Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 837

Unopposed MOTION for Extension of Time to File Answer re 796 Answer to Amended Complaint, Counterclaim, 797 Answer to Amended Complaint, Counterclaim 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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JURY TRIAL
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EOLAS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO REPLY TO GOOGLE INC. AND YOUTUBE LLC’S
COUNTERCLAIMS TO SECOND AMENDED COMPLAINT
Plaintiff Eolas Technologies Incorporated (“Eolas”) files this Unopposed Motion for
Extension of Time for Eolas to Reply to the Counterclaims of Defendants Google Inc.
(“Google”) and YouTube LLC (“YouTube”) and would show the Court the following:
I.
Google and YouTube filed their Answer and Counterclaims to Eolas’ Second Amended
Complaint on July 29, 2011. Eolas’ replies to those counterclaims are currently due on August
15, 2011. Eolas respectfully requests an extension of time to serve these replies until August 19,
2011. Google and YouTube do not oppose this motion.
II.

This motion is not for delay but so that justice may be done.
Wherefore, Eolas respectfully requests that the Court grant the present Motion and extend
Eolas’ deadline to reply to Google and YouTube’s counterclaims until August 19, 2011.

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DATED: August 10, 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]
Rosemary T. Snider
Texas State Bar No. 18796500
[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. Curran
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 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 August 10, 2011. Local Rule CV-5(a))3)(A).

/s/ Josh W. Budwin
Josh W. Budwin

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