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

Filing 951

MOTION for Leave to File Corrected Reply in Support of its Motion for an Award of Post-Judgment Royalties by I/P Engine, Inc.. (Attachments: # 1 Exhibit Reply in Support of its Motion for an Award of Post-Judgment Royalties, # 2 Proposed Order Proposed Order)(Schultz, Donald)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION __________________________________________ ) ) I/P ENGINE, INC., ) ) Plaintiff, ) v. ) ) AOL, INC. et al., ) ) Defendants. ) __________________________________________) Civil Action No. 2:11-cv-512 I/P ENGINE, INC.’S MOTION FOR LEAVE TO FILE CORRECTED REPLY IN SUPPORT OF ITS MOTION FOR AN AWARD OF POST JUDGMENT ROYALTIES Plaintiff I/P Engine, Inc. (“I/P Engine”), by counsel, respectfully moves the Court to enter an Order granting I/P Engine leave to file a corrected Reply in Support of Its Motion for an Award of Post Judgment Royalties, attached as Exhibit A, and in support states as follows: 1. On May 20, 2013, I/P Engine filed a Reply in Support of its Motion for an Award of Post-Judgment Royalties [D.E. #949] (the “Reply”). 2. The Reply contained three errors that I/P Engine seeks leave to correct. On page 2, fifth line from the bottom, the word “infringers” should be changed to “infringes.” Also on page 2, the second sentence from the bottom that begins with “It asks . . . .” should be deleted in its entirety. Finally, on page 8, first line, the reference to “2013” should be changed to “2012”. 3. Plaintiff requests that the Court grants leave to file a corrected Reply. corrected Reply, containing these changes, is attached as Exhibit A. 4. The Defendants consent to the relief sought by I/P Engine. The WHEREFORE, Plaintiff I/P Engine, Inc., respectfully moves this Honorable Court for entry of an Order granting leave to allow it to file a corrected Reply in Support of its Motion for Post-Judgment Royalties, and for all just and necessary relief. Dated: May 22, 2013 I/P ENGINE, INC. By: Donald C. Schultz, VSB No. 30531 W. Ryan Snow, VSB No. 47423 CRENSHAW, WARE & MARTIN, P.L.C. 150 West Main Street, Suite 1500 Norfolk, Virginia 23510 Telephone: (757) 623-3000 Facsimile: (757) 623-5735 dschultz@cwm-law.com wrsnow@cwm-law.com Jeffrey K. Sherwood, VSB No. 19222 Frank C. Cimino, Jr. Kenneth W. Brothers Dawn Rudenko Albert Charles J. Monterio, Jr. DICKSTEIN SHAPIRO LLP 1825 Eye Street, NW Washington, DC 20006 Telephone: (202) 420-2200 Facsimile: (202) 420-2201 Counsel for I/P Engine, Inc. 2 /s/ Donald C. Schultz Of Counsel CERTIFICATE OF SERVICE I certify that on this 22nd day of May 2013 I electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will send notification to the following: Stephen Edward Noona Kaufman & Canoles, P.C. 150 W Main St, Suite 2100 Norfolk, VA 23510 senoona@kaufcan.com David Bilsker David Perlson Quinn Emanuel Urquhart & Sullivan LLP 50 California Street, 22nd Floor San Francisco, CA 94111 davidbilsker@quinnemanuel.com davidperlson@quinnemanuel.com Robert L. Burns Finnegan, Henderson, Farabow, Garrett & Dunner, LLP Two Freedom Square 11955 Freedom Drive Reston, VA 20190 robert.burns@finnegan.com Cortney S. Alexander Finnegan, Henderson, Farabow, Garrett & Dunner, LLP 3500 SunTrust Plaza 303 Peachtree Street, NE Atlanta, GA 94111 cortney.alexander@finnegan.com /s/ Donald C. Schultz 3

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