PA Advisors, LLC v. Google Inc. et al

Filing 65

RESPONSE to Motion re #54 MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6) or, in the Alternative, for a More Definite Statement MOTION to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6) or, in the Alternative, for a More Definite Statement by WPP Group USA, Inc. filed by PA Advisors, LLC. (Attachments: #1 Text of Proposed Order)(LaValle, Amy)

PA Advisors, LLC v. Google Inc. et al

Doc. 65

Case 2:07-cv-00480-TJW

Document 65

Filed 01/11/2008

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC Plaintiff, No. 2:07-cv-480-TJW v. JURY TRIAL DEMANDED GOOGLE INC., ET AL. Defendants. PLAINTIFF'S RESPONSE TO WPP GROUP USA, INC.'S MOTION TO DISMISS PURSUANT TO FEDERAL RULES OF CIVIL PROCEDURE 12(B)(2) AND 12(B)(6) OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT Plaintiff PA Advisors, LLC ("PA Advisors") files this Response to WPP Group USA, Inc.'s Motion to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6) or, in the Alternative, for a More Definite Statement ("WPP Group USA's Motion to Dismiss") (Dkt. No. 54). PA Advisors hereby notifies the Court that WPP Group USA's Motion to Dismiss is now moot in light of Plaintiff's Notice of Voluntary Dismissal of WPP Group USA, Inc. (Dkt. No. 64) filed earlier today. PA Advisors filed the notice of dismissal, without prejudice, based on the representations made by WPP Group USA in its Motion to Dismiss and the supporting Declaration of Firouzeh Bahrampour filed therewith. As such, PA Advisors asks the Court to deny as moot WPP Group USA, Inc.'s Motion to Dismiss Pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6) or, in the Alternative, for a More Definite Statement.

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Case 2:07-cv-00480-TJW

Document 65

Filed 01/11/2008

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Dated: January 11, 2008

Respectfully submitted, PA ADVISORS, LLC By: /s/ Amy E. LaValle Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2659 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] David M. Pridham R.I. State Bar No. 6625 INTELLECTUAL PROPERTY NAVIGATION GROUP, LLC 207 C North Washington Avenue Marshall, Texas 75670 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Amy E. LaValle Texas State Bar No. 24040529 THE LAVALLE LAW FIRM 3811 Turtle Creek Boulevard Suite 1620 Dallas, Texas 75219 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Of Counsel: Joseph Diamante JENNER & BLOCK LLP 919 Third Avenue, 37th Floor New York, New York 10022-3908 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEYS FOR PLAINTIFF PA ADVISORS, LLC

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Case 2:07-cv-00480-TJW

Document 65

Filed 01/11/2008

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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.

Dated: January 11, 2008

/s/ Amy E. LaValle

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