Hangingout, Inc. v. Google, Inc.

Filing 12

MOTION for Preliminary Injunction by Hanginout, Inc. (Attachments: # 1 Memo of Points and Authorities, # 2 Declaration of Justin Malone, # 3 Notice of Lodgment of Non-Electronic Exhibits Submitted, # 4 Table of Exhibits to Declaration of Justin Malone, # 5 Exhibit 1 , # 6 Exhibit 2, # 7 Exhibit 3, # 8 Exhibit 4 , # 9 Exhibit 5 , # 10 Exhibit 6 , # 11 Exhibit 7, # 12 Exhibit 8, # 13 Exhibit 9, # 14 Exhibit 10, # 15 Exhibit 11, # 16 Exhibit 12, # 17 Exhibit 13, # 18 Exhibit 14, # 19 Exhibit 15, # 20 Exhibit 16, # 21 Exhibit 17 , # 22 Exhibit 18 , # 23 Exhibit 19 , # 24 Exhibit 20, # 25 Exhibit 21, # 26 Exhibit 22, # 27 Exhibit 23, # 28 Exhibit 24 , # 29 Exhibit 25, # 30 Exhibit 26, # 31 Exhibit 27, # 32 Exhibit 28, # 33 Exhibit 29, # 34 Exhibit 30, # 35 Exhibit 31, # 36 Proof of Service)(Skale, Andrew) (Modified to remove excess text on 1/24/2014) (cge).

1 Andrew D. Skale (SBN 211096)

[e-mail]

2 Justin S. Nahama (SBN 281087)

[e-mail]

3 MINTZ LEVIN COHN FERRIS GLOVSKY AND POPEO P.C.

3580 Carmel Mountain Road, Suite 300

4 San Diego, CA 92130

Telephone: [phone]

5 Facsimile: [phone]
6 Attorneys for Plaintiff

HANGINOUT, INC.

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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF CALIFORNIA

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11 HANGINOUT, INC., a Delaware

Case No. 3:13-cv-02811-AJB-NLS

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PLAINTIFF HANGINOUT, INC.’S
NOTICE OF MOTION AND MOTION
FOR PRELIMINARY INJUNCTION

corporation,

Plaintiff,

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vs.

GOOGLE, INC., a Delaware
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Defendant.

Date:
March 13, 2014
Time:
2:00 p.m.
Courtroom 3B
The Honorable Anthony Battaglia

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PLEASE TAKE NOTICE THAT, on March 13, 2014, at 2:00 p.m., or as soon

19 thereafter as the matter may be heard in Courtroom 3B of the above-entitled court,
20 located at 880 Front Street, San Diego, California 92101, Plaintiff, HANGINOUT,
21 INC. (“Plaintiff” or “Hanginout”) will move for an order for preliminary injunction
22 requiring GOOGLE, INC. to cease use of the term “Hangouts” in its messaging
23 platforms and social media, cease use of its Hangouts Question and Answer platform,
24 and cease advertising and solicitation utilizing the term “Hangouts” in connection
25 with its messaging platform; or, in the alternative, cease any new uses of the term
26 “Hangouts” in California.
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Case No. 3:13-cv-02811-AJB-NLS

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This Motion is based upon this Notice of Motion and Motion, the

2 Memorandum of Points and Authorities in support thereof, the declaration of Justin
3 Malone In Support of Plaintiff’s Motion for Preliminary injunction and the evidence
4 submitted concurrently therewith, the papers submitted in reply supporting the
5 Motion, the papers and pleadings on file in this action, matters subject to judicial
6 notice, and such other evidence or argument that may be presented at or before the
7 hearing on the motion.
8 Dated: January 22, 2014
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MINTZ LEVIN COHN FERRIS GLOVSKY
AND POPEO PC
By /s/Andrew D. Skale
Andrew D. Skale
Justin S. Nahama

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Attorneys for Plaintiff
HANGINOUT, INC.

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25581898v.1

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Case No. 3:13-cv-02811-AJB-NLS