Vulcan Golf, LLC v. Google Inc. et al

Filing 51

MOTION by Defendant Sedo LLC for leave to file excess pages (Martin, Misty)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 51 Case 1:07-cv-03371 Document 51 Filed 08/10/2007 Page 1 of 3 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, ) ) ) ) ) Vs. ) ) GOOGLE INC., OVERSEE NET, ) SEDO, LLC, [misnamed] DOTSTER, INC., AKA ) INTERNET REIT, INC., d/b/a IREIT, INC., ) And JOHN DOES I-X ) Defendants. ) No. 07 CV 3371 Judge Kocoras Magistrate Judge Brown DEFENDANT SEDO.COM, LLC'S MOTION FOR LEAVE TO FILE MOTION TO DISMISS IN EXCESS OF 15 PAGES Defendant,, LLC, (misnamed Sedo, LLC) ("Sedo"), by its attorneys, hereby requests the court pursuant to Local Rule 7.1 to grant leave to file a motion in excess of 15 pages and in support thereof states as follows: 1. On June 19, 2007, Plaintiff, Vulcan Golf, LLC, filed a 12-Count Class Action Complaint in Law and Equity against the above-captioned defendants alleging violations of RICO under 18 U.S.C. 1962(e) and (d), Cybersquatting under 15 U.S.C. 1125(d), Trademark Infringement under 15 U.S.C. 1114(1), False Designation of Origin under 15 U.S.C. 1125(a), Dilution under 15 U.S.C. 1125(c), Consumer Fraud, Common Law Trademark Violations, Contributory Trademark Infringement, Intentional Interference with Current and Prospective Economic Advantage, and Unjust Enrichment. (See Docket Document #1) 2. pages. 3. Defendant, Sedo, intends to file a Motion to Dismiss Plaintiff's Complaint. Plaintiff's complaint contains 638 paragraphs and comprises more than 120 Case 1:07-cv-03371 Document 51 Filed 08/10/2007 Page 2 of 3 4. Due to the complex nature of the allegations and claims made in this case, the number of legal claims made by Plaintiff, the number of Defendants, and the sheer volume of Plaintiff's Complaint, Defendant, Sedo, respectfully request 30 pages in which to Draft a Motion to Dismiss Plaintiff's Complaint. 5. to this motion. WHEREFORE, Defendant, Sedo, prays this Court grant it leave to file its Motion to Dismiss and Memorandum in Support Thereof in excess of 15 pages. Defendant has contacted Plaintiff with this request and Plaintiff has no objection Respectfully submitted, By: Jeffrey Singer (ARDC # 2670510) Misty R. Martin (ARDC # 6284999) Segal McCambridge Singer & Mahoney 233 South Wacker Drive Sears Tower Suite 5500 Chicago, IL 60606 (312) 645-7800 (t) (312) 645-4463 (f) /s/ Jeffrey Singer On behalf of, LLC 2 Case 1:07-cv-03371 Document 51 Filed 08/10/2007 Page 3 of 3 Certificate of Service I, Misty R. Martin, attorney of record for defendant, certify that on August 10, 2007, a copy of this document was served on counsel of record for the plaintiff via the court's electronic filing system. __/s/ Misty R. Martin____ 3

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