`ESTTA641327
`ESTTA Tracking number:
`11/26/2014
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`91211259
`Defendant
`MediaNaviCo LLC
`Plaintiff
`Home Box Office, Inc.
`No
`
`Proceeding.
`Applicant
`
`Other Party
`
`Have the parties
`held their discov-
`ery conference
`as required under
`Trademark Rules
`2.120(a)(1) and
`(a)(2)?
`
`Motion for an Extension of Answer or Discovery or Trial Periods With
`
`The Defendant's Time to Answer is currently set to close on 11/26/2014. MediaNaviCo LLC requests that
`such date be extended for 30 days, or until 12/26/2014, and that all subsequent dates be reset accordingly.
`
`Consent
`
`Time to Answer :
`Deadline for Discovery Conference :
`Discovery Opens :
`Initial Disclosures Due :
`Expert Disclosure Due :
`Discovery Closes :
`Plaintiff's Pretrial Disclosures :
`Plaintiff's 30-day Trial Period Ends :
`Defendant's Pretrial Disclosures :
`Defendant's 30-day Trial Period Ends :
`Plaintiff's Rebuttal Disclosures :
`Plaintiff's 15-day Rebuttal Period Ends :
`
`12/26/2014
`01/25/2015
`01/25/2015
`02/24/2015
`06/24/2015
`07/24/2015
`09/07/2015
`10/22/2015
`11/06/2015
`12/21/2015
`01/05/2016
`02/04/2016
`
`The grounds for this request are as follows:
`- Parties are engaged in settlement discussions
`- The Board is advised that the parties have taken no discovery, though settlement has been discussed ex-
`tensively. The parties have continued to negotiate the coexistence agreement, and since the last exten-
`sion request, the parties have discussed the most recent draft agreement internally and between the
`parties. Applicant#s new in-house counsel has required time to become familiar with the opposition, the
`settlement discussions and the draft agreement. A discussion regarding the settlement agreement will be
`conducted by the parties# attorneys shortly. The parties remain optimistic that the agreement will be con-
`cluded in the next few months.
`MediaNaviCo LLC has secured the express consent of all other parties to this proceeding for the extension
`and resetting of dates requested herein.
`MediaNaviCo LLC has provided an e-mail address herewith for itself and for the opposing party so that any
`order on this motion may be issued electronically by the Board.
`
`
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by Facsimile or email (by agreement only) on this date.
`Respectfully submitted,
`/Michelle L. Visser/
`Michelle L. Visser
`tmdocketing@raderfishman.com
`allienicholson@dwt.com
`11/26/2014

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