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

Filing 817

MOTION for Extension of Time to File Response/Reply as to 809 Bill of Costs (Unopposed) and Memorandum in Support of Unopposed Motion for Extension of Time to File a Response to Plaintiff's Bill of Costs by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1)(Noona, Stephen)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION I/P ENGINE, INC. Plaintiff, Civil Action No. 2:11-cv-512 v. AOL INC., et al., Defendants. UNOPPOSED MOTION AND MEMORANDUM IN SUPPORT OF UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO PLAINTIFF’S BILL OF COSTS The Defendants AOL Inc. (“AOL”), IAC Search & Media, Inc. (“IAC Search & Media”), Gannett Co., Inc. (“Gannett”), Target Corporation (“Target”), and Google Inc. (“Google”) (collectively “Defendants”), by counsel, pursuant to Rule 7 of the Local Rules of Practice for the United States District Court for the Eastern District of Virginia, move this Court for entry of an order granting Defendants an extension of time through and including January 11, 2012, in which to file their response to Plaintiff’s Bill of Costs (D.N. 809), and in support thereof state as follows: 1. Plaintiff filed its Bill of Costs on December 3, 2012. Under Local Rule 7 and Fed. R. Civ. P. 6, Defendants’ response is due on December 17, 2012. 2. Defendants have requested, and Plaintiff has agreed to, an extension through and including January 11, 2013, to file their response to Plaintiff’s Bill of Costs. 01980.51928/5096657.1 3. Defendants will not oppose an extension until January 25, 2013, for Plaintiff to file its reply in support of its Bill of Costs. 4. Granting Defendants an extension through and including January 11, 2013, to file their responses to the Plaintiff’s Bill of Costs, and Plaintiff an extension through and including January 25, 2013 to file its reply in support of its Bill of Costs, will not prejudice the parties. 5. Attached as Exhibit 1 is a proposed agreed order granting Defendants through and including January 11, 2013 to file their response to Plaintiff's Bill of Costs, and granting Plaintiff through and including January 25, 2013 to file its reply in support of its Bill of Costs. WHEREFORE, Defendants, by counsel, request that this Court enter the proposed agreed order attached as Exhibit 1 granting Defendants through and including January 11, 2013 to file their response to Plaintiff’s Bill of Costs, and granting Plaintiff through and including January 25, 2013 to file its reply in support of its Bill of Costs. Dated: December 17, 2012 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 AOL Inc., Google Inc., IAC Search & Media, Inc., Gannett Co., Inc. and Target Corporation David Bilsker David A. Perlson QUINN EMANUEL URQUHART & 2 SULLIVAN, LLP 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: (415) 875-6600 Facsimile: (415) 875-6700 davidbilsker@quinnemanuel.com davidperlson@quinnemanuel.com Counsel for Google Inc., IAC Search & Media, Inc., Gannett Co., Inc. and Target Corporation /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 Robert L. Burns FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP Two Freedom Square 11955 Freedom Drive Reston, VA 20190 Telephone: (571) 203-2700 Facsimile: (202) 408-4400 Cortney S. Alexander FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP 3500 SunTrust Plaza 303 Peachtree Street, NE Atlanta, GA 94111 Telephone: (404) 653-6400 Facsimile: (415) 653-6444 Counsel for Defendant AOL Inc. 3 CERTIFICATE OF SERVICE I hereby certify that on December 17, 2012, 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: W. Ryan Snow Donald C. Schultz Steven Stancliff CRENSHAW, WARE & MARTIN, P.L.C. 150 West Main Street, Suite 1500 Norfolk, VA 23510 Telephone: (757) 623-3000 Facsimile: (757) 623-5735 dschultz@cwm-law.cm wrsnow@cwm-law.com sstancliff@cwm-law.com 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 12107040v1 4