Mirror Worlds, LLC v. Apple, Inc.

Filing 77

Joint Motion for Entry of Agreed Protective Order (Attachments: #1 Exhibit Agreed Protective Order, #2 Text of Proposed Order)(Smith, Stefani)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 77

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 § § § JURY TRIAL DEMANDED § § § § §

JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER Pursuant to Federal Rule of Civil Procedure 26(c), Plaintiff Mirror Worlds, LLC ("Plaintiff") and Defendant Apple Inc. ("Defendant") jointly request that the Court enter the Protective Order attached as Exhibit A to this motion. All of the terms of the attached Protective Order are agreed to by the parties. As reflected in paragraph 6(b) of the attached Protective Order, the parties dispute one issue relating to the Protective Order. As stated in that paragraph, "The parties dispute whether counsel of record in the present action should be able to participate in reexamination proceedings relating to the Patents-in-Suit. The Court will address that issue in an addendum to this

Protective Order, following briefing and argument by the parties, which will specify language that will replace this sentence and the previous sentence." The parties will file briefing to present this issue to the Court shortly.

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Dated: May 21, 2009

Respectfully submitted,

/s/ Kenneth Stein 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] Attorneys for Plaintiff MIRROR WORLDS, LLC

/s/ Steven S. Cherensky 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] Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 [phone] (Telephone) [phone] (Facsimile) [e-mail] Attorneys for Defendant APPLE INC.

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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) on this 21st day of May, 2009. As of this date, all counsel of record that have consented to electronic service are being served with a copy of this document through the Court's CM/ECF system under Local Rule CV-5(a)(3)(A). /s/ Stefani C. Smith Stefani C. Smith

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