`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
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`REALTIME ADAPTIVE STREAMING LLC
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`POLYCOM, INC.,
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`Plaintiff,
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`v.
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`Defendant.
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` Case: 1:17-cv-02692-RBJ
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`JURY TRIAL DEMANDED
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`)))))))))
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`DEFENDANT POLYCOM’S THIRD UNOPPOSED MOTION FOR EXTENSION OF
`TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S ORIGINAL
`COMPLAINT
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`Defendant Polycom, Inc. (“Polycom”), by and through its undersigned counsel,
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`respectfully moves for a third unopposed extension of time in which to respond to Plaintiff
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`Realtime Adaptive Streaming, LLC’s (“Realtime”) Complaint, up to and including March 2, 2018.
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`In support of this Motion, Polycom states
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`1.
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`Realtime filed its Complaint on November 10, 2017. For the purposes of this
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`Motion, Polycom accepts that it was served with the Complaint on December 4, 2017, making
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`its response due on December 26, 2107. [Doc. No. 1]
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`2.
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`On December 21, 2017 Polycom requested and the Court granted an Unopposed
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`Motion for Extension of Time to Answer or Otherwise Respond to Plaintiff’s Original
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`Complaint. [Doc. Nos. 15 and 16 respectively]
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`3.
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`On January 22, 2018 Polycom requested and the Court granted Polycom’s Second
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`Unopposed Motion for Extension of Time to Answer or Otherwise Respond to Plaintiff’s
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`Original Complaint. [Doc. Nos. 22 and 23 respectively]
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`4.
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`On February 5, 2018 Polycom engaged the undersigned counsel to represent it in
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`the instant action.
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`1
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`Case 1:17-cv-02692-RBJ Document 27 Filed 02/08/18 USDC Colorado Page 2 of 4
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`5.
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`Additional time is required to allow the undersigned counsel, who have filed their
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`appearances today, time to review and otherwise become familiar with the case and coordinate
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`a response.
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`6.
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`Pursuant to D.C.COLO.LCivR 7.1(a), on February 7, 2018, Counsel for Polycom
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`conferred with Counsel for Realtime regarding this request. Counsel for Realtime has indicated
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`that it consents to the relief requested, subject to the Court’s approval.
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`7.
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`Therefore, Polycom requests an extension of an additional twenty-one (21) days to
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`respond to the Complaint, up to and including March 2, 2018. This is Polycom’s third requested
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`extension of time for its response to Realtime’s Complaint.
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`8.
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`The requested extension of time is not presented for purposes of delay, and it is
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`believed that neither the Court nor Realtime will be prejudiced by the requested extension.
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`9.
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`Pursuant to D.C.COLO.LCivR 6.1(c), counsel for Defendant certifies that a copy
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`of this motion was served on Defendant contemporaneously with the filing of this motion.
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`WHEREFORE, Polycom respectfully requests that the Court grant the requested third
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`extension of time within which Polycom may answer or otherwise respond to Realtime’s
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`Complaint, up to and including March 2, 2018.
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`2
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`Case 1:17-cv-02692-RBJ Document 27 Filed 02/08/18 USDC Colorado Page 3 of 4
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`CERTIFICATE OF CONFERENCE
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`Pursuant to D.C.COLO.LCivR 7.1, the undersigned counsel for Polycom certifies that they
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`have conferred with counsel for Realtime regarding the relief requested in this motion, and counsel
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`for Realtime have notified counsel for Polycom that they do not oppose the relief sought by this
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`motion.
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`Dated: February 8, 2018
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`
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`Respectfully submitted,
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`ERISE IP, P.A.
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`/s/ Kelly R. Hughes
`Kelly R. Hughes
`Abran J. Kean (EOA to be filed)
`Paul R. Hart
`5600 Greenwood Plaza Blvd, Suite. 200
`Greenwood Village, CO 80111
`Phone: 913.777.5600
`Facsimile: 913.777.5601
`Kelly.hughes@eriseip.com
`Abran.kean@eriseip.com
`Paul.hart@eriseip.com
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`Eric A. Buresh (Admission pending)
`7015 College Blvd., Suite. 700
`Overland Park, KS 66211
`Phone: 913.777.5600
`Facsimile: 913.777.5601
`Eric.buresh@eriseip.com
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`Counsel for Defendant Polycom, Inc.
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`3
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`Case 1:17-cv-02692-RBJ Document 27 Filed 02/08/18 USDC Colorado Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on February 8, 2018, I electronically filed a true and correct copy of
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`the foregoing with the Clerk of Court using the Court’s CM/ECF System, which will send
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`electronic notification of such filing to counsel of record.
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`I further certify that a true and correct copy of the foregoing was served upon Defendant
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`Polycom, Inc. by email, pursuant to D.C.COLO.LCivR 6.1(c).
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`
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`/s/ Kelly R. Hughes
`Kelly R. Hughes
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`Counsel for Defendant Polycom, Inc.
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`4
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