Red Bend Software, Inc. et al v. Google

Filing 80

Joint MOTION for Extension of Time to June 1, 2010 to Exchange Claim Terms and Proposed Constructions by Red Bend Software, Inc., Red Bend, Ltd..(Tempesta, Jennifer)

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS RED BEND LTD. and RED BEND SOFTWARE INC., Plaintiffs, v. GOOGLE INC., Defendant. GOOGLE INC., Counterclaim-Plaintiff, v. RED BEND LTD. and RED BEND SOFTWARE INC., Counterclaim-Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CIVIL ACTION NO. 09-cv-11813

JOINT MOTION TO EXTEND DEADLINE FOR EXCHANGE OF CLAIM TERMS AND PROPOSED CONSTRUCTIONS Pursuant to Local Rule 7.1, the parties in the above-captioned action jointly move for an Order of the Court granting a three (3) day extension from Friday, May 28, 2010 to Tuesday, June 1, 2010 to exchange their claim terms for construction and proposed constructions (the "Terms and Constructions"). The Terms and Constructions are due to be exchanged on Friday, May 28, 2010. As grounds for this Motion, the parties state that they seek the additional time so as to be able to respond fully and succinctly to the claims and terms at issue in the case. WHEREFORE, the parties respectfully request that the Court grant this joint motion for extension to exchange their Terms and Constructions to Tuesday, June 1, 2010.

A/73393533.1/3005005-0000343244

Respectfully Submitted this 28th day of May 2010, RED BEND LTD, RED BEND SOFTWARE INC. By its attorneys, /s/ Jennifer C. Tempesta . GOOGLE, INC. By its attorneys, /s/ David M. Magee Jonathan M. Albano, BBO # 013850 [e-mail] David M. Magee, BBO # 652399 [e-mail] BINGHAM McCUTCHEN LLP One Federal Street Boston, MA 02110-1726, U.S.A. 617.951.8000 William F. Abrams [e-mail] BINGHAM McCUTCHEN LLP 1900 University Avenue East Palo Alto, CA 94303-2223 650.849.4400 Robert C. Bertin [e-mail] Susan Baker Manning [e-mail] BINGHAM McCUTCHEN LLP 2020 K Street, NW Washington, DC 20006-1806 202.373.6000 .

Daniel Cloherty (BBO# 565772) Dwyer & Collora, LLP 600 Atlantic Avenue - 12th Floor Boston, MA 02210-2211 Telephone: [phone] Facsimile: [phone] Robert C. Scheinfeld (admitted PHV) Eliot D. Williams (admitted PHV) Jennifer C. Tempesta (admitted PHV) Baker Botts, L.L.P. 30 Rockefeller Plaza 44th Floor New York, New York 10012-4498 Telephone: [phone] Facsimile: [phone]

Certificate of Service I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent to those indicated as non-registered participants, by Federal Express, on May 28, 2010. /s/ Jennifer C. Tempesta

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