Web Tracking Solutions, Inc. et al v. Google, Inc.

Filing 45

Joint MOTION for Extension of Time to File Markman briefing by Google, Inc., Web Tracking Solutions, Inc., Daniel Wexler. (Curran, Patrick)

Web Tracking Solutions, Inc. et al v. Google, Inc.

Doc. 45

Case 1:08-cv-03139-RRM -RER Document 45

Filed 02/11/10 Page 1 of 3

February 11, 2010 VIA ELECTRONIC FILING Magistrate Judge Ramon E. Reyes, Jr. United States District Court Eastern District of New York United States Courthouse 225 Cadman Plaza East, Room 263 Brooklyn, NY 11201 Re: Web Tracking Solutions, LLC and Daniel Wexler v. Google Inc., No. 1:08-cv-03139

Your Honor: The parties submit this joint request for certain amendments to the briefing schedule for claim construction in the above-referenced case. These changes will assist in the mutual accommodation of witness schedules for upcoming depositions, and avoid unnecessary discovery disputes. These changes would not alter the April 30, 2010 date for the claim construction hearing. The below chart summarizes the parties' requested revisions to the case schedule: Event Filing of Markman briefs and disclosure and exchange of Markman expert reports, affidavits, or declarations. Filing of responsive Markman briefs and disclosure and exchange of rebuttal Markman expert reports, affidavits, or declarations. Original Deadline February 22, 2010 Revised Deadline March 12, 2010

March 29, 2010

April 9, 2010

01980.51462/3321353.1

Dockets.Justia.com

Case 1:08-cv-03139-RRM -RER Document 45

Filed 02/11/10 Page 2 of 3

Attached hereto as Exhibit A is a draft order granting these requested changes. The parties are available to discuss these matters at Your Honor's convenience. Respectfully submitted,

/s/ Steven M. Hayes Steven M. Hayes HANLY CONROY BIERSTEIN FISHER & HAYES 112 Madison Avenue, 7th Floor New York, NY 10016 [phone] [e-mail] Counsel for Plaintiffs

/s/ Edward J. DeFranco Edward J. DeFranco QUINN EMANUEL URQUHART OLIVER & HEDGES 51 Madison Avenue, 22nd Floor New York, NY 10010 [phone] [e-mail] Counsel for Defendant

01980.51462/3321353.1

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Case 1:08-cv-03139-RRM -RER Document 45

Filed 02/11/10 Page 3 of 3

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK WEB TRACKING SOLUTIONS, LLC. and DANIEL WEXLER, Plaintiffs, v. GOOGLE, INC. Defendant. [PROPOSED] REVISED SCHEDULING ORDER Case No. 1:08-cv-03139 (RRM) (RER)

The Parties having now jointly requested certain amendments to the current case schedule, IT IS ORDERED that: 1. The parties shall file Markman briefs and make related exchanges and disclosures

on or before March 12, 2010. 2. The parties shall file responsive Markman briefs and make related exchanges and

disclosures on or before April 9, 2010. 3. All other provisions of the Scheduling Order, including deadlines not altered

above, remain in effect.

________________________ HON. RAMON E. REYES, JR. United States Magistrate Judge

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