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

Filing 224

Consent MOTION for Extension and Memorandum in Support of Consent Motion for Extension of Page Limit for Briefing Summary Judgment Motion by AOL Inc., Gannett Company, Inc., Google Inc., IAC Search & Media, Inc., Target Corporation. (Attachments: # 1 Exhibit 1)(Noona, Stephen)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION

I/P ENGINE, INC.
Plaintiff,
v.

Civil Action No. 2:11-cv-512

AOL, INC., et al.,
Defendants.

CONSENT MOTION AND MEMORANDUM IN SUPPORT OF CONSENT MOTION
FOR EXTENSION OF PAGE LIMIT FOR BRIEFING SUMMARY JUDGMENT
MOTION
Defendants Google Inc., Target Corporation, IAC Search & Media, Inc., Gannet Co., Inc.
and AOL Inc. (collectively “Defendants”), by counsel, move this Court for an extension of the
page limit set forth in Rule 7 of the Local Rules of Practice for the United States District Court
for the Eastern District of Virginia (“Local Rules of Practice”) in connection with an anticipated
motion for summary judgment (“Motion for Extension of Page Limits”), and in support thereof
states as follows:
1.

The Defendants anticipate filing a motion for summary judgment in the

referenced matter. Pursuant to Rule 7 of the Local Rules of Practice, moving and opposition
briefs are limited to 30 pages.
2.

In light of the complex issues involved in the motion, the Defendants have

requested and the Plaintiff has agreed to allow Defendants an additional 10 pages in connection

with the briefing of its motion for summary judgment. The Plaintiff will also be allowed an
additional 10 pages in its opposition.
3.

A proposed Agreed Order granting the request for an extension of the page

limitation is attached as Exhibit 1. The parties are circulating a copy of the proposed Order for
execution. Once the proposed Order is fully executed, the parties will file it with the Court for
consideration.
WHEREFORE, the Defendants, by counsel, request that this Court enter the proposed
Order attached as Exhibit 1 granting an extension of the page limitations imposed by Local Rule
7 in connection with the Defendants’ motion for summary judgment.

DATED: August 29, 2012

/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]
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Google Inc., Target Corporation,
IAC Search & Media, Inc., and
Gannet Co., Inc.

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By: /s/ Stephen E. Noona
Stephen E. Noona
Virginia State Bar No. 25367
KAUFMAN & CANOLES, P.C.
150 W. Main Street, Suite 2100
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
Robert L. Burns
FINNEGAN, HENDERSON, FARABOW, GARRETT &
DUNNER, LLP
Two Freedom Square
11955 Freedom Drive
Reston, VA 20190
Telephone: [phone]
Facsimile: [phone]
Cortney S. Alexander
FINNEGAN, HENDERSON, FARABOW, GARRETT &
DUNNER, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE
Atlanta, GA 94111
Telephone: [phone]
Facsimile: [phone]
Counsel for Defendant AOL, Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on August 29, 2012, 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]
Donald C. Schultz
W. Ryan Snow
Steven Stancliff
CRENSHAW, WARE & MARTIN, P.L.C.
150 West Main Street, Suite 1500
Norfolk, VA 23510
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
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: [phone]
Facsimile: [phone]
[e-mail]

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