1st Technology LLC v. IQ-Ludorum, PLC, et al

Filing 23

1st Technology LLC v. IQ-Ludorum, PLC, et al

Doc. 23

Case 2:06-cv-00323-LDG-RJJ

Document 23

Filed 07/25/2006

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JOANNA S. KISHNER, ESQ. State Bar No. 5037 [e-mail] PAUL T. TRIMMER, ESQ. State Bar No. 9291 [e-mail] DLA PIPER RUDNICK GRAY CARY US LLP 3960 Howard Hughes Parkway Suite 400 Las Vegas, Nevada 89109 [phone] Attorneys for Defendant IQ-LUDORUM PLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 1ST TECHNOLOGY LLC, Plaintiff, v. IQ-LUDORUM PLC, PLAYTECH CYPRUS LTD., TILTWARE LLC, and KOLYMA CORPORATION, A.V.V., Defendants. ) ) ) ) ) Case No.: ) ) ) ) ) ) )

2:06-cv-00323-LDG-RJJ

STIPULATION AND REQUEST TO EXTEND TIME FOR DEFENDANT IQLUDORUM PLC TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT (Third Request) It is hereby requested by Defendant in this case, IQ-Ludorum PLC (hereinafter referred

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to as "Defendant") through its respective counsel, that Defendant shall have until August 1, 2006, in which to file a Motion to Dismiss, answer, plead or otherwise respond to Plaintiff's Complaint, with Defendant specially reserving any jurisdictional defenses. 1. 2. This is an action for alleged patent infringement. This is the third request for an extension of time for Defendant to answer, plead

Dockets.Justia.com

Case 2:06-cv-00323-LDG-RJJ

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Filed 07/25/2006

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Plaintiffs filed a Complaint on March 15, 2006. A previous stipulated request for an extension of time for Defendant to answer,

plead or otherwise respond to Plaintiff's Complaint set the due date for Defendant's response as July 25, 2006. 5. An additional extension is necessary for counsel to continue settlement

negotiations. The parties have initiated communications in an effort to resolve this matter pursuant to settlement and have made good progress in their efforts. In the past few days, the

8 9 10 11 12 13 14 respond to Plaintiff's Complaint. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated:
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parties have exchanged settlement offers that would resolve all of the issues in the case, and those offers are under consideration. The requested extension will allow the parties to continue to focus on these discussions. 6. Counsel for Defendant spoke with Plaintiff's counsel who is in agreement with

the request for an extension until August 1, 2006 for Defendant to answer, plead or otherwise

7.

This request is made in good faith and not for the purpose of delay.

Dated this 25th day July, 2006. DLA PIPER RUDNICK GRAY CARY US LLP /s/ Joanna S. Kishner Joanna S. Kishner, Esq. Paul T. Trimmer, Esq. 3960 Howard Hughes Parkway Suite 400 Las Vegas, Nevada 89109 Attorneys for Defendant IQ-Ludorum PLC HUTCHINSON & STEFFEN, LLC /s/ L. Kristopher Rath L. Kristopher Rath, Esq. Peccole Professional Park 10080 Alta Drive Suite 200 Las Vegas, Nevada 89145 Attorneys for Plaintiff

IT IS SO ORDERED. Judge, U.S. District Court

Case 2:06-cv-00323-LDG-RJJ

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CERTIFICATE OF SERVICE Pursuant to Special Order #109, counsel of record registered for the CM/ECF system have been served with the foregoing Stipulation and Request to Extend Time for Defendant IQ-Ludorum PLC to Answer or Otherwise Respond to Complaint by electronic means. In addition, pursuant to Fed. R. Civ. P. 5(b), I hereby certify that the service of the same was made this day by depositing a true copy of the same for mailing at Las Vegas, Nevada, addressed to: Michael J. McCue, Esq. Lewis & Roca 3993 Howard Hughes Parkway Suite 600 Las Vegas, Nevada 89109 this 25th day of July, 2006. /s/ Paul Trimmer An Employee Of DLA Piper Rudnick Gray Cary US LLP

Doc. #4816383