PA Advisors, LLC v. Google Inc. et al

Filing 225

RESPONSE in Opposition re #222 MOTION to Intervene DEFENDANTS' AND PLAINTIFF'S JOINT OPPOSITION TO THIRD PARTY MOTIONS filed by Google Inc.. (Attachments: #1 Text of Proposed Order)(Cannon, Brian)

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PA Advisors, LLC v. Google Inc. et al Doc. 22 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC Plaintiff, v. GOOGLE INC., et al, Defendants ' ' ' ' ' ' ' ' ' ' CIVIL ACTION NO. 2:07-CV-480 (DF) DEFENDANTS' AND PLAINTIFF'S JOINT OPPOSITION TO THIRD PARTY MOTIONS DEFENDANTS' AND PLAINTIFF'S JOINT OPPOSITION TO THIRD PARTY MOTIONS On December 5, 2008, a third party filed handwritten papers titled, "Motion for Reconsideration & Clarification, Motion to Intervene as Plaintiffs under Fed. R. Civ. P. Rule 24(A)2, (B), Motion for Brief of Amicus Curiae, Friend of the Court." See Dkt. No. 222. The papers appear to be prepared by a federal prisoner and were mailed from Federal Correctional Institute Williamsburg, in Salters, South Carolina. Dkt. No. 222 at page 3. The filer of the papers purports to be "Jonathan Lee Riches," and the papers purport to be on behalf of several entities and individuals. The third party did not consult with any of the parties to this action before filing the papers. Defendant Google Inc. ("Google") has consulted with the other parties to this action, including Plaintiff, and all parties oppose any relief or intervention to the third party filer. The filings appear to be simultaneously filed in other pending actions. The third party who filed the papers has no known connection to any of the issues in this action, which involves a claim for patent infringement. The third party has not demonstrated that 51319/2739005.1 1 it has any claim or defense that shares with the main action a common question of law or fact as it must to intervene under Rule 24. See Rule 24, Fed. R. Civ. Proc. Accordingly, the parties respectfully request that this Court deny any relief requested in the papers filed December 5, 2008. Dated: December 23, 2008 Respect fully submitted, By: /s/ Brian C. Cannon Brian C. Cannon, pro hac vice m Quinn Emanuel Urquhart Oliver & Hedges, LLP 555 Twin Dolphin Dr Suite 560 Redwood Shores, CA 94065 Tel. (650) 801-5000 Fax: (650) 801-5100 Email: Charles K. Verhoeven, pro hac vice m David A. Perlson, pro hac vice m Quinn Emanuel Urquhart Oliver & Hedges, LLP 50 California Street, 22nd Floor San Francisco, CA 94111 Tel.: (415) 875-6600 Fax: (415) 875-6700 David J Beck Texas Bar No. 00000070 Beck Redden & Secrest 1221 McKinney St, Suite 4500 One Houston Center Houston, TX 77010-2020 51319/2739005.1 2 Tel: (713) 951-3700 Fax: (713) 951-3720 Email: Michael Ernest Richardson Texas Bar No. 240002838 Beck Redden & Secrest - Houston 1221 McKinney Suite 4500 Houston, TX 77010-2010 Tel: (713) 951-6284 Fax: (713) 951-3720 Email: ATTORNEYS FOR DEFENDANT GOOGLE INC. 51319/2739005.1 3 CERTIFICATE OF SERVICE I hereby certify that on the 23d day of December, 2008, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Eastern District of Texas, Marshall Division, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means. By: /s/ Brian C. Cannon 51319/2739005.1 4

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