Unites States of America v. Apple, Inc. et al

Filing 345

MOTION for Leave to File An Amicus Curiae Brief In Support of Proposed Final Judgment. Document filed by Kobo Inc.. (Attachments: # 1 Certificate of Service)(Wallance, Gregory)

Unites States of America v. Apple, Inc. et al

Doc. 34

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,
Plaintiff,
v.
APPLE, INC., et al.,
Defendants.

THE STATE OF TEXAS, et al.,
Plaintiffs,
v.
PENGUIN GROUP (USA) INC., et al.,
Defendants.

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Civil Action No. 12-cv-2826 (DLC)

Civil Action No. 12-cv-03394 (DLC)

NOTICE OF MOTION OF PROPOSED AMICUS CURIAE KOBO INC. FOR LEAVE TO
FILE AN AMICUS CURIAE BRIEF IN SUPPORT OF PROPOSED FINAL JUDGMENT
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Proposed
Amicus Curiae Kobo Inc. in Support of Proposed Final Judgment, Kobo Inc. (“Kobo”) hereby
moves this Court, before Judge Denise M. Cote at the United States District Court for the
Southern District of New York, 500 Pearl Street, New York, New York, for leave to file its
proposed amicus brief in support of the Proposed Final Judgment, which was filed with the court
on August 2, 2013.

61415046_3.docx

Dockets.Justia.com

Kobo notes that on August 7, 2013, Kobo filed a letter with the Court requesting
permission to file a short amicus brief, which was granted by endorsement on August 8, 2013.
On August 8, 2013, Kobo filed an additional letter with the Court providing more details
regarding Kobo’s request for permission. On August 8, 2013, Kobo received reaffirmation from
the Court of its permission to file an amicus brief.
Additional grounds for this motion are more fully set forth in the accompanying
memorandum of law.

August 8, 2013

Respectfully Submitted,
/s/ Gregory J. Wallance_____________
Gregory J. Wallance
Kaye Scholer LLP
425 Park Avenue
New York, NY 10022
[phone]
Robert B. Bell* (pro hac vice pending)
Kaye Scholer LLP
901 Fifteenth Street, NW
Washington, DC 20005
[phone]

Of Counsel:
Nick Catros*
SVP Business and Legal Affairs
Kobo Inc.
135 Liberty Street, Suite 101
Toronto, ON M6K 1A7
[phone] x3440
*Not admitted in New York

61415046_3.docx

Counsel for Proposed Amicus Curiae
Kobo Inc.

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