Performance Pricing, Inc. v. Google Inc. et al

Filing 219

Unopposed MOTION for Extension of Time to File Further Limited Claim Construction Briefing by Performance Pricing, Inc.. (Attachments: # 1 Text of Proposed Order)(Cho, Christin)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PERFORMANCE PRICING, INC., v. Plaintiff, Case No. 2:07-cv-432 (LED) JURY TRIAL DEMANDED GOOGLE INC., AOL LLC, MICROSOFT CORPORATION, YAHOO! INC., IAC SEARCH & MEDIA, INC., and A9.COM, INC., Defendants. UNOPPOSED MOTION FOR EXTENSION OF TIME TO SUBMIT FURTHER LIMITED CLAIM CONSTRUCTION BRIEFING Plaintiff Performance Pricing, Inc. respectfully files this Unopposed Motion seeking the Court's permission for a two-day extension of the deadline for Plaintiff to submit further claim construction briefing limited to the disputes identified in section 4 (pp. 4-5) of the Court's Order issued on July 15, 2009 (Docket No. 218) ("Order"), and in support of the same would show the Court as follows: The deadline for Plaintiff to submit the further limited claim construction briefing under section 4 of the Order is Monday, July 20, 2009, and the deadline for Defendants to submit its response is Friday, July 24, 2009. Plaintiff requests an extension of its deadline because Plaintiff's lead counsel, Greg Dovel, will be out of town from Friday, July 17, until Monday, July 20, 2009. Plaintiff believes that an extension of the deadline is necessary to complete the briefing. The motion is unopposed by Defendants. WHEREFORE, Plaintiff respectfully requests that this Court adjust the briefing schedule 01002.51305/3012438.1 1 as follows: Deadline for Plaintiff to submit further claim construction briefing to Wednesday, July 22, 2009; Deadline for Defendants to submit further claim constructing briefing to Tuesday, July 28, 2009. Dated: July 16, 2009 Respectfully submitted, By: /s/ Christin Cho Christin Cho CA State Bar No. 238173 Email: christin@dovellaw.com Gregory S. Dovel CA State Bar No. 135387 Email: greg@dovellaw.com Sean Luner CA State Bar No. 165443 Email: sean@dovellaw.com Dovel & Luner, LLP 201 Santa Monica Blvd., Suite 600 Santa Monica, CA 90401 Telephone: 310-656-7066 Facsimile: 310-657-7069 S. Calvin Capshaw State Bar No. 03783900 Elizabeth L. DeRieux State Bar No. 05770585 Capshaw DeRieux, L.L.P. Energy Centre 1127 Judson Road, Ste 220 P. O. Box 3999 (75606-3999) Longview, Texas 75601-5157 Telephone: (903) 236-9800 Facsimile: (903) 236-8787 Email: capshaw@capshawlaw.com Email: ederieux@capshawlaw.com Robert M. Parker 01002.51305/3012438.1 2 State Bar No. 15498000 Email: rmparker@cox-internet.com Robert Christopher Bunt State Bar No. 00787165 Email: cbunt@cox-internet.com Parker & Bunt, P.C. 100 East Ferguson, Ste. 1114 Tyler, TX 75702 Telephone: 903/531-3535 Facsimile: 903/533-9687 ATTORNEYS FOR PLAINTIFF PERFORMANCE PRICING, INC. 01002.51305/3012438.1 3 CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 16th day of July, 2009, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Christin K. Cho Christin K. Cho 01002.51305/3012438.1 4

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