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

Filing 30

MOTION for Extension of Time to File Answer by Digg, Inc.. (Attachments: # 1 Text of Proposed Order)(Bartow, D.)

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Beneficial Innovations, Inc. v. Blockdot, Inc. et al Doc. 30 Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, v. BLOCKDOT, INC., a Texas Corporation; CAREERBUILDER, LLC., a Delaware corporation; CNET NETWORK, INC., a Delaware corporation; DIGG, INC., a Delaware corporation; EBAUM'S WORLD, INC., a New York corporation; JABEZ NETWORKS, INC., a Tennessee corporation; THE NEW YORK TIMES COMPANY, a New York corporation; THE WASHINGTON POST COMPANY; a Delaware Corporation; THE WEATHER CHANNEL INTERACTIVE, INC., a Georgia corporation, Defendants. DIGG INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO ANSWER, MOVE OR OTHERWISE RESPOND TO BENEFICIAL INNOVATION, INC.'S FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT Civil Action No. 2:07-cv-263 (TJW/CE) JURY TRIAL DEMANDED LIBA/1818072.1 Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 2 of 3 Defendant DIGG, INC., 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 Beneficial Innovation, Inc.'s First Amended Complaint for Patent Infringement and would respectfully show the Court as follows: DIGG, INC. has requested and Plaintiff has agreed to an extension of DIGG'S INC.'s time to respond in any manner whatsoever including answer, motion or other pleading of any type to Plaintiff's Amended Complaint. Specifically, DIGG, INC. requests, and BENEFICIAL INNOVATIONS, INC. does not oppose, an additional extension of time up to and including August 31, 2007. A proposed Order granting this unopposed motion is attached for the Court's convenience. Respectfully submitted, /s/ D. Stuart Bartow Byron W. Cooper CA State Bar No. 166578 D. Stuart Bartow CA State Bar No. 233107 GOODWIN PROCTER LLP 530 Lytton Avenue Palo Alto, California 94301 Tel.: 650.617.3300 Fax: 650.617.3281 Attorneys for Defendant DIGG, INC., a Delaware corporation Dated: July 31, 2007 1 LIBA/1818072.1 Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 3 of 3 CERTIFICATE OF SERVICE This is to certify that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this 31st day of July, 2007. Any other counsel of record will be served by first class mail. /s/ D. Stuart Bartow D. Stuart Bartow 2 LIBA/1818072.1

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