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

Filing 869

Joint MOTION for Extension of Time to File Response/Reply as to #842 Opposed MOTION for Attorney Fees Yahoo!'s Motion to Declare this an Exceptional Case and for Attorneys' Fees and Costs Pursuant to 35 USC Sec. 285 (Joint Motion for Extension of Time to File Reply and Surreply to Yahoo!'s Motion to Declare this an Exceptional Case and for Attorneys' Fees and Costs Pursuant to 35 U.S.C. 285) 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 REPLY AND
SURREPLY TO YAHOO!’S MOTION TO DECLARE THIS AN EXCEPTIONAL CASE
AND FOR ATTORNEYS’ FEES AND COSTS PURSUANT TO 35 U.S.C. § 285
Plaintiff Bedrock Computer Technologies, LLC (“Bedrock”) and Defendant Yahoo! Inc.
(“Yahoo!”) file this motion to extend the time to file a reply and a surreply to Yahoo!’s Motion
to Declare This an Exceptional Case and For Attorneys’ Fees and Costs Pursuant to 35 U.S.C. §
285 and would respectfully show the Court the following:
Yahoo!’s current deadline to file a reply in support of its Motion to Declare This an
Exceptional Case and For Attorneys’ Fees and Costs Pursuant to 35 U.S.C. § 285 [Dkt. No. 842]
is July 11, 2011. Yahoo! requested a short extension, through and including July 15, 2011, to
file a reply [Dkt. No. 849]. 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]. Bedrock and Yahoo! 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, Bedrock and Yahoo! respectfully request that the Court enter an
order extending Yahoo!’s time to file a reply in support of its Motion to Declare This an

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

Exceptional Case and For Attorneys’ Fees and Costs Pursuant to 35 U.S.C. § 285 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