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`ESTTA Tracking number:
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`ESTTA940350
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`Filing date:
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`12/10/2018
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`Proceeding
`
`91241441
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`Party
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`Correspondence
`Address
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`Submission
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`Filer's Name
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`Filer's email
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`Signature
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`Date
`
`Defendant
`Neharia, Inc.
`
`RICHARD GURAK
`ADVITAM IP, LLC
`150 S. WACKER DRIVE, SUITE 2400
`CHICAGO, IL 60606
`RJGdocket@AdvitamIP.com, TValente@AdvitamIP.com
`no phone number provided
`
`Motion to Suspend for Settlement Discussions
`
`Michele S. Katz.
`
`mskdocket@advitamip.com, atokarz@advitamip.com
`
`/Michele S. Katz/
`
`12/10/2018
`
`Attachments
`
`Nehria Consent Extension.pdf(85229 bytes )
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`
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`
`
`APPLE, INC.,
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`Opposer
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`v.
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`NEHARIA, INC.
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`Applicant.
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`) Opposition No. 91241441
`)
`)
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`)
`
`CONSENTED MOTION FOR 30-DAY SUSPENSION
`
`The parties are actively engaged in negotiations for the settlement of this matter. The
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`deadline for the Applicant to answer was December 7, 2018. However, Opposer and Applicant
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`are actively engaged in settlement negotiations and are close to finalizing the Agreement.
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`Applicant, with consent of Opposer, requests that the deadlines in this proceeding, including the
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`deadline to answer, be suspended for thirty days so the parties can finalize the agreement.
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`At the current time, a comprehensive agreement between the parties is mostly approved..
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`Given the parties’ current positions, Applicant expects that the matter will either resolve within
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`the next thirty-days. Upon granting of this motion, the following time period would apply:
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`Current Deadline
`December 7, 2018
`January 6, 2019
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`January 6, 2019
`February 5, 2019
`June 5, 2019
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`Proposed Deadline
`January 6, 2019
`February 5, 2019
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`February 5, 2019
`March 7, 2019
`July 5, 2019
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`Action Due
`Time to Answer
`Deadline for Discovery
`Conference
`Discovery Opens
`Initial Disclosures Due
`Expert Disclosures Due
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`July 5, 2019
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`August 3, 2019
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`Discovery Closes
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`August 19, 2019
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`September 18, 2019
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`October 3, 2019
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`November 2, 2019
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`October 18, 2019
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`November 17, 2019
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`Plaintiff’s Pretrial
`Disclosures Due
`Plaintiff’s 30-Day Trial
`Period Ends
`Defendant’s Pretrial
`Disclosures Due
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`December 2, 2019
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`January 2, 2019
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`December 17, 2019
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`January 16, 2019
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`January 16, 2020
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`February 15, 2020
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`March 16, 2020
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`April 15, 2020
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`April 15, 2020
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`May15, 2020
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`Defendant’s 30-Day Trial
`Period Ends
`Plaintiff’s Rebuttal
`Disclosures Due
`Plaintiff’s 15-day Rebuttal
`Period Ends
`Plaintiff’s Opening Brief
`Due
`Defendant’s Brief Due
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`April 30, 2020
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`May 30, 2020
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`Plaintiff’s Reply Brief Due
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`May 10, 2020
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`June 9, 2020
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`Request for Oral Hearing
`(optional) Due
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`
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`Opposer submits that good cause is shown and respectfully requests that the Board grant
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`this motion. Opposer has secured the express consent of all other parties to this proceeding for
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`the extension and resetting of the date requested herein. Opposer has provided herewith an email
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`address for itself and for the opposing party so that any order on this motion may be issued
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`electronically.
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`Respectfully submitted,
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`By: _/s/ Michele S. Katz____
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`Michele S. Katz
`ADVITAM IP, LLC
`160 N. Wacker Drive
`Chicago, IL 60606
`Tel: (312) 332-7710
`Fax: (312) 332-7701
`Email: mkatz@advitamip.com
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`Attorney for Opposer
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`2
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the foregoing was served
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`upon counsel of record for Opposer, as agreed by electronic mail, on this 10th day of December,
`10, 2018 addressed to:
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`Joseph Petersen
`Two Embarcadero Center
`Suite 1900
`San Francisco, CA 94111
`jpetersen@ktslaw.com, agarcia@ktslaw.com, smanes@ktslaw.com, tmadmin@ktslaw.com
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`/s/ Michele S. Katz
` Michele S. Katz
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