Vulcan Golf, LLC v. Google Inc. et al

Filing 36

MOTION by Defendant Dotster, Inc. for extension of time to file answer or otherwise plead (Conlon, Alison)

Vulcan Golf, LLC v. Google Inc. et al

Doc. 36

Case 1:07-cv-03371

Document 36

Filed 07/27/2007

Page 1 of 3

IN THE UNITED STATE 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, 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 DOTSTER, INC. AKA REVENUEDIRECT.COM TO ANSWER OR OTHERWISE PLEAD Defendant Dotster, Inc. aka RevenueDirect.com ("Dotster"), by its attorneys, respectfully moves this Court to extend until August 15, 2007 the date by which Dotster must answer or otherwise plead to the Class Action Complaint in Law and Equity ("Class Action Complaint"). In support of this motion, Dotster states: 1. On June 15, 2007, Plaintiff filed the Class Action Complaint. Dotster was served

with a copy of the Summons and Class Action Complaint on July 5, 2007 and its deadline to answer or otherwise plead is July 25, 2007. 2. The Class Action Complaint is 121 pages long and alleges infringement and

deceptive practices of registered marks, trade names, logos and other distinctive/valuable marks. 3. Given the length of the Class Action Complaint and the nature of its claims,

Dockets.Justia.com

Case 1:07-cv-03371

Document 36

Filed 07/27/2007

Page 2 of 3

Dotster respectfully requests an additional twenty-one (21) days to properly review the pleading and prepare an adequate responsive pleading. 4. Dotster's counsel has conferred with Plaintiff's counsel about the proposed

extension and Plaintiff's counsel has agreed to a twenty-one (21) day extension to August 15, 2007 for Dotster to answer or otherwise plead. Dotster's responsive pleading will be filed prior to the next status date of August 21, 2007 and will not cause any undue delay. 5. All other defendants who have appeared have obtained extensions of their time to

answer or otherwise plead. 6. Pursuant to the Court's Case Management Procedures, Dotster will submit a

Proposed Order in electronic form to the Court's email address with a copy to all counsel of record. WHEREFORE, Defendant Dotster, Inc. aka RevenueDirect.com respectfully requests that the Court extend until August 15, 2007 the date by which it must answer or otherwise plead to the Class Action Complaint. Dated: July 27, 2007 Respectfully submitted, s/ Alison C. Conlon One of the Attorneys for Dotster, Inc. aka RevenueDirect.com Michael Dockterman (03121675) Alison C. Conlon (6272083) Wildman, Harrold, Allen & Dixon LLP 225 West Wacker Drive, Suite 2800 Chicago, Illinois 60606-1229 Phone: [phone] Fax: [phone]

2

Case 1:07-cv-03371

Document 36

Filed 07/27/2007

Page 3 of 3

CERTIFICATE OF SERVICE

The undersigned certifies that on July 27, 2007, a true and correct copy of the foregoing Agreed Motion For Extension of Time for Defendant Dotster, Inc. aka Revenuedirect.Com to Answer or Otherwise Plead, , was electronically filed with the Clerk of the Court for the Northern District of Illinois using the CM/ECF system. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's CM/ECF system.

__/s/ Alison C. Conlon___________________ Alison C. Conlon (6272083) Wildman, Harrold, Allen & Dixon LLP 225 West Wacker Drive, Suite 2800 Chicago, Illinois 60606-1229 Phone: [phone] Fax: [phone] Attorney for Dotster, Inc. aka RevenueDirect.com

3