I/P Engine, Inc. v. AOL, Inc. et al
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)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
I/P ENGINE, INC.,
AOL, INC. et al.,
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:
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”).
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”.
Plaintiff requests that the Court grants leave to file a corrected Reply.
corrected Reply, containing these changes, is attached as Exhibit A.
The Defendants consent to the relief sought by I/P Engine.
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.
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
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.
/s/ Donald C. Schultz
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 email@example.com
Quinn Emanuel Urquhart & Sullivan LLP
50 California Street, 22nd Floor San Francisco, CA 94111
Robert L. Burns
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP Two
11955 Freedom Drive Reston, VA 20190
Cortney S. Alexander
Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
3500 SunTrust Plaza
303 Peachtree Street, NE Atlanta, GA 94111
/s/ Donald C. Schultz
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