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

Filing 18

MOTION for Extension of Time to File Answer re 1 Complaint, to Answer, Plead or Otherwise Respond by IAC Search & Media, 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 IAC SEARCH & MEDIA, INC.
TO FILE RESPONSIVE PLEADINGS TO COMPLAINT
The defendant IAC Search & Media, Inc. (“IAC Search”) 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 IAC Search.
2.

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

3.

IAC Search has requested and I/P Engine has agreed to allow IAC Search 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 IAC Search 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, IAC Search, by counsel, requests that this Court enter the attached
proposed agreed order granting IAC Search an extension of time through November 14, 2011, to
answer, plead, or otherwise respond to the Complaint.
Dated: October 11, 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 IAC Search & Media, Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on October 11, 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.,
Gannett Co., Inc. and Target Corporation

/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 IAC Search & Media, Inc.
11336876_1.DOC

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