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

Filing 817

MOTION for Extension of Time to File Response/Reply as to 809 Bill of Costs (Unopposed) and Memorandum in Support of Unopposed Motion for Extension of Time to File a Response to Plaintiff's Bill of Costs 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,

Civil Action No. 2:11-cv-512

v.
AOL INC., et al.,
Defendants.

UNOPPOSED MOTION AND MEMORANDUM IN SUPPORT OF UNOPPOSED
MOTION FOR EXTENSION OF TIME TO FILE A RESPONSE TO PLAINTIFF’S BILL
OF COSTS
The Defendants AOL Inc. (“AOL”), IAC Search & Media, Inc. (“IAC Search & Media”),
Gannett Co., Inc. (“Gannett”), Target Corporation (“Target”), and Google Inc. (“Google”)
(collectively “Defendants”), by counsel, pursuant to Rule 7 of the Local Rules of Practice for the
United States District Court for the Eastern District of Virginia, move this Court for entry of an
order granting Defendants an extension of time through and including January 11, 2012, in
which to file their response to Plaintiff’s Bill of Costs (D.N. 809), and in support thereof state as
follows:
1.

Plaintiff filed its Bill of Costs on December 3, 2012. Under Local Rule 7 and

Fed. R. Civ. P. 6, Defendants’ response is due on December 17, 2012.
2.

Defendants have requested, and Plaintiff has agreed to, an extension through and

including January 11, 2013, to file their response to Plaintiff’s Bill of Costs.

01980.51928/5096657.1

3.

Defendants will not oppose an extension until January 25, 2013, for Plaintiff to

file its reply in support of its Bill of Costs.
4.

Granting Defendants an extension through and including January 11, 2013, to file

their responses to the Plaintiff’s Bill of Costs, and Plaintiff an extension through and including
January 25, 2013 to file its reply in support of its Bill of Costs, will not prejudice the parties.
5.

Attached as Exhibit 1 is a proposed agreed order granting Defendants through

and including January 11, 2013 to file their response to Plaintiff's Bill of Costs, and granting
Plaintiff through and including January 25, 2013 to file its reply in support of its Bill of Costs.
WHEREFORE, Defendants, by counsel, request that this Court enter the proposed agreed
order attached as Exhibit 1 granting Defendants through and including January 11, 2013 to file
their response to Plaintiff’s Bill of Costs, and granting Plaintiff through and including January
25, 2013 to file its reply in support of its Bill of Costs.

Dated: December 17, 2012

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 AOL Inc., Google Inc., IAC Search &
Media, Inc., Gannett Co., Inc. and Target
Corporation
David Bilsker
David A. Perlson
QUINN EMANUEL URQUHART &

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SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Counsel for Google Inc., IAC Search & Media, 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]
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 December 17, 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:
W. Ryan Snow
Donald C. Schultz
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]
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.

/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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