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`Case 2:22-cv-00828-CDS-BNW Document 12 Filed 06/16/22 Page 1 of 4Case 2:22-cv-00828-CDS-BNW Document 24 Filed 06/21/22 Page 1 of 4
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`Joseph R. Ganley (5643)
`Piers R. Tueller (14633)
`HUTCHISON & STEFFEN, PLLC
`Peccole Professional Park
`10080 West Alta Drive, Suite 200
`Las Vegas, Nevada 89145
`Telephone: (702) 385-2500
`Facsimile: (702) 385-2086
`jganley@hutchlegal.com
`ptueller@hutchlegal.com
`
`Ed Nelson, III (Pro hac vice forthcoming)
`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, TX 76107
`ed@nelbum.com
`
`Attorney for defendant
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`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
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`
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`ALLEGIANT TRAVEL COMPANY,
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`Plaintiff,
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`v.
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`R2 SOLUTIONS LLC,
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`Defendant.
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`
`
`Case No. 2:22-cv-00828-CDS-BNW
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`UNOPPOSED MOTION TO EXTEND R2
`SOLUTIONS LLC’S TIME
`TO RESPOND TO PLAINTIFF’S
`COMPLAINT
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`(First Request)
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`Defendant R2 Solutions LLC (“Defendant”) brings this unopposed motion to extend the
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`time for it to respond to Plaintiff Allegiant Travel Company’s (“Plaintiff”) Complaint for
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`Declaratory Judgment of Non-Infringement (ECF 1). To this end, Defendant requests, and
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`Plaintiff does not oppose, an extension of thirty (30) days to and including July 16, 2022 to do so.
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`Pursuant to LR IA 6-1, this is the first request to extend the time to respond to Plaintiff’s
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`This request is not made for the purpose of delay. Patent cases are complex. Plaintiff’s
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`Complaint involves seven distinct patents, at least three of which have not been litigated in prior
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`Case 2:22-cv-00828-CDS-BNW Document 12 Filed 06/16/22 Page 2 of 4Case 2:22-cv-00828-CDS-BNW Document 24 Filed 06/21/22 Page 2 of 4
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`patent infringement litigation brought by Plaintiff in the United States District Court for the
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`Eastern District of Texas. As such, there is much for Defendant’s counsel to consider in advance
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`of Defendant’s response.
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`Because patent cases are complex, minimum 30-day extensions like the one requested here
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`are routine. Knowing that additional time would be necessary, Defendant’s counsel approached
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`Plaintiff’s lead counsel about such an extension via email on May 31, 2022. See Exh. A.
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`Plaintiff’s counsel replied that Plaintiff does not oppose a 30-day extension. Id.
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`Complicating this case further is the fact that it is a declaratory judgement action with
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`complex jurisdictional issues and the presence of a mutual non-disclosure agreement, all of which
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`need to be properly investigated and addressed, as necessary or appropriate.
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`Case 2:22-cv-00828-CDS-BNW Document 12 Filed 06/16/22 Page 3 of 4Case 2:22-cv-00828-CDS-BNW Document 24 Filed 06/21/22 Page 3 of 4
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`For the foregoing reasons, Defendant respectfully asks that the Court grant this unopposed
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`motion re-setting Defendant’s deadline to respond to Plaintiff’s complaint to July 16, 2022.
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`Dated this 16th day of June, 2022.
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`HUTCHISON & STEFFEN, PLLC
`
`/s/ Joseph R. Ganley
`______________________________
`Joseph R. Ganley (5643)
`Piers R. Tueller (14633)
`Peccole Professional Park
`10080 West Alta Drive, Suite 200
`Las Vegas, Nevada 89145
`jganley@hutchlegal.com
`ptueller@hutchlegal.com
`
`Ed Nelson, III (Pro hac vice forthcoming)
`Nelson Bumgardner Conroy PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`ed@nelbum.com
`
`Attorneys for defendant
`R2 Solutions LLC
`
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`IT IS SO ORDERED.
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`____________________________________
`UNITED STATES MAGISTRATE JUDGE
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`DATED: June 21, 2022
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`Case 2:22-cv-00828-CDS-BNW Document 12 Filed 06/16/22 Page 4 of 4Case 2:22-cv-00828-CDS-BNW Document 24 Filed 06/21/22 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 16th day of June, 2022, I caused a true and correct copy of the
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`foregoing UNOPPOSED MOTION TO EXTEND R2 SOLUTIONS LLC’S TIME
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`TO RESPOND TO PLAINTIFF’S COMPLAINT to be submitted electronically for filing and
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`service with the United States District Court for the District of Nevada via the Electronic Filing
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`System to the following:
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`Patrick H. Hicks (4632)
`Kelsey E. Stegall (14279)
`LITTLER MENDELSON, P.C.
`3960 Howard Hughes Parkway, #300
`Las Vegas, Nevada 89169
`phicks@littler.com
`kstegall@littler.com
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`and via Email to:
`
`Michael A. Oblon
`JONES DAY
`51 Louisiana Avenue, N.W.
`Washington, D.C. 20001
`moblon@jonesday.com
`
`Keith Davis
`JONES DAY
`2727 North Harwood
`Dallas, Texas 75201
`kbdavis@jonesday.com
`
`H. Albert Liou
`JONES DAY
`717 Texas Avenue, Suite 3300
`Houston, Texas 77002
`aliou@jonesday.com
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`Attorneys for plaintiff
`Allegiant Travel Company
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`/s/ Kaci Chappuis
`____________________________________
`An employee of Hutchison & Steffen, PLLC
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