Luxpro Corporation v. Apple, Inc.

Filing 33

RESPONSE in Opposition re 25 MOTION to Transfer Case Plaintiff's Response in Opposition to Defendant's Motion to Transfer Venue and Brief in Support Thereof filed by Luxpro Corporation. (Attachments: # 1 Exhibit Ex A Declaration of Fu-Ching Wu)(Adams, Richard)

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS TEXARKANA DIVISION LUXPRO CORPORATION, a Taiwanese corporation, Plaintiff, vs. APPLE, INC. f/k/a Apple Computer, Inc., Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 4:08cv04092-HFB

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT'S MOTION TO DISMISS AND MOTION TO TRANSFER Plaintiff respectfully moves this Court for an order granting Plaintiff an extension of time in which to file a response to Defendant Apple, Inc.'s Motion to Dismiss (Dkt. No. 23) and Motion to Transfer (Dkt. No. 25), and would show the Court as follows: 1. On December 19, 2008, Apple, Inc. filed its Motion to Dismiss for Failure to State a Claim, and its Motion to Transfer, together with memoranda in support. 2. Plaintiff's response date is February 23, 2009. 3. The parties have reached an agreement extending the Plaintiff's response date to March 2, 2009. 4. Counsel for Plaintiff has agreed that Defendant may have to and including March 30, 2009 to file its reply to Plaintiff's responses to Defendant Apple, Inc.'s Motion to Dismiss and Motion to Transfer. WHEREFORE, Plaintiff prays the Court enter an order extending the time for Plaintiff to file its responses to Defendant Apple, Inc.'s Motion to Dismiss and Motion to Transfer to and including March 2, 2009, and extending the time for Defendant to reply to Plaintiff's responses to and including March 30, 2009.

Respectfully submitted,

Nicholas H. Patton Arkansas Bar No.: 63035 PATTON, TIDWELL & SCHROEDER, LLP 4605 Texas Boulevard ­ P.O. Box 5398 Texarkana, Texas 7550505398 Phone: [phone] Fax: [phone] Richard A. Adams Ark. Bar No. 97036 Phillip N. Cockrell Ark. BarNo. 79154 Corey D. McGaha Ark. Bar No. 2003047 PATTON ROBERTS PLLC 2900 St. Michael Drive, Suite 400 Texarkana, Texas 75505-6128 Phone: [phone] Fax: [phone] Jeremy Y. Hutchinson Ark. Bar No. 2006145 PATTON ROBERTS PLLC 111 Center St., Suite 1315 Little Rock, AR 72201 Telephone: [phone] Facsimile: [phone] Patrick J. Conroy Pro Hac Vice Glenn E. Janik Pro Hac Vice SHORE CHAN BRAGALONE LLP Bank of America Plaza 901 Main Street, Suite 3300 Dallas, Texas 75202 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR PLAINTIFF LUXPRO CORPORATION

CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system this 17th day of February, 2009.

Nicholas H. Patton