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

Filing 70

Joint MOTION for Extension of Time to File Objections to Report and Recommendation (dkt. 69) by Google, Inc., Web Tracking Solutions, Inc., Daniel Wexler. (Curran, Patrick)

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

Doc. 70

August 3, 2010 Via Electronic Filing The Honorable Roslyn R. Mauskopf United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Magistrate Judge Ramon E. Reyes, Jr. United States District Court Eastern District of New York 225 Cadman Plaza East, Room 263 Brooklyn, New York 11201 Re: Web Tracking Solutions, LLC and Daniel Wexler v. Google, Inc. No. 1:08-cv-03139

Dear Judge Mauskopf and Magistrate Judge Reyes: The parties are writing jointly to request certain amendments to the schedule in the abovereferenced case in light of the Report and Recommendation on the claim constructions at issue in this patent case ("R&R"), Docket Entry No. 69, that issued on July 27, 2010. First, the parties jointly request an extension of time for filing objections to the R&R. Objections are currently due to be filed on August 10, 2010, and responses to objections are due to be filed on August 20, 2010. The parties respectfully request that the time for filing objections be extended to August 31, 2010, and the time for filing responses to objections to September 30, 2010. This request is based on commitments the parties have in other matters, as well as personal obligations for several attorneys involved in the case. Second, the parties have agreed, subject to any contrary view of the Court, to not pursue further fact discovery pending the District Court's ruling on objections to the R&R (there is no date for the close of fact discovery in the current case schedule). The reason for this agreement is that the scope of necessary discovery in the case will likely be significantly impacted by the final ruling on claim construction issues. The parties are available for a telephonic conference to address any issues raised by this request. The parties thank the Court for its consideration.

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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] m 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] m Counsel for Defendant