Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 141

Joint MOTION for Extension of Time to File Docket Control Order by Uniloc Singapore Private Limited, Uniloc USA, Inc.. (Attachments: # 1 Text of Proposed Order)(Hill, Jack)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION UNILOC USA, INC., ET AL. Plaintiffs, vs. SONY CORPORATION OF AMERICA, ET AL. Defendants. UNILOC USA, INC., ET AL. Plaintiffs, vs. DISK DOCTORS LABS, INC., ET AL. Defendants. UNILOC USA, INC., ET AL. Plaintiffs,   vs. NATIONAL INSTURMENTS COPR., ET AL. Defendants. UNILOC USA, INC., ET AL. Plaintiffs, vs. ENGRASP, INC., ET AL. Defendants. § § § § § § § § § CASE NO. 6:10-CV-373 PATENT CASE § § § § § § § § §   CASE NO. 6:10-CV-471 PATENT CASE § § § § § § § § § CASE NO. 6:10-CV-472 PATENT CASE § § § § § § § § § CASE NO. 6:10-CV-591 PATENT CASE UNILOC USA, INC., ET AL. Plaintiffs, vs. BMC SOFTWARE, INC., ET AL. Defendants. UNILOC USA, INC., ET AL. Plaintiffs, vs. FOXIT CORPORATION, ET AL. Defendants. SYMANTEC CORPORATION, ET AL. Plaintiffs, vs. UNILOC USA, INC., ET AL. Defendants. § § § § § § § § § CASE NO. 6:10-CV-636 PATENT CASE § § § § § § § § § CASE NO. 6:10-CV-691 PATENT CASE § § § § § § § § § CASE NO. 6:11-CV-33 PATENT CASE JOINT MOTION FOR EXTENSION TO FILE DOCKET CONTROL ORDER Uniloc, Activision, Adobe, Aladdin, ApexSQL, Articulate Global, Automatic Duck, BMC, Data Access, Digital River, Gear entities (2), EA, eEye, Engrasp, Final Draft, Intego, Intuit, LegalPRO Systems, National Instruments, Onyx, Pinnacle, Quinstar, Safenet, ScriptLogic, Solar Winds, Sonic, Sony, Symantec, Tableau Software, Transmagic, and Wildpackets respectfully move the court for a two-day extension of time until June 2, 2011, to submit the Docket Control Order required by the Court’s May 20, 2011 order. As reflected in the certificate of conference attached hereto, since the issuance of the Court’s May 20th order, the parties have worked diligently to agree upon dates for the Docket Control Order. Despite their diligence to date, the moving parties believe that a brief two-day extension will allow the parties to continue to narrow certain remaining differences on particular dates. While not all parties have expressly joined this motion, no party has expressly opposed the requested two-day extension. An order reflecting the relief requested is attached for the Court’s convenience. By: /s/ Paul J. Hayes (w/permission Wes Hill) Paul J. Hayes – Lead Attorney Dean G. Bostock HAYES, BOSTOCK & CRONIN, LLC 300 Brickstone Square, 9th Floor Andover, MA 01810 (978) 809-3850 (978) 809-3869 (fax) dbostock@hbcllc.com T. John Ward, Jr. Texas State Bar. No. 00794818 J. Wesley Hill Texas State Bar. No. 24032294 WARD & SMITH LAW FIRM 111 West Tyler St. Longview, Texas 75601 Tel: (903) 757-6400 Fax: (903) 757-2323 Email: jw@wsfirm.com E-mail: wh@wsfirm.com ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF CONFERENCE I hereby certify that counsel for 57 of the 60 defendants has complied with the meet and confer requirements in Local Rule CV-7(h). This motion is consented to and not opposed by the parties listed below. Some parties have not participated. The Court Issued its Order on May 20, 2011. Uniloc emailed to all defendants a proposed Discovery Offer on May 22, 2011. A group of defendants circulated a counterproposal on May 26th. Seven group telephonic conferences were held May 27, 2011. Counsels for Uniloc and various defendants exchanged numerous emails between May 22, and May 31, 2011. Uniloc circulated modifications on May 30, 2011. A group of defendants responded with additional changes. A final meet and confer was conducted by telephone on May 31, 2011 with counsels for a number of the parties. The Discovery Order was finalized and submitted on May 31. A number of parties (34 listed below) believe a short extension of 2 days would allow the parties to narrow the open issues relating to the Docket Control Order. Parties consenting to the Extension Uniloc entities (2), Activision, Adobe, Aladdin entities (2), ApexSQL, Articulate Global, Automatic Duck, BMC, Data Access, Digital River, Gear entities (2), EA, eEye, Engrasp, Final Draft, Intego, Intuit, LegalPRO Systems, National Instruments, Onyx, Pinnacle, Quinstar, Safenet, ScriptLogic, Solar Winds, Sonic, Sony, Symantec, Tableau Software, Transmagic, Wildpackets /s/ Wesley Hill CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document through the Court’s CM/ECF system per Local Rule CV-5(a)(3) on the 31st day of May, 2011. /s/ Wesley Hill Wesley Hill

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