PA Advisors, LLC v. Google Inc. et al

Filing 394

Unopposed MOTION for Extension of Time to File Response/Reply to Motion for Summary Judgment of Non-Infringement by PA Advisors, LLC. (Attachments: #1 Text of Proposed Order Proposed Order)(Hoffman, Adam)

PA Advisors, LLC v. Google Inc. et al

Doc. 394

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-RRR JURY TRIAL DEMANDED

UNOPPOSED MOTION TO EXTEND DEADLINES FOR OPPOSITIONS TO AND REPLIES IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT Plaintiff nXn Tech, LLC (f/k/a PA Advisors, LLC) ("nXn") moves the Court to extend by one day the deadlines for nXn's oppositions to Defendants Google, Inc. ("Google") and Yahoo! Inc. ("Yahoo")'s pending Motions for Summary Judgment of Non-Infringement, and Yahoo and Google's replies in support of these motions. Google and Yahoo have agreed to this extension and do not oppose this Motion. The current deadlines are February 9, 2010 for nXn's oppositions, and February 15, 2010 for Google's and Yahoo's replies. The new deadlines would be February 10, 2010 for nXn's oppositions, and February 16, 2010 Google's and Yahoo's replies. Good cause exists for granting these extensions. Yahoo's expert witness Dr. Peters is available for deposition this week only on February 9, 2010. However, this date conflicts with counsel for nXn's requirement to prepare and file nXn's opposition briefs on this same date. The parties have therefore agreed to extend the deadlines for opposition and reply briefs on the motions for summary judgment by one day. WHEREFORE, nXn respectfully requests that the Court grant the relief requested in this unopposed motion. A proposed order is attached.

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Dated: February 8, 2010 Andrew W. Spangler LEAD COUNSEL SPANGLER LAW P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601 [phone] [phone] (fax) [e-mail] David M. Pridham LAW OFFICE OF DAVID PRIDHAM 25 Linden Road Barrington, Rhode Island 02806 [phone] [phone] (fax) [e-mail] John M. Bustamante Texas Bar No. 24040618 BUSTAMANTE, P.C. 54 Rainey Street, No. 721 Austin, Texas 78701 Tel. [phone] Fax. [phone] Email:[e-mail] Kip Glasscock Texas State Bar No. 08011000 KIP GLASSCOCK P.C. 550 Fannin, Suite 1350 Beaumont, TX 77701 Tel: [phone] Fax: [phone] Email: [e-mail]

Respectfully submitted, By: /s/ Adam Hoffman Marc A. Fenster, CA Bar No. 181067 CA Bar No. 181067 [e-mail] Andrew Weiss CA Bar No. 232974 [e-mail] Adam Hoffman CA Bar No. 218740 [e-mail] RUSS, AUGUST & KABAT 12424 Wilshire Blvd., 12th Floor Los Angeles, CA 90025 [phone] [phone] (fax) Patrick R. Anderson PATRICK R. ANDERSON PLLC 4225 Miller Rd, Bldg. B-9, Suite 358 Flint, MI 48507 [phone] [phone] (fax) [e-mail] Debera W. Hepburn, Texas Bar No. 24049568 HEPBURN LAW FIRM PLLC P.O. Box 118218 Carrollton, TX 75011 Telephone: [phone] Facsimile: 888/205-8791 Email: [e-mail] Elizabeth A. Wiley Texas State Bar No. 00788666 THE WILEY FIRM PC P.O. Box. 303280 Austin, Texas 78703-3280 Telephone: [phone] Facsimile: [phone] Email: [e-mail]

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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. \s\ Adam Hoffman Adam Hoffman

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