Beneficial Innovations, Inc. v. Blockdot, Inc. et al

Filing 22

MOTION for Extension of Time to File Answer by Jabez Networks, Inc.. (Attachments: # 1 Text of Proposed Order)(Geiszler, Steven)

Beneficial Innovations, Inc. v. Blockdot, Inc. et al

Doc. 22

Case 2:07-cv-00263-TJW-CE

Document 22

Filed 07/20/2007

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IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, v. BLOCKDOT, INC., CAREERBUILDER, LLC., CNET NETWORKS, INC., DIGG, INC., EBAUM'S WORLD, INC., JABEZ NETWORKS, INC., THE NEW YORK TIMES CO., THE WASHINGTON POST CO., THE WEATHER CHANNEL INTERACTIVE, INC., Defendant. JABEZ NETWORKS, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF'S AMENDED COMPLAINT Defendant Jabez Networks, Inc. ("Jabez"), without waiving any defenses or any matters that might be presented pursuant to Federal Rule of Civil Procedure 12(b) or any other rule or law, files this unopposed motion for extension of time in which to answer, move, or otherwise respond to Plaintiff Beneficial Innovations, Inc.'s ("Beneficial") Amended Complaint and would respectfully show the Court as follows: Jabez has requested and Beneficial has agreed to an extension of Jabez's time to respond in any manner whatsoever including answer, motion or other pleading of any type to Beneficial's Amended Complaint. Specifically, Jabez requests, and Beneficial does not oppose, an extension of time up to and including September 4, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. CIVIL ACTION NO. 2:07-CV-263 (TJW/CE) Jury Trial Demand

100266585_1.DOC

Dockets.Justia.com

Case 2:07-cv-00263-TJW-CE

Document 22

Filed 07/20/2007

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DATE: July 20, 2007

Respectfully submitted, GIBSON, DUNN & CRUTCHER LLP

By: /s/ Mark N. Reiter MARK N. REITER Texas Bar No. 16759900 [e-mail] STEVEN M. GEISZLER Texas Bar No. 24032227 [e-mail] 2100 McKinney Avenue, Suite 1100 Dallas, Texas 75201 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR DEFENDANT JABEZ NETWORKS, INC.

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Case 2:07-cv-00263-TJW-CE

Document 22

Filed 07/20/2007

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CERTIFICATE OF CONFERENCE I certify that counsel for Jabez Networks, Inc. conferred with counsel for Beneficial Innovations, Inc. on July 19, 2007 regarding the subject matter of the foregoing motion. The motion is unopposed.

/s/ Steven M. Geiszler _______________________ Steven M. Geiszler

CERTIFICATE OF SERVICE I certify that the foregoing document was filed electronically on July 20, 2007 pursuant to Local Rule CV-5(a) and has been served on all counsel who have consented to electronic service. Any other counsel of record will be served by first class U.S. mail on this same date.

/s/ Steven M. Geiszler _______________________ Steven M. Geiszler

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