Stragent, LLC et al v. Classmates Online, Inc. et al

Filing 83

Unopposed MOTION for Extension of Time to File Response/Reply to 69 United Online, Inc. and Classmates Media Corporation's Motion to Dismiss for Lack of Subject Matter Jurisdiction, Lack of Personal Jurisdiction, and Improper Venue by SeeSaw Foundation, Stragent, LLC. (Attachments: # 1 Text of Proposed Order)(Albritton, Eric)

Stragent, LLC et al v. Classmates Online, Inc. et al

Doc. 83

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION STRAGENT, LLC, et al., Plaintiffs, v. CLASSMATES ONLINE, INC., et al., Defendants. § § § § § § § § §

CIVIL ACTION NO. 6:10-CV-242-LED

JURY TRIAL DEMANDED

PLAINTIFFS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS UNITED ONLINE, INC. AND CLASSMATES MEDIA CORPORATION'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION, LACK OF PERSONAL JURISDICTION, AND IMPROPER VENUE

Plaintiffs Stragent, LLC and SeeSaw Foundation respectfully move for an extension of time to respond to Defendants United Online, Inc. and Classmates Media Corporation's Motion to Dismiss for Lack of Subject Matter Jurisdiction, Fed. R. Civ. P. 12(b)(1), Lack of Personal Jurisdiction, Fed. R. Civ. P. 12(b)(2), and Improper Venue, Fed. R. Civ. P. 12(b)(3) (Dkt. No. 69) ("UOL's Motion"). In support of this motion, Plaintiffs would show the Court the following: UOL's Motion was filed on October 18, 2010. Thus, Plaintiffs' due date to respond to UOL's Motion is currently November 4, 2010. Plaintiffs have conferred with Defendants United Online, Inc. and Classmates Media Corporation, who do not oppose extending this deadline to November 12, 2010. WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfully request the Court to extend their deadline to respond to UOL's Motion to November 12, 2010.

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Respectfully submitted,

___________________________ Eric M. Albritton Texas Bar No. 00790215 [e-mail] Adam A. Biggs Texas Bar No. 24051753 [e-mail] Debra Coleman Texas Bar No. 24059595 [e-mail] Matthew C. Harris Texas Bar No. 24059904 [e-mail] ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: [phone] Facsimile: [phone] T. John Ward, Jr. State Bar No. 00794818 [e-mail] WARD & SMITH LAW FIRM P.O. Box 1231 Longview, Texas 75606-1231 Telephone: [phone] Facsimile: [phone] Danny L. Williams Texas Bar No. 21518050 [e-mail] J. Mike Amerson Texas Bar No. 01150025 [e-mail] Jaison C. John Texas State Bar No. 24002351 [e-mail] Christopher N. Cravey Texas Bar No. 24034398 [e-mail]

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Matthew R. Rodgers Texas Bar No. 24041802 [e-mail] Michael A. Benefield Indiana Bar No. 24560-49 [e-mail] David Morehan Texas Bar No. 24065790 [e-mail] WILLIAMS, MORGAN & AMERSON, P.C. 10333 Richmond, Suite 1100 Houston, Texas 77042 Telephone: [phone] Facsimile: [phone] Attorneys for Stragent, LLC and SeeSaw Foundation

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 are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), 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 email, on this the 4th day of November 2010.

___________________________ Eric M. Albritton

CERTIFICATE OF CONFERENCE Counsel for Defendants United Online, Inc. and Classmates Media Corporation has advised that it is unopposed to the relief requested herein.

___________________________ Eric M. Albritton 3