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

Filing 204

Agreed MOTION for Extension of Time to File Patent Rule 3-3 and 3-4 Disclosures by Adobe Systems Inc., Alladin Knowledge Systems Ltd., Alladin Knowledge Systems, Inc., NATIONAL INSTRUMENTS CORP., Onyx Graphics, Inc., Pinnacle Systems, Inc., Safenet, Inc.. (Attachments: # 1 Text of Proposed Order)(Katz, Steven)

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION UNILOC USA, INC., ET AL. Plaintiffs, Civil Action No. 6:10-cv-472-LED v. JURY TRIAL DEMANDED NATIONAL INSTRUMENTS CORP., ET AL., Defendants. UNILOC USA, INC., ET AL. Plaintiffs, Civil Action No. 6:10-cv-591-LED v. JURY TRIAL DEMANDED ENGRASP, INC., ET AL., Defendants. UNILOC USA, INC., ET AL. Plaintiffs, Civil Action No. 6:10-cv-636-LED v. JURY TRIAL DEMANDED BMC SOFTWARE, INC., ET AL., Defendants. AGREED MOTION FOR EXTENSION OF TIME FOR MOVING DEFENDANTS TO COMPLY WITH P.R. 3-3 AND 3-4 The Moving Defendants comprise certain parties to each of the above-captioned cases and include National Instruments Corporation, Adobe Systems Incorporated, SafeNet, Inc., Aladdin Knowledge Systems, Inc., Aladdin Knowledge Systems Ltd, Pinnacle Systems, Inc., Onyx Graphics, Inc., BMC Software, Inc., Freedom Scientific, Inc., and Freedom Scientific BLV Group LLC (collectively, the “Moving Defendants”). The Moving Defendants are represented by the same counsel, and together they respectfully file this agreed motion for extension of time to comply with P.R. 3-3 and 3-4 to furnish invalidity contentions and accompanying document production. Currently the Moving Defendants must comply with P.R. 3-3 and 3-4 by August 15, 2011. The Moving Defendants and Plaintiffs have conferred and agreed that the Moving Defendants shall have until and including August 26, 2011 to comply with P.R. 3-3 and 3-4. Moreover, the Moving Defendants and Plaintiffs have discussed the matter and recognize an extension of time is warranted, is in the interest of justice, and is not for purposes of delay. Accordingly, the Moving Defendants respectfully request that the Court grant this agreed motion for extension of time for the Moving Defendants to comply with P.R. 3-3 and 3-4. 2 Dated: August 8, 2011 FISH & RICHARDSON P.C. By: /s/ Steven R. Katz David J. Healey FISH & RICHARSON P.C. 1221 McKinney Street - Suite 2800 Houston, TX 77010 Phone: (713) 654-5300 Fax: (713) 652-0109 healey@fr.com Frank E. Scherkenbach Kurt L. Glitzenstein Steven R. Katz FISH & RICHARDSON P.C. One Marina Park Drive Boston, MA 02210 Phone: (617) 542-5070 Fax: (617) 542-8906 scherkenbach@fr.com glitzenstein@fr.com katz@fr.com Counsel for Defendants NATIONAL INSTRUMENTS, ADOBE SYSTEMS INCORPORATED, SAFENET, INC., ALADDIN KNOWLEDGE SYSTEMS, INC., ALADDIN KNOWLEDGE SYSTEMS LTD, PINNACLE SYSTEMS, INC., ONYX GRAPHICS, INC., BMC SOFTWARE, INC., FREEDOM SCIENTIFIC, INC., AND FREEDOM SCIENTIFIC BLV GROUP LLC. 3 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served, via the Court’s CM/ECF system per Local Rule CV-5(a)(3), upon all counsel of record on August 8, 2011. Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Steven R. Katz Steven R. Katz 4

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