PA Advisors, LLC v. Google Inc. et al

Filing 14

MOTION for Extension of Time to File Answer re #1 Complaint, Unopposed Motion for Extension of Time for 24/7 Real Media, Inc. and WPP Group USA, Inc. to Answer or Otherwise Respond to Complaint by WWP Group USA, Inc., 24/7 Real Media, Inc.. (Attachments: #1 Text of Proposed Order)(Gillam, Harry)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

PA ADVISORS, LLC Plaintiff, vs. GOOGLE INC., et al. Defendants.

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CASE NO. 2:07CV480 Jury Trial Demanded

UNOPPOSED MOTION FOR EXTENSION OF TIME FOR 24/7 REAL MEDIA, INC. AND WPP GROUP USA, INC. TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT TO THE HONORABLE JUDGE OF SAID COURT: 1. Defendants 24/7 REAL MEDIA, INC. and WPP GROUP USA, INC.

hereby move the Court to extend the time within which Defendants are required to move, answer, or otherwise respond to Plaintiff PA ADVISORS, LLC's Complaint up to and including December 27, 2007. 2. Good cause exists for the granting of this motion and the motion is made

for the reason and on the grounds that the additional time is necessary in order to allow counsel to adequately confer with their clients and respond appropriately to Plaintiff's Complaint. WHEREFORE, Defendants 24/7 REAL MEDIA, INC. and WPP GROUP USA, INC. respectfully pray that the time to answer or otherwise move or respond to Plaintiff's Complaint be extended until December 27, 2007.

Dated: November 26, 2007

Respectfully submitted, GILLAM & SMITH, LLP

/s/ Harry L. Gillam, Jr. State Bar No. 07921800 Melissa R. Smith State Bar No. 24001351 GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, TX 75670 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR DEFENDANT 24/7 REAL MEDIA, INC. AND WPP GROUP USA, INC.

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Defendants and counsel for Plaintiff conferred on November 21, 2007 and Plaintiff does not oppose this motion.

/s/ Harry L. Gillam, Jr. CERTIFICATE OF SERVICE The undersigned hereby certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by certified mail, return receipt requested, on this 26th day of November, 2007.

/s/ Harry L. Gillam, Jr.