Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 621

Joint MOTION for Extension of Time to File Response/Reply as to 601 MOTION to Compel PRODUCTION OF SOURCE CODE FROM GO DADDY by The Go Daddy Group, Inc.. (Attachments: # 1 Text of Proposed Order)(Mukherji, Proshanto)

Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Doc. 621

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EOLAS TECHNOLOGIES, INC., Plaintiff, Civil Action No. 6:09-cv-446-LED v. JURY TRIAL DEMANDED ADOBE SYSTEMS, INC., et. al., Defendants. JOINT MOTION FOR EXTENSION OF TIME TO RESPOND TO EOLAS' MOTION TO COMPEL PRODUCTION OF SOURCE CODE FROM GO DADDY Defendant The Go Daddy Group Inc. ("Go Daddy") and Plaintiff Eolas Technologies, Inc. ("Eolas") respectfully file this joint motion for extension of time for Go Daddy to respond to Eolas's Motion to Compel Production of Source Code from Go Daddy (Dkt. 601) ("Eolas' motion to compel"). Currently, Go Daddy must respond to Eolas's motion to compel by Monday, April 4, 2011. Go Daddy and Eolas are attempting to resolve the issues raised in Eolas' motion to compel between themselves, and have conferred and agreed that Go Daddy shall have until April 8, 2011 to respond to Eolas's motion to compel. The granting of this motion will not alter any other case deadline. Accordingly, Go Daddy and Eolas respectfully request that the Court grant this Joint Motion for Extension of Time to Respond to Eolas' Motion to Compel Production of Source Code from Go Daddy to April 8, 2011.

Dockets.Justia.com

Dated: March 31, 2011

Respectfully submitted, /s/ Proshanto Mukherji Thomas M. Melsheimer (Bar No. 13922550) <[e-mail]> Neil J. McNabnay (Bar No. 24002583) <[e-mail]> Carl E. Bruce (Bar No. 24036278) <[e-mail]> FISH & RICHARDSON P.C. 1717 Main Street, Suite 5000 Dallas, TX 75201 Telephone: [phone] Proshanto Mukherji (pro hac vice) <[e-mail]> FISH & RICHARDSON P.C. One Marina Park Drive Boston, MA 02110-1878 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Counterclaimant The Go Daddy Group, Inc.

/s/ Mike McKool Mike McKool Lead Attorney Texas State Bar No. 13732100 [e-mail] Douglas Cawley Texas State Bar No. 04035500 [e-mail] MCKOOL SMITH, P.C. 300 Crescent Court, Suite 1500 Dallas, Texas 75201 Telephone: [phone] Facsimile: [phone] Kevin L. Burgess Texas State Bar No. 24006927 [e-mail] John B. Campbell Texas State Bar No. 24036314 [e-mail] Josh W. Budwin Texas State Bar No. 24050347 [e-mail] Gretchen K. Harting Texas State Bar No. 24055979 [e-mail] Matthew B. Rappaport Texas State Bar No. 24070472 [e-mail] MCKOOL SMITH, P.C. 300 West Sixth Street, Suite 1700 Austin, Texas 78701 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Eolas Technologies, 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). As such, this document was served on all counsel who have consented to electronic services on this the 31st day of March, 2011. Local Rule CV- 5(a)(3)(A).

/s/ Proshanto Mukherji Proshanto Mukherji