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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
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`Civil Action No. 1:17-cv-02692
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`REALTIME ADAPTIVE STREAMING LLC,
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`v.
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`POLYCOM, INC.,
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`Plaintiff,
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`Defendant.
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`DEFENDANT POLYCOM’S SECOND UNOPPOSED MOTION
`FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND
`TO PLAINTIFF’S ORIGINAL COMPLAINT
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`Defendant Polycom, by and through undersigned counsel, requests the Court
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`grant a fifteen (15) day extension of time to answer and/or otherwise respond to Plaintiff’s
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`Original Complaint. This is Polycom’s second request for an extension.
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`Plaintiff’s Original Complaint was filed on November 10, 2017. Doc. 1. Polycom
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`was served on December 4, 2017, making Polycom’s answer or response originally due
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`on December 26, 2017. Doc. 14. On December 22, 2017, the Court granted Polycom’s
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`unopposed request for an extension of its deadline to answer or respond by thirty (30)
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`days, until January 25, 2018. Doc. 16. Polycom requested Plaintiff grant Polycom an
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`additional fifteen (15) day extension, until February 9, 2018, to which Plaintiff has agreed.
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`Polycom requests this second extension of time to provide further time to
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`investigate the facts and allegations in the Complaint, to finalize its selection of litigation
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`counsel, and to allow its selected counsel to review the issues and prepare a response.
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`1
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`Case 1:17-cv-02692-RBJ Document 22 Filed 01/22/18 USDC Colorado Page 2 of 3
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`Polycom does not seek this extension for any improper purpose, and no prejudice will
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`arise from the extension.
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`Pursuant to D.C.COLO.LCivR 6.1(E), undersigned counsel certifies that a copy of
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`this Motion will be served on undersigned’s client.
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`Wherefore, Polycom respectfully moves that the Court enter an order extending
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`the deadline to file an answer or otherwise respond to Plaintiff’s Original Complaint, for
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`fifteen (15) days, through and including February 9, 2018.
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`DATED:
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`January 22, 2018
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`Respectfully submitted,
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`/s/ James H. Hall
`James H. Hall
`Blank Rome LLP
`717 Texas Avenue, Suite 1400
`Houston, Texas 77002
`Telephone: (713) 228-6601
`Fax: (713) 228-6605
`JHall@BlankRome.com
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`ATTORNEY FOR DEFENDANT
`POLYCOM, INC.
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`2
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`Case 1:17-cv-02692-RBJ Document 22 Filed 01/22/18 USDC Colorado Page 3 of 3
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that Defendant’s counsel conferred with counsel for Plaintiff
`regarding the relief requested in this motion via e-mail. Plaintiff’s counsel agreed to the
`requested relief and is unopposed to this motion.
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`/s/ James H. Hall
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`CERTIFICATE OF SERVICE
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`I hereby certify that on January 22, 2018, I electronically filed the foregoing with
`the Clerk of the Court by using the Court’s CM/ECF electronic filing system, which will
`send notification of such filing to the following e-mail addresses.
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`Brian David Ledahl (bledahl@raklaw.com)
`Jay Young Chung (jchung@raklaw.com)
`Marc Aaron Fenster (mafenster@raklaw.com)
`Reza Mirzaie (rmirzaie@raklaw.com)
`Timothy T. Hsieh (thsieh@raklaw.com)
`Eric Bryan Fenster (eric@fensterlaw.net)
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`/s/ Lynn Marlin
`Lynn Marlin
`Blank Rome LLP
`717 Texas Avenue, Suite 1400
`Houston, Texas 77002
`Telephone: (713) 228-6601
`Fax: (713) 228-6605
`Email: LMarlin@BlankRome.com
`Paralegal for Defendant Polycom, Inc.
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`3
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