Wireless Recognition Technologies LLC v. A9.com, Inc. et al

Filing 110

Unopposed MOTION for Extension of Time to File Response/Reply as to 109 Response in Opposition to Motion, 108 Reply to Response to Motion by A9.com, Inc., Amazon.com, Inc., Google, Inc.,, Nokia, Inc., Ricoh Innovations, Inc.. (Attachments: # 1 Text of Proposed Order)(Smith, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
vs.
A9.COM, INC., AMAZON.COM, INC.,
GOOGLE INC., NOKIA, INC., and
RICOH INNOVATIONS, INC.,
Defendants.

WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
vs.
NOKIA CORPORATION and RICOH
COMPANY, LTD.,
Defendants.

WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
vs.
A9.COM, INC., AMAZON.COM, INC.,
GOOGLE INC., NOKIA, INC., and
RICOH INNOVATIONS, INC.,
Defendants.

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Civil No. 2:10-CV-00364-DF

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Civil No. 2:10-CV-00365-DF

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Civil No. 2:10-CV-00577-DF

WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
vs.
NOKIA CORPORATION and RICOH
COMPANY, LTD.,
Defendants.

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Civil No. 2:10-CV-00578-DF

DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
COMES NOW, Defendants A9.com, Inc., Amazon.com, Inc., Google Inc., Nokia, Inc.,
Ricoh Innovations, Inc., Nokia Corporation, and Ricoh Company, Ltd. and file this Unopposed
Motion for Extension of Time to file their Sur-Reply to Plaintiff Wireless Recognition
Technologies LLC’s Motion to Consolidate Pursuant to Federal Rule of Civil Procedure 42(a)
and Local Rule CV-42(b), as well as their Reply in support of Defendants’ Cross-Motion to
Sever Pursuant to Rules 20 and 21 of the Federal Rules of Civil Procedure, and in support
thereof would state as follows:
Plaintiff filed its Reply to its Motion to Consolidate Pursuant to Federal Rule of Civil
Procedure 42(a) and Local Rule CV-42(b) on October 11, 2011. (Dkt. Nos. 108 (2:10-cv-364),
37 (2:10-cv-365), 52 (2:10-cv-577), and 39 (2:10-cv-578).) Defendants’ Sur-Reply is currently
due on Friday, October 21, 2011. Plaintiff filed its Opposition to Defendants’ Cross-Motion to
Sever Pursuant to Rules 20 and 21 of the Federal Rules of Civil Procedure on October 11, 2011.
(Dkt. Nos. 109 (2:10-cv-364), 38 (2:10-cv-365), 53 (2:10-cv-577), and 40 (2:10-cv-578).)
Defendants’ Reply is currently due on Friday, October 21, 2011. Defendants respectfully request

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an additional five (5) days to file their Sur-Reply to Plaintiff’s Motion to Consolidate and their
Reply to Defendants’ Cross-Motion to Sever up to and including October 26, 2011.
Counsel for Defendants have conferred with counsel for Plaintiff and Plaintiff does not
oppose the relief requested herein.

Dated: October 21, 2011

Respectfully submitted,

/s/ Michael C. Smith
Michael C. Smith
[e-mail]
Texas State Bar No. 18650410
SIEBMAN, BURG, PHILLIPS & SMITH, LLP
P.O. Box 1556
Marshall, TX 75671-1556
Telephone: [phone]
Facsimile: 972.767.4620
James F. Valentine (admitted pro hac vice)
[e-mail]
California State Bar No. 149269
Daniel T. Shvodian (admitted pro hac vice)
[e-mail]
California State Bar No. 184576
Perkins Coie LLP
3150 Porter Drive
Palo Alto, CA 94304-1212
Telephone: [phone]
Facsimile: 650.838.4350
Attorneys for Defendants and
Counterclaimants
A9.COM, INC., AMAZON.COM, INC., and
GOOGLE INC.

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/s/ Michael C. Smith
Michael C. Smith
[e-mail]
Texas State Bar No. 18650410
SIEBMAN, BURG, PHILLIPS & SMITH, LLP
P.O. Box 1556
Marshall, TX 75671-1556
Telephone: [phone]
Facsimile: 972.767.4620
Robert F. Perry (admitted pro hac vice)
Allison H. Altersohn (admitted pro hac vice)
KING & SPALDING LLP
1185 Avenue of the Americas
New York, NY 10036
Telephone: [phone]
Facsimile: 212.556.2222
E-mail: [e-mail]
E-mail: [e-mail]
Attorneys for Defendant
NOKIA INC. and NOKIA CORPORATION

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/s/ Michael E. Jones
Michael E. Jones
Texas State Bar No. 18650410
Allen Franklin Gardner
POTTER MINTON P.C.
110 N. College, Suite 500
P.O. Box 359
Tyler, TX 75710-0359
Telephone: [phone]
Facsimile: 903.593.0846
E-mail: [e-mail]
E-mail: [e-mail]
Mark D. Rowland (admitted pro hac vice)
ROPES & GRAY LLP
1900 University Avenue, 6th Floor
East Palo Alto, CA 94303-2284
Telephone: [phone]
Facsimile: 650.566.4144
Email: [e-mail]
Attorneys for Defendant and Counterclaimant
RICOH INNOVATIONS, INC. and RICOH
COMPANY, LTD.

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CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in
compliance with Local Rule CV-5(a). As such, this document was served on all counsel who are
deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R.
Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have
consented to electronic service were served with a true and correct copy of the foregoing by
email, on this 21st day of October, 2011.
/s/ Michael C. Smith
Michael C. Smith

09234-0001/LEGAL21983095.1