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)

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.

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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: [phone]
Fax: [phone]
[e-mail]
Frank E. Scherkenbach
Kurt L. Glitzenstein
Steven R. Katz
FISH & RICHARDSON P.C.
One Marina Park Drive
Boston, MA 02210
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
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.

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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

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