WI-LAN Inc. v. Alcatel-Lucent USA Inc. et al

Filing 433

Unopposed MOTION for Extension of Time to File Response/Reply as to 413 SEALED MOTION for Clarification by WI-LAN Inc.. (Attachments: # 1 Text of Proposed Order)(Pai, Ajeet)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION
WI-LAN INC.,
Plaintiff,
v.
ALCATEL-LUCENT USA INC.; et al.
Defendants.

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Civil Action No. 6:10-cv-521-LED
JURY TRIAL DEMANDED

PLAINTIFF WI-LAN INC.’S UNOPPOSED MOTION FOR EXTENSION OF
TIME TO RESPOND TO THE ERICSSON AND SONY MOBILE
DEFENDANTS’ MOTION FOR CLARIFICATION

Wi-LAN Inc. (“Plaintiff”) respectfully moves the Court to extend the time for
Plaintiff to respond to the Ericsson and Sony Mobile Defendants’ (collectively,
“Defendants”) Motion for Clarification (Dkt. No. 413) through and including Monday,

July 26, 2013. Plaintiff would show the following in support of its motion:
As currently set, Plaintiff’s response to Defendants’ Motion is due on July 5,
2013, immediately before presentation of evidence in the jury trial currently set in this
matter on July 8, 2013. Defendants’ Reply is currently due on July 15, 2013, during trial.
Plaintiff respectfully requests that its deadline to respond (and subsequent dates for
Defendants’ Reply and Plaintiff’s Sur-Reply, if any) be moved until after trial in order to
permit the parties to focus on trial preparation and the trial itself.
Defendants Ericsson and Sony Mobile do not oppose this request. Plaintiff seeks
this extension of time not for delay but for good cause and that justice may be served.

WHEREFORE, for good cause shown, Plaintiff respectfully requests that the time
to respond to Defendants’ Motion for Clarification (Dkt. No. 413) be extended through
and including Monday, July 26, 2013.

Dated: July 3, 2013

Respectfully submitted,

By:
Local Counsel
Johnny Ward (TX Bar No. 00794818)
Wesley Hill (TX Bar No. 24032294)
Claire Abernathy Henry
(TX Bar No. 24053063)
WARD & SMITH LAW FIRM
P.O. Box 1231
1127 Judson Rd., Ste. 220
Longview, TX 75606-1231
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
claire@wsfirmcom

/s/ Ajeet P. Pai
David B. Weaver (TX Bar No. 00798576)
Lead Attorney
Avelyn M. Ross (TX Bar No. 24027817)
Ajeet P. Pai (TX Bar No. 24060376)
Syed K. Fareed (TX Bar No. 24065216)
Jeffrey T. Han (TX Bar No. 24069870)
Seth A. Lindner (TX Bar No. 24078862)
Janice Ta (TX Bar No. 24075138)
VINSON & ELKINS LLP
2801 Via Fortuna, Suite 100
Austin, TX 78746
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Steve R. Borgman (TX Bar No. 02670300)
Gwendolyn J. Samora
(TX Bar No. 00784899)
VINSON &ELKINS LLP
1001 Fannin Street, Suite 2500
Houston, TX 77002-6760
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Constance S. Huttner
(NY Bar No. 1722024)

VINSON & ELKINS LLP
666 5th Avenue, 26th Floor
New York, NY 10103-0040
Tel: [phone]
Fax: (9l7) 849-5339
[e-mail]
[e-mail]
Attorneys for Plaintiff, Wi-LAN Inc.

CERTIFICATE OF CONFERENCE
As required by Local Rule CV–7(h), following conference, counsel for the
Ericsson and Sony Mobile Defendants do oppose this request.
/s/ Ajeet P. Pai
Ajeet P. Pai

CERTIFICATE OF SERVICE
The undersigned certifies that the foregoing document was filed electronically in
compliance with Local Rule CV-5(a). As such, this document was served on all counsel
who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). All
other counsel of record not deemed to have consented to electronic service were served
with a true and correct copy of the foregoing by email and/or fax, on this the 3rd day of
July 2013.

/s/ Ajeet P. Pai
Ajeet P. Pai