Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 350

Unopposed MOTION to Amend/Correct #1 Complaint,,,,,,, Plaintiff's Unopposed Motion to Change the Name of Defendant Victoria's Secret by Parallel Networks, LLC. (Attachments: #1 Text of Proposed Order)(Tadlock, Charles)

Parallel Networks, LLC v. Adidas America, Inc. et al

Doc. 350

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Parallel Networks, LLC, Plaintiff, v. Adidas America, Inc., et al., Defendants. PLAINTIFF'S UNOPPOSED MOTION TO CHANGE THE NAME OF DEFENDANT VICTORIA'S SECRET Plaintiff Parallel Networks, LLC respectfully moves the Court to change the name of Defendant Victoria's Secret to Victoria's Secret Direct Brand Management, LLC, and shows the Court as follows: 1. The parties have worked in good faith to resolve the issues raised by Defendant No. 6:10-cv-00491-LED Jury Trial Demanded

regarding the proper names of the parties to this action; 2. 3. Plaintiff's Original Complaint lists Victoria's Secret as a Defendant in this action; The correct name of the Defendant should be Victoria's Secret Direct Brand

Management, LLC; 4. The Parties request that the caption be reformed to reflect the proper parties, as set

forth in the proposed Order accompanying this Motion; 5. Motion; 6. Pursuant to agreed extension, Defendant Victoria's Secret Direct Brand Defendant Victoria's Secret Direct Brand Management, LLC does not oppose this

Management, LLC will answer or otherwise respond to the complaint on or before December 1, 2010. 1

Dockets.Justia.com

7.

This Motion is not sought for the purposes of delay, but to ensure that the correct

parties are properly joined to this action. Dated: November 29, 2010 Respectfully submitted, By: /s/ Charles Craig Tadlock Charles Craig Tadlock Texas State Bar No. 00791766 TADLOCK LAW FIRM 400 E. Royal Lane, Suite 290 Irving, Texas 75039 214-785-6014 (phone) [e-mail] and 315 N. Broadway, Suite 307 Tyler, Texas 75702 903-283-2758 (phone) George S. Bosy (pro hac vice) David R. Bennett (pro hac vice) Bosy & Bennett 300 N. La Salle St. 49th Floor Chicago, IL 60654 Telephone: [phone] Email: [e-mail] [e-mail] ATTORNEYS FOR PLAINTIFF PARALLEL NETWORKS, LLC

CERTIFICATE OF CONFERENCE I hereby certify that counsel for Plaintiff Parallel Networks and Defendant Victoria's Secret Direct Brand Management, LLC, have conferred by phone in accordance with Local Rule CV-7, and that this Motion is unopposed. /s/ Charles Craig Tadlock One of the Attorneys for Parallel Networks, LLC

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CERTIFICATE OF SERVICE I hereby certify that counsel of record who are deemed to have consented to electronic service are being served this 29th day of November, 2010, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Charles Craig Tadlock One of the Attorneys for Parallel Networks, LLC

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