`
`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
`
`
`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
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`
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`
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`THE UNITED STATES,
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`
`
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`Plaintiffs,
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`
`
`v.
`
`
`
`Defendant.
`
`
`
`
`
`
`
`
`
`No. 19-859 C
`
`Judge Ryan T. Holte
`
`
`UNOPPOSED MOTION TO FILE SECOND AMENDED COMPLAINT
`PURSUANT TO COURT OF FEDERAL CLAIMS RULE 15(a)(2)
`
`
`
`Plaintiffs e-Numerate Solutions, Inc. and e-Numerate, LLC (collectively “e-Numerate”)
`
`hereby file this unopposed motion to file the hereto attached Second Amended Complaint. In
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`support of this motion, e-Numerate states as follows:
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`WHEREAS the Amended Complaint asserts infringement of seven (7) United States
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`Patents;
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`WHEREAS e-Numerate wishes to assert United States Patent 10,423,708 against the
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`United States and third parties to this litigation;
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`WHEREAS e-Numerate wishes to amend the present counts to assert infringement of
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`previously asserted patents against both additional government agencies and third parties;
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`WHEREAS there is no Scheduling Order in this matter setting forth a date by which
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`amendments to the pleadings should be made;
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`WHEREAS CFC Rule 15(a)(2) specifies that the Court should freely give leave to amend
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`when justice so requires; and
`
`
`
`1
`
`
`
`Case 1:19-cv-00859-RTH Document 50 Filed 04/23/21 Page 2 of 2
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`WHEREAS e-Numerate conferred with the Government about this request and the
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`Government does not oppose the relief sought.
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`WHEREFORE e-Numerate respectfully requests that the Court grant e-Numerate
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`permission to file the hereto attached Second Amended Complaint.
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`
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`Dated: April 23, 2021
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`
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`
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`Respectfully submitted,
`
`O’KELLY & ERNST, LLC
`
`/s/Sean T. O’Kelly
`Sean T. O’Kelly
`824 N. Market Street, Suite 1001A
`Wilmington, Delaware 19801
`(302) 778-4000
`(302) 295-2873 (facsimile)
`sokelly@oelegal.com
`
`and
`
`O’ROURKE LAW OFFICE, LLC
`Gerard M. O'Rourke
`1201 N. Orange Street
`Suite 7260
`Wilmington, DE 19801-1186
`(484) 770-8046
`gorourke@orourkefirm.com
`
`Attorneys for Plaintiffs e-Numerate
`Solutions, Inc. and e-Numerate LLC
`
`
`
`2
`
`
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