I/P Engine, Inc. v. AOL, Inc. et al
Filing
12
MOTION for Extension of Time to File Response/Reply as to 1 Complaint, by Gannett Company, Inc.. (Attachments: # 1 Exhibit A)(Noona, Stephen)
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Norfolk Division
I/P ENGINE, INC.,
Plaintiff,
v.
Civil Action No. 2:11cv512 (RAJ-FBS)
AOL INC., GOOGLE, INC.,
IAC SEARCH & MEDIA, INC.,
GANNETT CO., INC. and
TARGET CORPORATION
Defendants.
MOTION FOR EXTENSION OF TIME FOR GANNETT CO., INC.
TO FILE RESPONSIVE PLEADINGS TO COMPLAINT
The defendant Gannett Co., Inc. (“Gannett”), by counsel, moves this Court for an
extension of time through November 14, 2011, to answer, plead, or otherwise respond to the
Complaint filed by I/P Engine, Inc. (“I/P Engine”), and in support thereof states as follows:
1.
On September 15, 2011, I/P Engine filed its Complaint for patent infringement
against Gannett. On September 23, 2011, I/P Engine served its Complaint upon Gannett.
2.
Gannett’s responsive pleadings are not due until October 14, 2011.
3.
Gannett has requested and I/P Engine has agreed to allow Gannett an extension of
time through November 14, 2011, for Gannett to answer, plead, or otherwise respond to the
Complaint filed by I/P Engine.
4.
Attached as Exhibit A is a proposed agreed order granting Gannett an extension
of time through November 14, 2011, to answer, plead or otherwise respond to the Complaint
filed by I/P Engine. The proposed agreed order is being circulated for endorsement and will be
delivered to the Court once it is fully signed.
WHEREFORE, Gannett, by counsel, requests that this Court enter the attached proposed
agreed order granting Gannett an extension of time through November 14, 2011, to answer,
plead, or otherwise respond to the Complaint.
Dated: October 4, 2011
Respectfully submitted,
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
senoona@kaufcan.com
Counsel for Gannett Co., Inc.
2
CERTIFICATE OF SERVICE
I hereby certify that on October 4, 2011, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
the following:
Jeffrey K. Sherwood
Kenneth W. Brothers
DICKSTEIN SHAPIRO LLP
1825 Eye Street NW
Washington, DC 20006
Telephone: (202) 420-2200
Facsimile: (202) 420-2201
sherwoodj@dicksteinshapiro.com
brothersk@dicksteinshapiro.com
Counsel for Plaintiff, I/P Engine, Inc.
/s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 West Main Street, Suite 2100
Norfolk, VA 23510
Telephone: (757) 624-3000
Facsimile: (757) 624-3169
senoona@kaufcan.com
Counsel for Gannett Co., Inc.
11329925_1.DOC
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