Technology Licensing Corporation v. Grass Valley USA, Inc

Filing 17

ORDER by Chief Magistrate Judge Maria-Elena James granting 14 Stipulation to Extend time to respond to complaint (rmm2S, COURT STAFF) (Filed on 12/20/2012)

1 Vicki S. Veenker (SBN 158669)
Joshua C. Walsh-Benson (SBN 228983)
2 Benjamin Petersen (SBN 267120)
SHEARMAN & STERLING LLP
3 Five Palo Alto Square, 6th Floor
Palo Alto, CA 94306
[phone]
4 Telephone:
Facsimile:
[phone]
5 Email: [e-mail]
[e-mail]
[e-mail]
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7 Attorneys for Defendant
GRASS VALLEY USA, LLC
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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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TECHNOLOGY LICENSING
13 CORPORATION,

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
RESPOND TO COMPLAINT AND
RESET INITIAL CASE DEADLINES

Plaintiff,

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Case No.: 3:12-cv-06060-MEJ

v.

16 GRASS VALLEY USA, LLC,
Defendant.

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Pursuant to Local Rules 6-1(b) and 6-2(a), and subject to the Court’s approval, Defendant

21 Grass Valley USA, LLC (“Grass Valley”) and Plaintiff Technology Licensing Corporation
22 (“TLC”), by and through their respective counsel of record, hereby stipulate as follows:
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WHEREAS, TLC served its Complaint for Patent Infringement (the “Complaint”) on

24 December 3, 2012;
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WHEREAS, the Court issued its Order Setting Initial Case Management Conference and

26 ADR Deadlines on November 29, 2012 (the “Scheduling Order”);
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STIP. AND [PROPOSED] ORDER TO
EXTEND TIME TO RESPOND

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CASE NO. 12-CV-06060-MEJ
PLDOCS01/74639.3

WHEREAS, Grass Valley currently has until December 24, 2012 to answer or otherwise

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2 respond to TLC’s Complaint (Declaration of Vicki S. Veenker (the “Veenker Declaration”), filed
3 concurrently herewith, at ¶2);
WHEREAS, the parties have stipulated, pending approval of the Court, to an additional

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5 60 days for Grass Valley to answer or respond to TLC’s Complaint, enlarging the time for
6 response up to and including February 22, 2013 (Veenker Declaration, at ¶4); and
WHEREAS, because a 60-day extension would cause Grass Valley’s response to be due

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8 six days before the Initial Case Management Conference and after all other deadlines in the
9 Court’s Scheduling Order, the parties have further stipulated to a 29-day extension of time of the
10 deadlines set by the Court’s Scheduling Order (Veenker Declaration, at ¶5).
NOW, THEREFORE, the parties, by and through their respective counsel, stipulate as

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12 follows:
1. Grass Valley’s time to answer or otherwise respond to TLC’s Complaint shall be

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extended 60 days to February 22, 2013.

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2. The parties’ last day to meet and confer regarding initial disclosures, early settlement,

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ADR process, and discovery plan; to file ADR certification; and to file either

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Stipulation to ADR Process or Notice of Need for ADR Phone Conference shall be

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extended 29 days to Friday, March 8, 2013.

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3. The parties’ last day to file the Rule 26(f) Report, complete initial disclosures or state

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objections in that Rule 26(f) Report and file a Case Management Statement per the

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Court’s Standing Order re Contents of Joint Case Management Statements shall be

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extended 29 days to Friday, March 22, 2013.
4. The Initial Case Management Conference shall be rescheduled by the Court to a date

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on or after Friday, March 29, 2013.

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STIP. AND [PROPOSED] ORDER TO
EXTEND TIME TO RESPOND

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CASE NO. 12-CV-06060-MEJ
PLDOCS01/74639.3

1 Dated: December 19, 2012

SHEARMAN & STERLING LLP

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By:

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/s/ Vicki Veenker
Vicki S.Veenker
Joshua C. Walsh-Benson
Benjamin Petersen

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Attorneys for Defendant
GRASS VALLEY USA, LLC

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NIRO, HALLER & NIRO
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By:

/s/ Martin Fineman
Martin L. Fineman
Raymond P. Niro
Joseph N. Hosteny
Arthur A. Gasey

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Attorneys for Plaintiff
TECHNOLOGY LICENSING
CORPORATION

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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22 Dated: December 20, 2012
The Honorable Maria-Elena James
United States Magistrate Judge

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STIP. AND [PROPOSED] ORDER TO
EXTEND TIME TO RESPOND

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CASE NO. 12-CV-06060-MEJ
PLDOCS01/74639.3

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GENERAL ORDER 45 X.B. – ATTESTATION

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I, Vicki Veenker, am the ECF User whose ID and password are being used to file this

3 STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO
4 COMPLAINT. In compliance with General Order 45, X.B., I hereby attest that other counsel
5 whose e-signature appears on the foregoing signature page has concurred with this filing.
6 Dated: December 19, 2012

/s/ Vicki Veenker
Vicki Veenker

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STIP. AND [PROPOSED] ORDER TO
EXTEND TIME TO RESPOND

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CASE NO. 12-CV-06060-MEJ
PLDOCS01/74639.3