Sharing Sound, LLC v. Apple, Inc. et al

Filing 55

Unopposed MOTION for Extension of Time to File Answer by Rhapsody International Inc.. (Attachments: # 1 Text of Proposed Order)(Moran, Ryan)

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Sharing Sound, LLC v. Apple, Inc. et al Doc. 55 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION § SHARING SOUND, LLC, § § Plaintiff, § § v. § § APPLE, INC.; SONY ERICSSON MOBILE § CIVIL ACTION NO. 2:10-cv-00162-DF COMMUNICATIONS AB; SONY § ERICSSON MOBILE COMMUNICATIONS § JURY TRIAL DEMANDED INC.; SONY CORPORATION OF AMERICA; § SONY ELECTRONICS, INC.; SONY § COMPUTER ENTERTAINMENT INC.; § SONY COMPUTER ENTERTAINMENT § AMERICA, INC.; SONY CORPORATION; § RHAPSODY INTERNATIONAL, INC.; § NAPSTER, L.L.C.; BRILLIANT DIGITAL § ENTERTAINMENT, INC.; MICROSOFT § SHARING SOUND, LLC, § § Defendants. § § UNOPPOSED MOTION BY RHAPSODY INTERNATIONAL, INC. TO EXTEND TIME TO MOVE, ANSWER, OR OTHERWISE RESPOND TO PLAINTIFF'S ORIGINAL COMPLAINT Defendant Rhapsody International, Inc. ("Rhapsody"), without waiving any defenses or any matters that might be presented pursuant to Federal Rule of Civil Procedure 12(b), moves for an extension of time up to and including September 3, 2010, in which to move, answer, or otherwise respond to Plaintiff's Original Complaint. Plaintiff does not oppose ­ and has agreed to ­ the proposed extension. Defendant Rhapsody is filing with this motion a proposed Order. Dockets.Justia.com DATE: August 18, 2010 Respectfully submitted, By: HOWREY LLP /s/ Ryan Moran David Stewart (admitted pro hac vice) Washington State Bar No. 32150 California State Bar No. pending stewartd@howrey.com HOWREY LLP 525 Market Street, Suite 3600 San Francisco, CA 94105-2708 Tel: (415) 848-4900 Fax: (415) 848-4999 Ryan J. Moran California State Bar No. 244447 Admitted E.D. Tex. moranr@howrey.com HOWREY LLP 1950 University Ave., 4th Floor East Palo Alto, CA 94303 Phone: 650-798-3500 Fax: 650-798-3600 Attorneys for RHAPSODY INTERNATIONAL, INC. 2 CERTIFICATE OF CONFERENCE The Plaintiff is unopposed to the relief requested herein. CERTIFICATE OF SERVICE I here by 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 18th day of August 2010. Any other counsel of record will be served by first class U.S. mail on this same date. /s/ Ryan Moran Ryan Moran 3

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