VIA VADIS, LLC v. SKYPE, Inc. et al

Filing 6

STIPULATION Regarding Response Time for Defendant Skype, Inc. by VIA VADIS, LLC. (Attachments: # 1 Proposed Order Proposed Order)(Zoltick, Martin)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION VIA VADIS, LLC, Plaintiff, Civil Action No. 3:11-CV-306 (REP) v. SKYPE, INC.; SKYPE COMMUNICATIONS SARL; SKYPE GLOBAL SARL; SKYPE SOFTWARE SARL; and SKYPE TECHNOLOGIES, SA, Defendants. STIPULATION AND [PROPOSED] ORDER REGARDING RESPONSE TIME FOR DEFENDANT SKYPE, INC. IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for Plaintiff Via Vadis, LLC (“Via Vadis”) and Defendant Skype, Inc. (“Skype”) herein, as follows: 1. On May 17, 2011, Via Vadis served Skype with the Complaint in this action. Skype’s response date is currently June 7, 2011. 2. Skype and Via Vadis have agreed to a thirty (30) day extension of time in which Skype may respond to the Complaint. The date by which Skype shall respond to the Complaint shall be July 7, 2011. 3. By entering into this stipulation, Skype does not waive any objections or defenses it may assert in response to the Complaint. Skype agrees not to use this extension requested by Skype or the fact that Via Vadis agreed to such extension against Via Vadis, including in setting the schedule in this case, conducting discovery, and preparing for and proceeding with trial. 04194.51872/4173449.1 Dated: June 7, 2011 ROTHWELL, FIGG, ERNST & MANBECK, P.C. QUINN EMANUEL URQUHART & SULLIVAN, LLP By: __/s/_________________________ Martin M. Zoltick (VSB No. 30058) mzoltick@rfem.com 1425 K St., N.W., Suite 800 Washington, D.C. 20005 Tel: (202) 783-6040 By: __/s/_________________________ Claude M. Stern claudestern@quinnemanuel.com 555 Twin Dolphin Drive, 5th Floor Redwood Shores, CA 94065 Tel: (650) 801-5000 Attorneys for Plaintiff Via Vadis, LLC 04194.51872/4173449.1 Attorneys for Defendant Skype, Inc. 2 CERTIFICATE OF SERVICE I certify that on the 7th day of June, 2011, I electronically filed the foregoing STIPULATION AND [PROPOSED] ORDER REGARDING RESPONSE TIME FOR DEFENDANT SKYPE, INC. with the Clerk of Court for the U.S. District Court for the Eastern District of using the CM/ECF system, which in turn will send notification of such filing (NEF) to all counsel of record. ___/s/________________________ Martin M. Zoltick (VSB No. 30058) mzoltick@rfem.com Rothwell Figg Ernst & Manbeck, P.C. 1425 K St., N.W., Suite 800 Washington, D.C. 20005 Tel: (202) 783-6040 Attorneys for Plaintiff Via Vadis, LLC 04194.51872/4173449.1 3

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