Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 868

Joint MOTION for Extension of Time to File Response/Reply as to #845 MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) MOTION for Judgment as a Matter of Law Regarding Invalidity (Renewed) (Joint Motion for Extension of Time to File A Reply and Surreply to Yahoo!'s Renewed Motion for Judgment as a Matter of Law Regarding Invalidity) by Bedrock Computer Technologies, LLC, Yahoo! Inc.. (Attachments: #1 Text of Proposed Order)(Doan, Jennifer)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION
BEDROCK COMPUTER TECHNOLOGIES
LLC,
PLAINTIFF
VS.
YAHOO!, INC.,
DEFENDANT

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§ CIVIL ACTION NO. 6:09-cv-269-LED-JDL
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§ JURY TRIAL DEMANDED
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JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY
AND SURREPLY TO YAHOO!’S RENEWED MOTION FOR
JUDGMENT AS A MATTER OF LAW REGARDING INVALIDITY
Plaintiff Bedrock Computer Technologies, LLC (“Bedrock”) and Defendant Yahoo! Inc.
(“Yahoo!”) file this motion to extend the time to file a reply and surreply to Yahoo!’s Renewed
Motion for Judgment as a Matter of Law Regarding Invalidity and would respectfully show the
Court the following:
Yahoo!’s current deadline to file a reply in support of its Renewed Motion for Judgment
as a Matter of Law Regarding Invalidity [Dkt. No. 845] is July 11, 2011. Yahoo! requested a
short extension, through and including July 15, 2011, to file a reply [Dkt. No. 848]. The Court
denied Yahoo!’s motion without prejudice to refilling if the parties agreed on a schedule where
all replies and surreplies were filed no later than July 18, 2011 [Dkt. No. 867]. Yahoo! and
Bedrock have agreed to extend the date to file a reply through and including July 12, 2011 and
have agreed to extend the date to file a surreply through and including July 18, 2011.
For the above reasons, Yahoo! and Bedrock respectfully request that the Court enter an
order extending Yahoo!’s time to file a reply in support of its Renewed Motion for Judgment as a

JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 1

Matter of Law Regarding Invalidity through and including July 12, 2011 and extending
Bedrock’s time to file a surreply through and including July 18, 2011.
Respectfully submitted,

/s/ Robert Christopher Bunt
Douglas A. Cawley, Lead Attorney
Texas Bar No. 04035500
[e-mail]
Theodore Stevenson, III
Texas Bar No. 19196650
[e-mail]
Rosemary T. Snider
Texas Bar No. 18796500
[e-mail]
Scott W. Hejny
Texas State Bar No. 24038952
[e-mail]
Jason D. Cassady
Texas Bar No. 24045625
[e-mail]
J. Austin Curry
Texas Bar No. 24059636
[e-mail]
Phillip M. Aurentz
Texas State Bar No. 24059404
[e-mail]
McKOOL SMITH, P.C.
300 Crescent Court, Suite 1500
Dallas, Texas 75201
Telephone: [phone]
Facsimile: 214-978-4044
Sam F. Baxter
Texas Bar No. 01938000
McKOOL SMITH, P.C.
[e-mail]
104 E. Houston Street, Suite 300
P.O. Box 0
Marshall, Texas 75670
Telephone: [phone]
Facsimile: [phone]

JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 2

Robert M. Parker
Texas Bar No. 15498000
Robert Christopher Bunt
Texas Bar No. 00787165
PARKER, BUNT & AINSWORTH, P.C.
100 E. Ferguson, Suite 1114
Tyler, Texas 75702
Telephone: [phone]
Facsimile: 903-533-9687
E-mail: [e-mail]
E-mail: [e-mail]
ATTORNEYS FOR BEDROCK
COMPUTER TECHNOLOGIES LLC

/s/ Jennifer H. Doan
Jennifer H. Doan
Texas Bar No. 08809050
J. Scott Andrews
Texas Bar No. 24064823
HALTOM & DOAN
6500 Summerhill Road, Suite 100
Texarkana, TX 75503
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Fay Morisseau
Christopher D. Bright
Cal. Bar No. 206273
MCDERMOTT WILL & EMERY LLP
18191 Von Karman Ave, Ste. 500
Irvine, California 92612
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
E-mail: [e-mail]
Yar R. Chaikovsky
[e-mail]
John A. Lee
[e-mail]
MCDERMOTT WILL & EMERY
JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 3

275 Middlefield Rd., Suite 100
Menlo Park, CA 94025
Telephone: [phone]
Facsimile: [phone]
ATTORNEYS FOR YAHOO!, INC.

CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in
compliance with Local Rule CV-5(a). 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 certified mail,
return receipt requested, on this the 8th day of July, 2011.

/s/ Jennifer H. Doan
Jennifer H. Doan

JOINT MOTION FOR EXTENSION OF TIME TO FILE A REPLY AND SURREPLY – Page 4