Polaris IP, LLC v. Google Inc. et al

Filing 125

Consent MOTION to Amend/Correct Unopposed Motion by Plaintiff for Leave to Amend Complaint by Polaris IP, LLC. (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Edmonds, John)

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Polaris IP, LLC v. Google Inc. et al Doc. 125 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC NO. 2:07-CV-371-CE v. JURY 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. 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 18, 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 Dockets.Justia.com Spangler Law P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 Telephone: (903) 753-9300 Facsimile: (903) 553-0403 spangler@spanglerlawpc.com David M. Pridham R.I. State Bar No. 6625 Law Office of David Pridham 25 Linden Road Barrington, Rhode Island 02806 Telephone: (401) 633-7247 Fax: (401) 633-7247 david@pridhamiplaw.com Daniel F. Perez Texas State Bar No. 15776380 THE PEREZ LAW FIRM 6131 Park Lane Dallas, Texas 75225 Telephone: (214) 289-6659 Facsimile: (214) 521-1128 dan@pereziplaw.com John J. Edmonds Texas Bar No. 00789758 THE EDMONDS LAW FIRM, PC 709 Sabine Street Houston, Texas 77007 Telephone: (713) 858-3320 Facsimile: (832) 415-2535 (Fax) johnedmonds@edmondslegal.com COUNSEL FOR PLAINTIFF BRIGHT RESPONSE LLC, F/K/A POLARIS IP, LLC 2 CERTIFICATE OF CONFERENCE Plaintiff has conferred by email with Defendants and this Motion for Leave is unopposed. July 18, 2008 /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 18, 2008 /s/ John J. Edmonds John J. Edmonds 3

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