Beneficial Innovations, Inc. v. Blockdot, Inc. et al Doc.

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Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION

BENEFICIAL INNOVATIONS, INC.,

Plaintiff,
Civil Action No. 2:07-cv-263 (TJW/CE)
v.
JURY TRIAL DEMANDED
BLOCKDOT, INC., a Texas Corporation;
CAREERBUILDER, LLC., a Delaware
corporation; CNET NETWORK, INC., a
Delaware corporation; DIGG, INC., a
Delaware corporation; EBAUM'S WORLD,
INC., a New York corporation; JABEZ
NETWORKS, INC., a Tennessee corporation;
THE NEW YORK TIMES COMPANY, a New
York corporation; THE WASHINGTON POST
COMPANY; a Delaware Corporation; THE
WEATHER CHANNEL INTERACTIVE,
INC., a Georgia corporation,

Defendants.

DIGG INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO

ANSWER, MOVE OR OTHERWISE RESPOND TO BENEFICIAL INNOVATION,
INC.'S FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT

LIBA/1818072.1

Dockets.Justia.com
 Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 2 of 3

Defendant DIGG, INC., without waiving any defenses or any matters that might be

presented pursuant to Federal Rule of Civil Procedure 12(b) or any other rule or law, files this

unopposed motion for extension of time in which to answer, move, or otherwise respond to

Beneficial Innovation, Inc.'s First Amended Complaint for Patent Infringement and would

respectfully show the Court as follows:

DIGG, INC. has requested and Plaintiff has agreed to an extension of DIGG’S INC.’s

time to respond in any manner whatsoever including answer, motion or other pleading of any

type to Plaintiff’s Amended Complaint. Specifically, DIGG, INC. requests, and BENEFICIAL

INNOVATIONS, INC. does not oppose, an additional extension of time up to and including

August 31, 2007.

A proposed Order granting this unopposed motion is attached for the Court’s

convenience.

Respectfully submitted,

/s/ D. Stuart Bartow

Byron W. Cooper
CA State Bar No. 166578
BCooper@goodwinprocter.com
D. Stuart Bartow
CA State Bar No. 233107
SBartow@goodwinprocter.com
GOODWIN PROCTER LLP
530 Lytton Avenue
Palo Alto, California 94301
Tel.: 650.617.3300
Fax: 650.617.3281

Attorneys for Defendant

DIGG, INC., a Delaware corporation

Dated: July 31, 2007

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LIBA/1818072.1
 Case 2:07-cv-00263-TJW-CE Document 30 Filed 07/31/2007 Page 3 of 3

CERTIFICATE OF SERVICE

This is to certify that all counsel of record who are deemed to have consented to

electronic service are being served with a copy of this document via the Court’s CM/ECF system

per Local Rule CV-5(a)(3) on this 31st day of July, 2007. Any other counsel of record will be

served by first class mail.

/s/ D. Stuart Bartow

D. Stuart Bartow

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LIBA/1818072.1