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

Filing 68

Joint MOTION for Extension of Time to File for Extension of Deadline for Serving Third-Party Subpoenas by Web Tracking Solutions, Inc., Daniel Wexler. (Flynn, Edward)

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

Doc. 68

July 16, 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

Dear Judge Reyes: The parties jointly request a further extension of the time for serving third-party subpoenas in this case. As we explained in our prior request, the parties encountered significant technical difficulties in connection with the production of a large number of third-party documents. The documents have recently been re-produced, and with the exception of a relatively few number of documents, the technical issues appear to have been resolved. The parties respectfully request this extension so as to allow for additional time to fully review these documents and identify all third party witnesses who may need to be subpoenaed. In addition, since claims constructions may well influence the scope of third-party witnesses that may be necessary in this case, the parties would suggest that the deadline be reset for thirty (30) days after the Court issues its claims construction ruling. Alternatively, we would request the time be extended to August 20, 2010. We again thank the Court for its consideration. Respectfully submitted, /s/ Edward C. Flynn______ Edward C. Flynn ECKERT SEAMANS CHERIN & MELLOTT, LLC U.S. Steel Building 600 Grant Street, 44th Floor Pittsburgh, PA 15219 Tel: [phone] Fax: [phone] [e-mail] Counsel for Plaintiffs /s/ Edward J. DeFranco______ QUINN EMANUEL URQUHART & SULLIVAN 51 Madison avenue, 22nd Floor New York, NY 10010 Tel: [phone] Fax: [phone] [e-mail] Counsel for Defendant

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