PA Advisors, LLC v. Google Inc. et al

Filing 99

RESPONSE to Motion re #95 MOTION to Dismiss Plaintiff's First Amended Complaint, or in the Alternative, for a More Definate Statement by Yahoo! Inc. filed by PA Advisors, LLC. (Attachments: #1 Text of Proposed Order)(LaValle, Amy)

PA Advisors, LLC v. Google Inc. et al

Doc. 99

Case 2:07-cv-00480-TJW

Document 99

Filed 02/01/2008

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 DEFENDANT YAHOO! INC.'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT, OR IN THE ALTERNATIVE, FOR MORE DEFINITE STATEMENT In response to Defendant Yahoo! Inc.'s Motion to Dismiss Plaintiff's First Amended Complaint, or in the Alternative, for a More Definite Statement, PA Advisors hereby incorporates by reference its Response and Sur-Reply to Yahoo's opening Motion to Dismiss, or in the Alternative, for More Definite Statement. See Dkt. Nos. 59 and 97. PA Advisors, therefore, asks the Court to deny Defendant Yahoo! Inc.'s Motion to Dismiss Plaintiff's First Amended Complaint, or in the Alternative, for a More Definite Statement and to order Yahoo to file an answer to PA Advisors' First Amended Complaint. In the alternative, if the Court deems PA Advisors' current First Amended Complaint to be deficient in any way, then PA Advisors requests leave to amend the First Amended Complaint to address any such issues.

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Case 2:07-cv-00480-TJW

Document 99

Filed 02/01/2008

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Dated: February 1, 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 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 99

Filed 02/01/2008

Page 3 of 3

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: February 1, 2008

/s/ Amy E. LaValle

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