Mirror Worlds, LLC v. Apple, Inc.

Filing 116

Joint MOTION for Extension of Time to File Response/Reply as to #105 SEALED MOTION to Dismiss Apple, Inc.'s Infringement Counterclaim by Apple, Inc.. (Attachments: #1 Text of Proposed Order)(Smith, Stefani)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 116

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED

APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants.

JOINT MOTION FOR AN EXTENSION OF TIME FOR APPLE TO OPPOSE MIRROR WORLDS' MOTION TO DISMISS Defendant and Counterclaim Plaintiff Apple Inc. ("Apple") and Plaintiff and Counterclaim Defendant Mirror Worlds, LLC ("Mirror Worlds") hereby move to extend Apple's deadline to oppose Mirror Worlds' Motion to Dismiss until Thursday, September 10, 2009. Good cause exists for the requested relief. Mirror Worlds filed its Motion to Dismiss on August 10, 2009. Apple's opposition to that motion is presently due Thursday, September 3, 2009. The parties are engaged in

discussions in an effort to resolve the motion by stipulation. Accordingly, Apple and Mirror

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Worlds respectfully request the Court to extend the time for Apple to oppose Mirror Worlds' motion to Thursday, September 10, 2009. This extension is not sought for the purpose of delay, but instead so that justice may be served. WHEREFORE, PREMISES CONSIDERED, the parties respectfully request the Court to grant their motion to permit Apple to file its opposition as set forth herein above.

Dated: September 3, 2009

Respectfully submitted,

/s/ Richard An Otis Carroll Texas Bar No. 03895700 Lead Attorney Deborah Race Texas Bar No. 16448700 IRELAND, CARROLL & KELLY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 903-561-1600 (Telephone) 903-581-1071 (Facsimile) [e-mail] Of counsel: Joseph Diamante (Pro Hac Vice) Kenneth Stein (Pro Hac Vice) Richard An (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, NY 10038 212-806-5400 (Telephone) 212-806-6006 (Facsimile) [e-mail] [e-mail] [e-mail]

/s/ Stefani C. Smith Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 [phone] (Telephone) [phone] (Facsimile) [e-mail] Matthew Powers Lead Attorney Steven S. Cherensky Sonal N. Mehta (Pro Hac Vice) Stefani C. Smith (Pro Hac Vice) WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (Telephone) 650-802-3100 (Facsimile) [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Defendant APPLE INC.

Attorneys for Plaintiff MIRROR WORLDS, LLC

CERTIFICATE OF SERVICE This is to certify that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on this the 3rd day of September, 2009.

/s/ Stefani C. Smith Stefani C. smith