Hangingout, Inc. v. Google, Inc.

Filing 9

MOTION to Dismiss for Failure to State a Claim by Google, Inc.. (Attachments: # 1 Memo of Points and Authorities, # 2 Declaration of Margret M. Caruso, # 3 Exhibit 1 to Caruso Declaration)(Caruso, Margaret)Attorney Margaret M. Caruso added to party Google, Inc.(pty:dft) (kaj).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP

Margret M. Caruso (Bar No. 243473)
Cheryl A. Galvin (Bar No. 252262)
555 Twin Dolphin Drive, 5th Floor
3 Redwood Shores, California 94065-2139
Telephone: [phone]
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5 Attorneys for Defendant Google Inc.
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UNITED STATES DISTRICT COURT

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SOUTHERN DISTRICT OF CALIFORNIA

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13 HANGINOUT, INC,

Plaintiff,

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vs.

16 GOOGLE INC.,
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Defendant.

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CASE NO. 13-CV-2811 JAH NLS
NOTICE OF MOTION AND
MOTION TO DISMISS
ORAL ARGUMENT REQUESTED
Date: March 3, 2014
Time: 2:30 p.m.
Courtroom 13B
Judge: Hon. John A. Houston

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-1NOTICE OF MOTION AND MOTION TO DISMISS

Case No. 13-CV-2811 JAH NLS

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TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF

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PLEASE TAKE NOTICE that on March 3, 2014 at 2:30 p.m., or as soon

4 thereafter as may be heard before the Honorable John A. Houston of the Southern
5 District of California, in Courtroom 13B of the United States Courthouse Annex
6 located at 333 West Broadway, San Diego, CA 92101, Defendant Google Inc. will
7 and does hereby move to dismiss, pursuant to Federal Rule of Civil Procedure
8 12(b)(6), Plaintiff Hanginout, Inc.’s Complaint.
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This motion is based on this Notice of Motion and Motion to Dismiss, the

10 Memorandum of Points and Authorities in Support of Google’s Motion to Dismiss,
11 the accompanying declaration of Margret M. Caruso and the exhibit thereto, the
12 pleadings, records, and files in this action, all matters which are properly the subject
13 of judicial notice, and such other evidence and argument as may be properly
14 presented prior to and at the hearing on this motion.
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16 DATED: January 10, 2014
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Respectfully submitted,
QUINN EMANUEL URQUHART
& SULLIVAN, LLP

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/s/ Margret M. Caruso
Margret M. Caruso
Attorneys for Defendant Google Inc.

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-2NOTICE OF MOTION AND MOTION TO DISMISS

Case No. 13-CV-2811 JAH NLS

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CERTIFICATE OF SERVICE
I hereby certify that on January 10, 2014, I will cause to be filed the foregoing

3 NOTICE OF MOTION AND MOTION TO DISMISS with the Clerk of the
4 Court using the CM/ECF system, which will then send a notification of such filing
5 to counsel for Plaintiff Hanginout, Inc.
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QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By /s/ Margret M. Caruso
Margret M. Caruso
Attorneys for Defendant Google Inc.
[e-mail]

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-3NOTICE OF MOTION AND MOTION TO DISMISS

Case No. 13-CV-2811 JAH NLS