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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`Civil Action No. 2:12cv2769 JPM-tmp
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`Hon. Jon Phipps McCalla
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`JURY DEMAND
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`v.
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`FACEBOOK, INC.,
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`Defendant.
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`JOINT MOTION (INCLUDING MEMORANDUM) OF
`PLAINTIFF B.E. TECHNOLOGY, LLC AND DEFENDANT FACEBOOK, INC. TO
`MODIFY CERTAIN LOCAL PATENT RULE DEADLINES
`AND RESTORE UNIFORMITY TO RELATED CASE SCHEDULES
`(WITH CERTIFICATE OF CONSULTATION)
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`Plaintiff B.E. Technology, LLC (“plaintiff”) and defendant Facebook, Inc. (“defendant”)
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`jointly move the Court to enter the accompanying proposed Order, modifying the deadlines for
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`four events under the Local Patent Rules (LPR’s) in this action.
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`The proposed Order is the same as submitted by plaintiff and defendant Google Inc. with
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`their similar joint motion recently filed on June 19, 2013, as ECF No. 47 in the action B.E.
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`Technology, LLC v. Google Inc., Case Number 2:12-cv-02830-JPM-tmp in this Court (the
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`“Google Action Motion”). Plaintiff and the defendant in this instant action respectfully
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`incorporate by reference and adopt the points and legal authorities cited in the Google Action
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`Motion in support of the same relief herein.
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`CERTIFICATE OF CONSULTATION
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`The foregoing motion is presented by plaintiff and defendant jointly, based on successful
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`consultation compliant with the Court’s Local Rule 7.
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`Case 2:12-cv-02769-JPM-tmp Document 59 Filed 07/17/13 Page 2 of 3 PageID 449
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`Dated: July 17, 2013
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`Respectfully submitted:
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`/s/ Orion Armon
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`Heidi Keefe (CA #178960) (pro hac vice)
`hkeefe@cooley.com
`Mark Weinstein (CA #193043) (pro hac vice)
`mweinstein@cooley.com
`COOLEY LLP
`3175 Hanover Street
`Palo Alto, CA 94304-1130
`Telephone: (650) 843-5000
`Facsimile: (650) 849-7400
`
`Orion Armon (CO # 34923) (pro hac vice)
`oarmon@cooley.com
`Sara Radke CO # 44995) (pro hac vice)
`sradke@cooley.com
`COOLEY LLP
`380 Interlocken Crescent, Suite 900
`Broomfield, CO 80021
`Telephone: (720) 566-4000
`Facsimile: (720) 566-4099
`
`Heather J. Hubbard (TN # 23699)
`Laura P. Merritt (TN # 26482)
`WALLER LANSDEN DORTCH & DAVIS, LLP
`Nashville City Center
`511 Union St., Suite 2700
`Nashville, TN 37219-8966
`615-850-6024
`Fax: 615-244-6804
`heather.hubbard@wallerlaw.com
`laura.merritt@wallerlaw.com
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`Counsel for Defendant Facebook, Inc.
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`2
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`Case 2:12-cv-02769-JPM-tmp Document 59 Filed 07/17/13 Page 3 of 3 PageID 450
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`CERTIFICATE OF SERVICE
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`I hereby certify that a copy of the foregoing has been served this 17 day of July, 2013, on
`the following counsel of record via the Court’s Electronic Filing System:
`
`Craig Robert Kaufman
`Robert Edward Freitas
`Qudus B. Olaniran
`Hsiang Hong Lin
`Daniel J. Weinberg
`FREITAS TSENG & KAUFMAN, LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`650-593-6300
`ckaufman@ftklaw.com
`rfreitas@ftklaw.com
`qolaniran@ftklaw.com
`jlin@ftklaw.com
`dweinberg@ftklaw.com
`
`Adam Calhoun Simpson
`Richard M. Carter
`MARTIN TATE MORROW & MARSTON
`International Place, Tower II
`6410 Poplar Avenue, Suite 1000
`Memphis, TN 38119
`901-522-9000
`asimpson@martintate.com
`rcarter@martintate.com
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` /s/ Orion Armon
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`3
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