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)

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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. § § § § § § § § § § 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: (903) 757-6400 Fax: (903) 757-2323 jw@jwfirm.com wh@jwfirm.com 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: (512) 542-8400 Fax: (512) 542-8612 dweaver@velaw.com aross@velaw.com apai@velaw.com sfareed@velaw.com jhan@velaw.com slindner@velaw.com jta@velaw.com 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: (713) 758-2222 Fax: (713) 758-2346 sborgman@velaw.com gsamora@velaw.com Constance S. Huttner (NY Bar No. 1722024) VINSON & ELKINS LLP 666 5th Avenue, 26th Floor New York, NY 10103-0040 Tel: (212) 237-0040 Fax: (9l7) 849-5339 chuttner@velaw.com Wi-LAN@velaw.com 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

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