICE I hereby certify that on October 4, 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. /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 Google, Inc. 11318740_1.DOC 3