Personalized User Model LLP v. Google Inc.

Filing 334

STIPULATION (STIPULATION FOR LEAVE FOR GOOGLE INC. TO FILE SECOND AMENDED ANSWER AND COUNTERCLAIMS) by Google Inc.. (Moore, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, L.L.P.,
Plaintiff,
v.
GOOGLE INC.,
Defendant.
GOOGLE, INC.
Counterclaimant,
v.
PERSONALIZED USER MODEL, LLP and
YOCHAI KONIG
Counterdefendants.

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C.A. No. 09-525-LPS
JURY TRIAL DEMANDED

STIPULATION FOR LEAVE FOR GOOGLE INC. TO FILE
SECOND AMENDED ANSWER AND COUNTERCLAIMS
WHEREAS, the parties have agreed that Defendant Google Inc.(“Google”) may file
Google Inc.’s Second Amended Answer and Defenses to Personalized User Model, LLP’s First
Amended Complaint for Patent Infringement and Google Inc.’s Amended Counterclaims Against
Personalized User Model, LLP and Yochai Konig (“Google’s Amended Answer”), as set forth in
Exhibit 1, subject to Plaintiff Personalized User Model LLP’s (PUM) and Yochai Konig’s
(“Konig”) reservation of rights to contest the merits of, and take any and all actions in response
to, the Amended Answer;
WHEREAS, the parties have agreed that PUM and Konig shall have 35 days to answer,
move or otherwise respond to Google’s Second Amended Answer;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and among the parties, subject
to the approval of the Court, that Google shall have leave to file Google’s Second Amended

Answer, as attached as Exhibit 1, and that PUM shall have 35 days to answer, move or otherwise
respond to Google’s Second Amended Answer.

MORRIS, NICHOLS, ARSHT & TUNNELL
LLP

POTTER ANDERSON & CORROON LLP

By: /s/ Karen Jacobs Louden
Karen Jacobs Louden (#2881)
Jeremy A. Tigan (#5239)
1201 N. Market Street
Wilmington, DE 19801
[phone]
[e-mail]
[e-mail]

By: /s/ David E. Moore
Richard L. Horwitz (#2246)
David E. Moore (#3983)
Hercules Plaza, 6th Floor
1313 N. Market Street
Wilmington, DE 19801
Tel: [phone]
[e-mail]
[e-mail]

Attorneys for Plaintiff Personalized User
Model, L.L.P.

Attorneys for Defendant Google, Inc.

IT IS SO ORDERED this _______ day of __________, 2011.

_______________________________________
U.S.D.J.

1039317 / 34638

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