Software Research, Inc. v. Dynatrace LLC

Filing 20

STIPULATION AND ORDER re 19 to Extend Dynatrace's Time to Respond to Plaintiff's Complaint filed by Dynatrace LLC. Signed by Judge Edward M. Chen on 3/2/18. (bpf, COURT STAFF) (Filed on 3/2/2018)

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DUANE MORRIS LLP
Karineh Khachatourian (CA SBN 202634)
[e-mail]
Daniel T. McCloskey (CA SBN 191944)
[e-mail]
2475 Hanover Street
Palo Alto, CA 94304-1194
Telephone: [phone]
Facsimile: 650.847.4151
Attorneys for Defendant,
DYNATRACE LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SOFTWARE RESEARCH, INC.,
Plaintiff,
v.
DYNATRACE LLC,

Case No.: 18-cv-00232-EMC
SECOND STIPULATION AND
[PROPOSED] ORDER TO EXTEND
DYNATRACE LLC’S TIME TO
ANSWER OR OTHERWISE RESPOND
TO PLAINTIFF’S COMPLAINT

Defendant.

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Pursuant to Civil L.R. 6-1(b), Plaintiff Software Research, Inc. (“Plaintiff”) and Defendant

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Dynatrace LLC (“Dynatrace”), by and through their undersigned attorneys, hereby state and

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stipulate as follows:

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WHEREAS, Plaintiff served Dynatrace with the Complaint and associated documents in
this action on or about January 18, 2018;
WHEREAS, absent an extension, Dynatrace’s deadline to answer or otherwise respond to
the Complaint was February 8, 2018;
WHEREAS, Plaintiff and Dynatrace agreed to an initial extension to answer, or otherwise

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respond to the Complaint by 30 days, i.e., to March 12, 2018;

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WHEREAS, Plaintiff and Defendant agree to an additional extension of time for Defendant
DM2\8630566
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SECOND STIPULATION AND [PROPOSED] ORDER TO EXTEND DYNATRACE’S TIME TO RESPOND TO COMPLAINT
CASE NO.: 18-cv-00232-EMC

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to respond to the Complaint up to and including April 5, 2018, so that Defendant can have

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additional time to investigate this matter and the parties may explore the possibility of settlement;

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WHEREAS the initial Case Management Conference is currently scheduled for April 19,

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2018. As such, the parties’ stipulated extension of time will not impact any other court-ordered

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deadlines in the case.

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NOW THEREFORE, IT IS STIPULATED AND AGREED that Dynatrace’s deadline to
answer or otherwise respond to the Complaint is April 5, 2018.

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DUANE MORRIS LLP

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Dated: March 1, 2018

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By: /s/ Karineh Khachatourian
Karineh Khachatourian
Daniel T. McCloskey

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Attorneys for Defendant,
DYNATRACE LLC

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SINGER BEA LLP

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Dated: March 1, 2018

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By: /s/ Benjamin L. Singer
Benjamin L. Singer
Evan N. Budaj
Attorneys for Plaintiff,
SOFTWARE RESEARCH, INC.

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[PROPOSED ORDER]

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Pursuant to the stipulation of the parties and good cause appearing, Defendant Dynatrace

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LLC’s deadline to respond to Plaintiff Software Research, Inc.’s Complaint is hereby continued to

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April 5, 2018. No other deadlines shall be affected by this Order.
IT IS SO ORDERED.
S

ERED

FO

Jud

R NIA

HONORABLE EDWARD M. CHEN
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United States dDistrictheJudge
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O ORD
IT IS S

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3/2/18

NO

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DATED:

UNIT
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SECOND STIPULATION AND [PROPOSED] ORDER TO EXTEND DYNATRACE’S TIME TO RESPOND TO COMPLAINT
ER
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CASE NO.: 18-cv-00232-EMCD
OF
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IS T RIC T

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ATTESTATION
Pursuant to Civil L.R. 5-1(i)(3) regarding signatures, I attest under penalty of perjury that
the concurrence in the filing of this document has been obtained from its signatories.

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DUANE MORRIS LLP

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Dated: March 1, 2018

By: /s/ Karineh Khachatourian
Karineh Khachatourian
Daniel T. McCloskey

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Attorneys for Defendant,
DYNATRACE LLC

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SECOND STIPULATION AND [PROPOSED] ORDER TO EXTEND DYNATRACE’S TIME TO RESPOND TO COMPLAINT
CASE NO.: 18-cv-00232-EMC