API Technologies, LLC v. Facebook, Inc. et al

Filing 175

Joint MOTION for Extension of Time to File (proposed agreed Protective Order) by API Technologies, LLC. (Attachments: # 1 Text of Proposed Order)(Saxon, Adam)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION API TECHNOLOGIES, LLC Plaintiff, Civil Action No. 2:09-CV-00147 v. FACEBOOK, INC., ET AL, Defendants. JURY TRIAL DEMANDED

JOINT MOTION FOR EXTENSION OF TIME Plaintiff, API Technologies, LLC, and Defendants, Google Inc., Android, Inc., Yahoo! Inc., and Best Buy Co. Inc., request an extension of time up to and including May 11, 2010 to submit a proposed agreed Protective Order to the Court. The current deadline, established by the Court granting the parties' previous Joint Motion for Extension of Time, is May 4, 2010. The parties have been diligently negotiating an agreed form for the proposed protective order but have been unable to resolve all of the outstanding issues as of yet. The parties, however, believe that a 1-week extension will allow the parties to resolve the majority, if not all, of the outstanding issues. The requested extension will not affect any other deadlines.

DATED this 4th day of May, 2010. GOOGLE INC., ANDROID, INC., YAHOO! INC., BEST BUY CO. INC., THE DUN & BRADSTREET CORPORATION, AND HOOVER'S, INC. By: /s/ Ryan J. McBrayer (with permission) Ryan J. McBrayer Perkins Coie LLP - Seattle 1201 Third Avenue

Respectfully submitted, API TECHNOLOGIES, LLC By: /s/ Adam C. Saxon Andrew W. Spangler­ LEAD COUNSEL State Bar No. 24041960 SPANGLER LAW P.C. 208 N. Green Street, Suite 300 Longview, Texas 75601

40th Floor Seattle , WA 98101-3099 Telephone: [phone] Facsimile: 206-359-4073 [e-mail] ATTORNEY FOR DEFENDANT GOOGLE INC. AND ANDROID, INC. By: /s/ Jennifer A. Kash (with permission) Jennifer A. Kash Quinn Emanuel Urquhart Oliver & Hedges LLP - San Francisco 50 California Street 22nd Floor San Francisco , CA 94111 Telephone: [phone] Facsimile: 415-875-6700 [e-mail] ATTORNEY FOR DEFENDANT YAHOO! INC. By: /s/ Melissa M. Wendland (with permission) Melissa M. Wendland Robins Kaplan Miller & Ciresi L.L.P. 2800 LaSalle Plaza 800 LaSalle Avenue Minneapolis , MN 55402-2015 Telephone: [phone] Facsimile: 612-339-4181 [e-mail] ATTORNEY FOR DEFENDANT BEST BUY CO. INC.

Telephone: [phone] Facsimile: 903 553-0403 [e-mail] Marc A. Fenster CA Bar No. 181067 RUSS, AUGUST & KABAT 12424 Wilshire Boulevard, 12th Floor Los Angeles, CA 90025 Telephone: [phone] Facsimile: 310-826-6991 [e-mail] Adam C. Saxon Texas State Bar No. 24070558 Saxon Law Firm PLLC 3235 Cole Avenue, Ste. 40 Dallas, TX 75204 Telephone: [phone] [e-mail] ATTORNEYS FOR PLAINTIFF API TECHNOLOGIES, LLC

CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 4th day of May, 2010, 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: May 4, 2010 /s/ Adam C. Saxon Adam C. Saxon