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

Filing 225

Agreed MOTION for Extension of Time to File RESPONSE IN OPPOSITION TO PLAINTIFFS MOTION FOR ENTRY OF PROTECTIVE ORDER by Symantec Corp.. (Attachments: # 1 Text of Proposed Order)(Jones, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION

UNILOC USA, INC. and
UNILOC SINGAPORE PRIVATE LIMITED,

Civil Action No. 6:10-CV-472-LED

Plaintiffs,
v.
NATIONAL INSTRUMENTS CORP. et al.,
Defendants.

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

Defendant Symantec Corporation (“Symantec”) hereby respectfully files this agreed
motion for extension of time to file a Response in Opposition (“Opposition”) to Plaintiffs’
Uniloc USA, Inc. and Uniloc Singapore Private Limited’s (collectively “Uniloc” or “Plaintiffs”)
Motion for Entry of Protective Order.
Currently, Symantec’s Opposition is due by August 19, 2011. Symantec and Plaintiffs
have conferred and agreed that Symantec shall have until and including August 26, 2011 to file
an Opposition. Moreover, Symantec 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, Symantec respectfully requests that the Court grant this agreed motion for
extension of time.

{A07/7643/0005/W0483174.1 }

Dated: August 19, 2011

Respectfully submitted,

/s/ Michael E. Jones
Michael E. Jones
State Bar No. 10929400
POTTER MINTON
A Professional Corporation
110 N. College, Suite 500
Tyler, Texas 75702
[phone]
[phone] (Facsimile)
[e-mail]
LATHAM & WATKINS LLP
Mark A. Flagel
Yury Kapgan
Dale Chang
355 S. Grand Avenue
Los Angeles, CA 90071-1560
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
LATHAM & WATKINS LLP
Dean G. Dunlavey
650 Town Center Drive, 20th Floor
Costa Mesa, CA 92626-1925
Tel: [phone]
Fax: [phone]
[e-mail]
ATTORNEYS FOR DEFENDANT
SYMANTEC CORPORATION

{A07/7643/0005/W0483174.1 }

CERTIFICATE OF SERVICE
I hereby certify that all counsel of record who 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) on
August 19, 2011. Any other counsel of record will be served by electronic mail or first class U.S.
mail on this same date.
/s/ Michael E. Jones
Michael E. Jones

{A07/7643/0005/W0483174.1 }