Polaris IP, LLC v. Google Inc. et al

Filing 124

***FILED IN ERROR; PLEASE IGNORE***Consent MOTION to Amend/Correct Unopposed Motion by Plaintiff for Leave to Amend Complaint by Polaris IP, LLC. (Attachments: # 1 Exhibit 1, # 2 Exhibit 1A)(Edmonds, John) Modified on 7/16/2008 (mpv, ).

Polaris IP, LLC v. Google Inc. et al

Doc. 124

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC v. GOOGLE, INC., et al. UNOPPOSED MOTION BY PLAINTIFF FOR LEAVE TO AMEND COMPLAINT Pursuant to Federal Rule of Civil Procedure 15(a), Plaintiff Bright Response, LLC (f/k/a Polaris IP, LLC) requests leave to file the amended complaint attached at Exhibit 1 hereto. Bright Response is mindful of the Defendants' pending Rule 12 motions challenging the sufficiency of Bright Response's Original Complaint. While Bright response submits that the Defendant's Rule 12 motions lack merit, the purpose of this amendment is to incorporate Bright Response's P.R. 3-1 infringement contentions in to the complaint, in order for the complaint to provide additional notice of Bright Response's infringement claims to the Defendants. The Defendants do not oppose this motion for leave, provided that their rights to challenge the adequacy of the Amended Complaint are preserved. Bright Response is agreeable to the foregoing. Wherefore, premises considered, Bright Response requests leave to file the Amended Complaint at Exhibit 1 hereto. July 16, 2008 Respectfully submitted, BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC By:_/s/ John J. Edmonds__________ Andrew W. Spangler ­ LEAD COUNSEL Texas Bar No. 24041960 1

2:07-CV-371-CE

Dockets.Justia.com

Spangler Law P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 Telephone: [phone] Facsimile: [phone] [e-mail] David M. Pridham R.I. State Bar No. 6625 Law Office of David Pridham 25 Linden Road Barrington, Rhode Island 02806 Telephone: [phone] Fax: [phone] [e-mail] Daniel F. Perez Texas State Bar No. 15776380 THE PEREZ LAW FIRM 6131 Park Lane Dallas, Texas 75225 Telephone: [phone] Facsimile: [phone] [e-mail] John J. Edmonds Texas Bar No. 00789758 THE EDMONDS LAW FIRM, PC 709 Sabine Street Houston, Texas 77007 Telephone: [phone] Facsimile: [phone] (Fax) [e-mail] COUNSEL FOR PLAINTIFF BRIGHT RESPONSE LLC, F/K/A POLARIS IP, LLC CERTIFICATE OF CONFERENCE Plaintiff has conferred by phone with Defendants and this Motion for Leave is unopposed. July 16, 2008 2

_/s/ John J. Edmonds__________ John J. Edmonds

CERTIFICATE OF SERVICE I hereby certify that the counsel of record who are deemed to have consented to electronic service are being served today with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. July 16, 2008 _/s/ John J. Edmonds__________ John J. Edmonds

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