Mirror Worlds, LLC v. Apple, Inc.

Filing 248

Unopposed MOTION for Extension of Time to File Response/Reply as to #220 SEALED MOTION UNDER DAUBERT AND RULE 26 TO LIMIT THE TESTIMONY AND EXPERT REPORTS OF JOHN LEVY, #226 SEALED MOTION FOR PARTIAL SUMMARY JUDGMENT DISMISSING MIRROR WORLDS' ALLEGATIONS OF WILLFUL INFRINGEMENT, #224 SEALED MOTION FOR PARTIAL SUMMARY JUDGMENT TO ESTABLISH NON-INFRINGEMENT OF APPLE'S FOREIGN PRODUCTS AND EXCLUDE FOREIGN SALES FROM ANY POTENTIAL DAMAGES AWARD, #225 SEALED MOTION FOR SUMMARY JUDGMENT OF NONINFRINGEMENT OF U.S. PATENT NOS. 6,006,227; 6,638,313; 6,725,427; AND 6,768,999, #227 SEALED MOTION UNDER DAUBERT TO STRIKE PORTIONS OF THE REBUTTAL EXPERT REPORT OF KEITH R. UGONE, PH.D. AND TO EXCLUDE UGONES TESTIMONY REGARDING APPLES SURVEY INSTRUMENTS AND MARKETING RESEARCH, #229 MOTION for Summary Judgment OF INVALIDITY OF US PATENT NO. 6,613,101, #221 MOTION for Summary Judgment THAT THE ASSERTED CLAIMS OF U.S. PATENT NOS. 6,006,227, 6,638,313, 6,725,427 AND 6,768,999 ARE INVALID AS ANTICIPATED AND OBVIOUS, #228 SEALED MOTION Mirror Worlds, LLC's Motion for Summary Judgment of No Inequitable Conduct, #223 SEALED MOTION FOR PARTIAL SUMMARY JUDGMENT OF INEQUITABLE CONDUCT REGARDING INVENTORSHIP OF THE '227 PATENT by Mirror Worlds Technologies, Inc., Mirror Worlds, LLC. (Attachments: #1 Text of Proposed Order)(Solo, Alexander)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 248

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, JURY TRIAL DEMANDED v. APPLE, INC. Defendant. APPLE, INC. Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS, TECHNOLOGIES, INC. Counterclaim Defendants. MIRROR WORLDS UNOPPOSED MOTION FOR ADDITIONAL TIME TO RESPOND TO DOCKET NOS. 220, 221, 223, 224, 225, AND 226 AND CORRESPONDING EXTENSION FOR APPLE INC TO RESPOND TO DOCKET NOS. 227, 228, AND 229 Mirror Worlds, LLC ("Mirror Worlds") and Mirror Worlds Technologies, Inc. ("MWT) respectfully submit this Unopposed Motion for Additional Time (one day) to respond to the following: 1) Sealed Motion Under Daubert And Rule 26 To Limit The Testimony And Expert Reports Of John Levy. (D.I. 220) 2) Motion For Summary Judgment That The Asserted Claims Of U.S. Patent Nos. 6,006,227, 6,638,313, 6,725,427 And 6,768,999 Are Invalid As Anticipated And Obvious. (D.I. Civil Action No. 6:08-CV-88 LED

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221). 3) Sealed Motion For Partial Summary Judgment Of Inequitable Conduct Regarding Inventorship Of The '227 Patent. (D.I. 223). 4) Sealed Motion For Partial Summary Judgment To Establish Non-Infringement Of Apple's Foreign Products And Exclude Foreign Sales From Any Potential Damages Award. (D.I. 224). 5) Sealed Motion For Summary Judgment Of Noninfringement Of U.S. Patent Nos. 6,006,227; 6,638,313; 6,725,427; And 6,768,999. (D.I. 225). 6) Sealed Motion For Partial Summary Judgment Dismissing Mirror Worlds' Allegations Of Willful Infringement. (D.I. 226) Mirror Worlds respectfully requests that the Court grant a similar extension to Apple Inc. to respond to the following: 7) Sealed Motion Under Daubert To Strike Portions Of The Rebuttal Expert Report Of Keith R. Ugone, Ph.D. And To Exclude Ugone's Testimony (D.I. 227). 8) Sealed Motion Mirror Worlds, LLC's Motion For Summary Judgment Of No

Inequitable Conduct By Mirror Worlds, LLC. (D.I. 228). 9) Motion For Summary Judgment Of Invalidity Of US Patent No. 6,613,101. (D.I. 229). This Motion for Additional Time is unopposed. On July 21, 2010, Alexander Solo, counsel for Mirror Worlds and MWT, contacted counsel for Apple and proposed the requested

one day extension for the above responses. On July 21, 2010, counsel for Apple Inc., Mirror Worlds, and MWT met and conferred telephonically and agreed to the extension. This extension is sought due to unforeseen circumstances and not for purposes of delay. Dated: July 21, 2010 Respectfully submitted, By: /s/ Alexander Solo Otis Carroll, Lead Counsel (Texas States Bar No. 03895700) Deborah Race (Texas State Bar No. 16448700) IRELAND CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: [phone] Fax: [phone] Email: [e-mail] Joseph Diamante (Pro Hac Vice) Kenneth L. Stein (Pro Hac Vice) Ian G. DiBernardo (Pro Hac Vice) Alexander Solo (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, N.Y. 10038 Tel: [phone] Fax: [phone] Email: [e-mail] ATTORNEYS FOR MIRROR WORLDS, LLC AND MIRROR WORLDS TECHNOLOGIES, INC.

CERTIFICATE OF CONFERENCE I hereby certify that counsel for Mirror Worlds and MWT has satisfied the "meet and confer" requirements of Local Rule CV-7(h), and that counsel of record in this matter are not opposed to the relief sought in this Motion. /s/ Alexander Solo Alexander Solo CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document this 21st day of July, 2010, via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Alexander Solo