`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`IRONBURG INVENTIONS LTD.
`
`Plaintiff,
`
`v.
`
`COLLECTIVE MINDS GAMING
`CO. LTD.
`
`Defendant.
`
`Civil Action No. 1:16-cv-04110-TWT
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`DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`ANSWER OR OTHERWISE RESPOND TO THE PLAINTIFF’S
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Defendant Collective Minds Gaming Co. Ltd. (“CMG” or “Defendant”)
`
`hereby submits this unopposed motion moving this Court for an extension of time
`
`within which Defendant must answer, move, or otherwise respond to Plaintiff
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`Ironburg Inventions Ltd.’s (“Ironburg” or “Plaintiff”) Complaint for Patent
`
`Infringement (“Complaint”). A proposed Order is attached to this Motion.
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`In support of its motion, Defendant states as follows:
`
`1.
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`On November 2, 2016, Plaintiff filed its Complaint against Defendant.
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`[Dkt. 1].
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`1
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`IPR2018-00354
`COLLECTIVE EX1016 Page 1
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`
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`Case 1:16-cv-04110-TWT Document 4 Filed 01/18/17 Page 2 of 5
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`2.
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`3.
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`Defendant was served on January 4, 2017.
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`The below counsel of record have recently been retained to appear on
`
`behalf of Defendant in this case.
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`4.
`
`Pursuant to Fed. R. Civ. P. 12(a)(1)(A), Defendant is required to answer
`
`or otherwise respond to Plaintiff’s Complaint by January 25, 2017.
`
`5.
`
`Defendant requires additional time to investigate and prepare an
`
`appropriate response to the Complaint, which accuses Defendant of direct and
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`induced infringement of five different patents.
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`6.
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`The deadline for Defendant to answer or otherwise respond to the
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`Complaint has not previously been extended.
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`7.
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`Defendant respectfully requests an extension of thirty (30) days,
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`moving the deadline for Defendant to answer or otherwise respond to the Complaint
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`to February 24, 2017.
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`8.
`
`Counsel for Plaintiff has indicated that Plaintiff does not oppose
`
`Defendant’s requested extension.
`
`Dated: January 18, 2017
`
`
`Respectfully Submitted,
`
`HILL, KERTSCHER & WHARTON, LLP
`
`
`
`/s/ Steven G. Hill
`Steven G. Hill, GA Bar No. 354658
`Martha L. Decker, GA Bar No. 420867
`3350 Riverwood Parkway, Suite 800
`
`
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`2
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`IPR2018-00354
`COLLECTIVE EX1016 Page 2
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`
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`Case 1:16-cv-04110-TWT Document 4 Filed 01/18/17 Page 3 of 5
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`Atlanta, Georgia 30339
`Telephone: (770) 953-0995
`Facsimile: (770) 953-1358
`Email:
`sgh@hkw-law.com
`
`
`md@hkw-law.com
`
`OF COUNSEL:
`
`ERISE IP, P.A.
`Eric A. Buresh, KS Bar No. 19895
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`Email:
`eric.buresh@eriseip.com
`
`ERISE IP, P.A.
`Paul R. Hart, CO Bar No. 45697
`Michelle A. Callaghan, CO Bar No. 50082
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`Email: paul.hart@eriseip.com
`
` michelle.callaghan@eriseip.com
`
`Attorneys for Defendant Collective Minds
`Gaming Co. Ltd.
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`3
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`IPR2018-00354
`COLLECTIVE EX1016 Page 3
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`Case 1:16-cv-04110-TWT Document 4 Filed 01/18/17 Page 4 of 5
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`CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1D
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`
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`Pursuant to LR 7.1(D), the undersigned counsel certifies that this motion has
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`been prepared using Times New Roman 14-point font, as permitted under LR 5.1(C).
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`Dated: January 18, 2017
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`Respectfully submitted,
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`
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`/s/ Steven G. Hill
`Steven G. Hill
`Georgia Bar No. 354658
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`Attorney for Defendant
`Collective Minds Gaming Co. Ltd.
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`4
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`IPR2018-00354
`COLLECTIVE EX1016 Page 4
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`Case 1:16-cv-04110-TWT Document 4 Filed 01/18/17 Page 5 of 5
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`CERTIFICATE OF SERVICE
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`The undersigned counsel hereby certifies that on January 18, 2017, a true and
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`correct copy of the Defendant’s Unopposed Motion for Extension of Time to
`Answer or Otherwise Respond to the Plaintiff’s Complaint for Patent
`Infringement was filed with the Clerk of Court using the CM/ECF system, which
`will automatically send email notification of such filing to the following attorneys
`of record:
`
`Cynthia R. Parks
`Parks IP Law LLC
`730 Peachtree St. NE, Suite 600
`Atlanta, GA 30308
`T: 678.365.4444
`F: 678.365.4450
`cparks@parksiplaw.com
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`The undersigned counsel further certifies that on January 18, 2017, a copy of
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`the foregoing was sent to the following counsel for Plaintiff via electronic mail:
`
`
`Robert D. Becker
`Manatt, Phelps & Phillips, LLP
`1841 Page Mill Road, Suite 200
`Palo Alto, CA 94304
`T: 650.812.1300
`F: 650.213.0260
`rbecker@manatt.com
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`Dated: January 18, 2017
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`Respectfully submitted,
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`/s/ Steven G. Hill
`Steven G. Hill
`Georgia Bar No. 354658
`
`
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`
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`Attorney for Defendant
`Collective Minds Gaming Co. Ltd.
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`5
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`IPR2018-00354
`COLLECTIVE EX1016 Page 5
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