Vulcan Golf, LLC v. Google Inc. et al

Filing 15

MOTION by Defendant Google Inc. for extension of time to Answer or Otherwise Plead (Agreed) (Attachments: # 1 Exhibit A)(Moran, Mariah)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 15 Case 1:07-cv-03371 Document 15 Filed 07/10/2007 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC., Individually and on behalf of all Others Similarly Situated, Lead Plaintiff, v. GOOGLE INC., OVERSEE.NET, SEDO LLC, DOTSTER, INC., AKA REVENUEDIRECT.COM INTERNET REIT, INC. d/b/a IREIT, INC., and JOHN DOES I-X, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 07 CV 3371 Judge Kocoras Magistrate Judge Brown AGREED MOTION FOR EXTENSION OF TIME FOR DEFENDANT GOOGLE, INC. TO ANSWER OR OTHERWISE PLEAD Defendant Google, Inc. ("Google"), by and through its attorneys, respectfully move this Court to extend until August 10, 2007 the date by which Google must answer or otherwise plead to the Class Action Complaint ("Complaint"). In support of this motion, Defendant Google states as follows: 1. On June 15, 2007, Plaintiff filed the Complaint in this matter. Google was served with a copy of the Summons and Complaint on June 20, 2007. Accordingly, Google's responsive pleading currently is due on July 10, 2007. 2. The Complaint is 121 pages in length, contains at least 638 paragraphs and asserts class action claims alleging infringement and deceptive practices of registered marks, trade names, logos and other distinctive/valuable marks. 3. Given the extraordinary size of the Complaint and the nature of the claims raised Case 1:07-cv-03371 Document 15 Filed 07/10/2007 Page 2 of 2 therein, Defendant Google respectfully submits that it will need an additional 30 days to properly review and digest the Complaint to adequately prepare a responsive pleading. 4. Plaintiff's counsel has been apprised of the basis of this motion and agrees to the terms set forth herein. Attached hereto as Exhibit A is a signed Stipulation and Proposed Order Extending Defendant's Time in Which to Answer or Otherwise Plead. WHEREFORE, for the foregoing reasons, Defendant Google, Inc., respectfully requests that the Court extend until August 10, 2007, the date by which it must answer or otherwise plead to the Class Action Complaint. Respectfully submitted: GOOGLE, INC. By: /s/ Mariah E. Moran One of Google, Inc.'s Attorneys Joseph J. Duffy Jonathan M. Cyrluk Mariah E.Moran STETLER & DUFFY, LTD. 11 South LaSalle Street Suite 1200 Chicago, IL 60603 Tel: (312) 338-0200 Fax: (312) 338-0070 2

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