PA Advisors, LLC v. Google Inc. et al

Filing 295

MOTION for Protective Order Modification by Yahoo! Inc.. (Attachments: #1 Pleading requesting leave (motion) #2 Affidavit, #3 Exhibit 1, #4 Exhibit 2, #5 Text of Proposed Order)(White, Jason) Modified on 11/4/2009 (sm, ). (Additional attachment(s) added on 11/4/2009: #6 Revised Order) (sm, ). Modified on 11/13/2009 (mrm, ). *Referred to Judge Everingham*

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, v. GOOGLE INC., et al. Defendants. ) ) ) ) ) ) ) ) )

Civil Action No. 2-07-CV-480-DF

MOTION FOR LEAVE TO FILE YAHOO! INC.'S MOTION TO MODIFY THE PROTECTIVE ORDER Defendant Yahoo! Inc. ("Yahoo") submits this motion for leave to file a motion to modify the protective order. This motion will explain the facts surrounding the necessity of modifying the protective order to protect Yahoo's confidential information in a way that will not burden plaintiff nXn, LLC f/k/a PA Advisors, LLC. For this reason, Yahoo respectfully requests leave to file a motion to modify the protective order.

Dated: November 3, 2009

Respectfully Submitted, /s/ Jason White Jason C. White HOWREY LLP 321 N. Clark, Suite 3400 Chicago, IL 60654 Tel: [phone] Fax: [phone] Email: [e-mail] Michael Jones Potter Minton 110 N. College St., Suite 500 P. O. Box 359 Tyler, Texas 75710 Tel: [phone]

Fax: [phone] Email: [e-mail] Attorneys for Defendant Yahoo! Inc.

CERTIFICATE OF SERVICE This is to certify that all known counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on November 3, 2009. /s/ Jason White Jason White

CERTIFICATE OF CONFERENCE Pursuant to Local Rule CV-7(h), Defendant Yahoo hereby certifies that its counsel has conferred, on numerous occasions, with opposing counsel in a good faith to attempt to resolve this matter without the Court's intervention. Plaintiff, Bright Response opposes this motion. /s/ Jason White Jason White