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

Filing 224

Agreed MOTION for Extension of Time to File Response/Reply 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 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.

AGREED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE IN OPPOSITION
TO PLAINTIFFS' MOTION FOR PROTECTIVE ORDER

The undersigned defendants (“Defendants”) in the above captioned matter respectfully
file this agreed motion for extension of time to file a Response in Opposition (“Opposition”) to
Plaintiffs’ Uniloc USA, Inc. and Uniloc Singapore Private Limited (collectively “Uniloc” or
“Plaintiffs”) Motion for Entry of Protective Order.
Currently, the Defendants’ Opposition is due by August 19, 2011. The Defendants and
Plaintiffs have conferred and agreed that the Defendants shall have until and including August
26, 2011 to file an Opposition. Moreover, the Defendants and Plaintiffs have discussed the
matter and recognize an extension of time is warranted, is in the interests of justice, and is not for
purposes of delay.

Accordingly, the Defendants respectfully request that the Court grant this agreed motion
for extension of time.

Respectfully submitted,
/s/ Steven Katz
Steven Katz (admitted pro hac vice)
[e-mail]
(MA Bar No. 642732)
Email: [e-mail]
Kurt Glitzenstein (admitted pro hac vice)
(MA Bar No. 565312)
Email: [e-mail]
FISH & RICHARDSON P.C.
One Marina Park Drive
Boston, MA 02210
Tel: [phone]
Fax: [phone]
David Healey
(Texas State Bar No. 09327980)
Email: [e-mail]
FISH & RICHARDSON P.C.
1221 McKinney Street
Ste 2800
Houston, TX 77010
Tel: [phone]
Fax: [phone]
COUNSEL FOR DEFENDANTS
NATIONAL INSTRUMENTS CORP.
ADOBE SYSTEMS, INC.
SAFENET, INC.
PINNACLE SYSTEMS, INC.
ONYX GRAPHICS, INC.
ALADDIN KNOWLEDGE SYSTEMS, INC.
ALADDIN KNOWLEDGE SYSTEMS LTD

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 via the Court’s
CM/ECF system per Local Rule CV-5(a)(3). All others not deemed to have consented to
electronic service were served with a true and correct copy of the foregoing pursuant to Federal
Rule of Civil Procedure 5(d) or Local Rule CV-5(d) via email or facsimile transmission or via
first class mail this 19th day of August, 2011.
/s/ Steven Katz
Steven Katz