Software Rights Archive, LLC v. Google Inc. et al

Filing 207

Unopposed MOTION for Extension of Time to File Response/Reply as to 194 Unopposed SEALED MOTION to Compel by Google Inc.. (Attachments: # 1 Text of Proposed Order)(Walsh, Thomas)

Software Rights Archive, LLC v. Google Inc. et al

Doc. 207

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION SOFTWARE RIGHTS ARCHIVE, LLC v. GOOGLE INC., YAHOO! INC., IAC SEARCH & MEDIA, INC., AOL, LLC, AND LYCOS, INC. GOOGLE'S UNOPPOSED MOTION FOR FURTHER EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL (Dkt. No. 194) Defendant Google Inc. ("Google") respectfully moves this Honorable Court for a further extension of time to file a Response in Opposition to Plaintiff Software Rights Archive, LLC's Motion to Compel (Dkt. No. 194). In support of this request for an extension, Google states as follows: 1. Plaintiff Software Rights Archive, LLC's Motion to Compel (Dkt. No. 194) was Civil Case No. 2:07-cv-511 (CE)

filed on December 10, 2009. 2. 2010. 3. In order to have adequate time to fully respond to Dkt. No. 194, Google requests a Google's Response in Opposition to Dkt. No. 194 is currently due on January 8,

further one-week extension of time until and including January 15, 2010 to file its Response in Opposition to Dkt. No. 194. 4. 5. This request for extension is not opposed by Plaintiff. This motion is not for purposes of delay but rather so that justice may be done.

GOOGLE'S UNOPPOSED MOTION FOR FURTHER EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL (Dkt. No. 194) ­ Page 1

Dockets.Justia.com

WHEREFORE, Google respectfully requests a further extension of time until and including January 15, 2010 to file its Response in Opposition to Plaintiff Software Rights Archive, LLC' s Motion to Compel (Dkt. No. 194).

GOOGLE'S UNOPPOSED MOTION FOR FURTHER EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL (Dkt. No. 194) ­ Page 2

Dated: January 7, 2010

Respectfully submitted, FISH & RICHARDSON P.C. By: /s/ Thomas B. Walsh, IV Ruffin B. Cordell - Lead Attorney Texas Bar No. 04820550 FISH & RICHARDSON P.C. 1425 K Street, 11th Floor Washington, DC 20005 Telephone: [phone] Facsimile: [phone] Thomas B. Walsh, IV Texas Bar No. 00785173 E-mail: [e-mail] Fish & Richardson P.C. 1717 Main Street, Suite 5000 Dallas, TX 75201 Telephone: [phone] Facsimile: [phone] Ramon K. Tabtiang Massachusetts BBO 663,943 E-mail: [e-mail] Stephen A. Marshall Massachusetts BBO 666,200 E-mail: [e-mail] Fish & Richardson P.C. 225 Franklin Street Boston, MA 02110-2804 Telephone: [phone] Facsimile: [phone] Harry L. Gillam, Jr. Texas Bar No. 07921800 E-mail: [e-mail] Melissa R. Smith Texas Bar No. 24001351 E-mail: [e-mail] GILLAM & SMITH, L.L.P. 303 South Washington Avenue Marshall, TX 75670 Telephone: [phone] Facsimile: [phone] Counsel for Defendant and Counter-Claimant GOOGLE INC.

GOOGLE'S UNOPPOSED MOTION FOR FURTHER EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL (Dkt. No. 194) ­ Page 3

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that a conference was previously held with Lee Kaplan, counsel for Plaintiff, regarding the relief requested herein by Google ­ that Google be allowed until and including January 15, 2010 to file its Response in Opposition to Plaintiff Software Rights Archive, LLC' s Motion to Compel (Dkt. No. 194). Counsel for Plaintiff stated that SRA does not oppose this request. /s/ Thomas B. Walsh, IV Thomas B. Walsh, IV

CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served on January 7, 2010 to all counsel of record who are deemed to have consented to electronic service via the Court' s CM/ECF system per Local Rule CV-5(a)(3). /s/ Thomas B. Walsh, IV Thomas B. Walsh, IV

GOOGLE'S UNOPPOSED MOTION FOR FURTHER EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL (Dkt. No. 194) ­ Page 4