I/P Engine, Inc. v. AOL, Inc. et al

Filing 15

MOTION for Extension of Time to File Answer re 1 Complaint, Answer, Plead or Otherwise Respond to Complaint by Target Corporation. (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 TARGET CORPORATION
TO FILE RESPONSIVE PLEADINGS TO COMPLAINT
The defendant Target Corporation (“Target”), 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 Target. On September 23, 2011, I/P Engine served its Complaint upon Target.
2.

Target’s responsive pleadings are not due until October 14, 2011.

3.

Target has requested and I/P Engine has agreed to allow Target an extension of

time through November 14, 2011, for Target 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 Target 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, Target, by counsel, requests that this Court enter the attached proposed
agreed order granting Target an extension of time through November 14, 2011, to answer, plead,
or otherwise respond to the Complaint.
Dated: October 10, 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: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Target Corporation

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CERTIFICATE OF SERVICE
I hereby certify that on October 10, 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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Plaintiff, I/P Engine, Inc.
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 W. Main Street, Suite 2100
Norfolk, VA 23510-1665
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Counsel for AOL Inc., Google, Inc.
and Gannett Co., 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: [phone]
Facsimile: [phone]
[e-mail]
Counsel for Target Corporation
11336876_1.DOC

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