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

Filing 226

Agreed MOTION for Extension of Time to File Response in Opposition to Plaintiffs' Motion for a Protective Order by FileMaker, Inc.. (Attachments: # 1 Text of Proposed Order)(Kim, Rudolph)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ) ) ) ) Plaintiffs, ) ) v. ) ) NATIONAL INSTRUMENTS CORP., ) et al. ) ) Defendants. __________________________________ ) UNILOC USA, INC. and UNILOC SINGAPORE PRIVATE LIMITED, Civil Action No. 6:10-cv-472-LED JURY TRIAL DEMANDED AGREED MOTION FOR EXTENSION OF TIME FOR DEFENDANT FILEMAKER, INC. TO FILE ITS RESPONSE IN OPPOSITION TO PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER Defendant FileMaker, Inc. (“FileMaker”) 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 (collectively “Uniloc” or “Plaintiffs”) Motion for Entry of Protective Order (Dkt. No. 200). Currently, FileMaker’s Opposition is due by August 19, 2011. FileMaker and Plaintiffs have conferred and agreed that FileMaker shall have until and including August 26, 2011 to file its Opposition. Moreover, FileMaker 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, FileMaker respectfully requests that the Court grants this agreed motion for extension of time. // // // Dated: August 19, 2011 Respectfully submitted, /s/ Rudy Y. Kim Rudy Y. Kim MORRISON & FOERSTER LLP Michael A. Jacobs (CA Bar No. 111664) 425 Market Street San Francisco, California 94105 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 E-mail: mjacobs@mofo.com MORRISON & FOERSTER LLP Rudy Y. Kim (CA Bar No. 199426) Christopher F. Jeu (TX Bar No. 24050823) 755 Page Mill Road Palo Alto, California 94304 Telephone: (650) 813-5600 Facsimile: (650) 494-0792 E-mail: rudykim@mofo.com E-mail: cjeu@mofo.com Attorneys for Defendant FILEMAKER, INC. 2 CERTIFICATE OF SERVICE The undersigned certifies that, on August 19, 2011, the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this document was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(e), any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Rudy Y. Kim Rudy Y. Kim 3

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