Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 713

Unopposed MOTION to Expedite BRIEFING ON EOLAS' MOTION TO COMPEL DISCOVERY FROM ADOBE SYSTEMS INC. REGARDING INVESTMENT/LICENSING AGREEMENTS WITH INTELLECTUAL VENTURES ENTITIES by Eolas Technologies Incorporated. (Attachments: # 1 Text of Proposed Order)(McKool, Mike)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
Eolas Technologies Incorporated,
Plaintiff,
vs.
Adobe Systems Inc., Amazon.com, Inc.,
Apple Inc., Argosy Publishing, Inc.,
Blockbuster Inc., CDW Corp.,
Citigroup Inc., eBay Inc., Frito-Lay, Inc.,
The Go Daddy Group, Inc., Google Inc.,
J.C. Penney Company, Inc., JPMorgan
Chase & Co., New Frontier Media, Inc.,
Office Depot, Inc., Perot Systems Corp.,
Playboy Enterprises International, Inc.,
Rent-A-Center, Inc., Staples, Inc., Sun
Microsystems Inc., Texas Instruments Inc.,
Yahoo! Inc., and YouTube, LLC
Defendants.

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§ Civil Action No. 6:09-CV-00446-LED
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JURY TRIAL
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EOLAS’ UNOPPOSED MOTION FOR EXPEDITED BRIEFING
ON EOLAS’ MOTION TO COMPEL DISCOVERY FROM
ADOBE SYSTEMS INC. REGARDING INVESTMENT/LICENSING
AGREEMENTS WITH INTELLECTUAL VENTURES ENTITIES
On June 20, 2011, Plaintiff Eolas Technologies Incorporated (“Eolas”) filed its Motion to
Compel Discovery from Adobe Regarding Investment/Licensing Agreements with Intellectual
Ventures Entities. Eolas requests that the Court issue an expedited briefing schedule on this
motion and address the motion on an expedited basis so that the matter may be heard at the
Court’s earliest convenience.1
Eolas requests that the Court set an expedited briefing schedule. Eolas proposes the
following expedited briefing schedule.
Defendant’s opposition brief due:

1

Friday, June 24, 2011.

Counsel for Adobe, David Healey, has advised counsel for Eolas that he is unavailable for the
hearing on June 29, 2011, but that Adobe would not oppose expedited resolution of this issue.

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Eolas’ reply brief due:

Monday, June 27, 2011.

WHEREFORE, Eolas therefore requests the Court grant the expedited briefing schedule
as outlined above and in the attached Order.
DATED: June 20, 2011

Respectfully submitted,
McKOOL SMITH P.C.
By:

/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]
Telecopier: [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]
Telecopier: [phone]
ATTORNEYS FOR PLAINTIFF
EOLAS TECHNOLOGIES INC.

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CERTIFICATE OF CONFERENCE
Counsel for Plaintiff conferred with Counsel for Defendant regarding the relief requested
in this motion on June 16, 2011. Counsel for Adobe, David Healey, has advised counsel for
Eolas that he is unavailable for the hearing on June 29, 2011, but that Adobe would not oppose
an expedited briefing schedule.
/s/ Josh W. Budwin____
Josh W. Budwin

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 June 20, 2011. Local Rule CV-5(a))3)(A).

/s/ Rosemary Snider________
Rosemary Snider

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