Beneficial Innovations, Inc. v. Careerbuilder, LLC et al

Filing 64

Unopposed MOTION for Extension of Time to File Answer re 13 Amended Complaint, by IAC Search & Media, Inc.. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

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Beneficial Innovations, Inc. v. Careerbuilder, LLC et al Doc. 64 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC., Plaintiff, v. COMCAST CORPORATION, THE DALLAS MORNING NEWS, INC., DIGG, INC., DISNEY ONLINE, THE WALT DISNEY COMPANY, EBAUM'S WORLD, INC., FACEBOOK, INC., GOOGLE INC., IAC SEARCH & MEDIA, INC., MORRIS COMMUNICATIONS COMPANY, LLC, NBC UNIVERSAL, INC., THE NEW YORK TIMES COMPANY, YOUTUBE, LLC, Defendants. 2:09-cv-00175-TJW JURY DEMANDED DEFENDANT IAC SEARCH & MEDIA, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME FOR IAC SEARCH & MEDIA, INC. TO ANSWER, MOVE, OR OTHERWISE RESPOND TO AMENDED COMPLAINT Defendant IAC Search & Media, Inc. ("IACSAM") moves the Court to extend the time for IACSAM to answer, move, or otherwise respond to Beneficial Innovations Inc. ("Beneficial Innovations")'s Amended Complaint for Patent Infringement. This suit was filed on June 1, 2009. The Amended Complaint adding IACSAM was filed on September 4, 2009. On October 13, 2009, the Court granted an Application for Extension of Time to Answer Complaint that extended the answering deadline to November 12, 2009. Counsel for IACSAM requested another extension of time to respond to the Amended Complaint until December 4, 2009, without waiving the IACSAM's defenses or any matters that might be presented pursuant to Rule 12(b) of the Federal Rules of Civil Procedure or any other rule or law. Plaintiff, Beneficial Innovations, agreed to IACSAM's request. 99999.77223/3197034.1 Dockets.Justia.com Accordingly, IACSAM requests that the Court extend the time for the IACSAM to respond to the First Amended Complaint to December 4, 2009, without waiving the IACSAM's defenses or any matters that might be presented pursuant to Rule 12(b) of the Federal Rules of Civil Procedure or any other rule or law. A proposed order granting the requested extension is attached for the Court's convenience. Dated: November 11, 2009 Respectfully submitted, /s/ Michael E. Jones Michael E. Jones State Bar No. 10929400 Potter Minton, PC 110 North College Suite 500 Tyler, TX 75702 Telephone: 903-597-8311 Fax: 903-593-0846 Email: mikejones@potterminton.com ATTORNEYS FOR DEFENDANT IAC SEARCH & MEDIA, INC. CERTIFICATE OF SERVICE I hereby certify that all counsel of record who have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV5(a)(3) on this the 11th day of November, 2009. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Michael E. Jones Michael E. Jones 99999.77223/3197034.1

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