`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`
`B.E. TECHNOLOGY, LLC,
`
`
`Plaintiff,
`
`
`
`Civil Action No. 2:12-cv-02772-JPM-tmp
`
`JURY DEMAND
`
`)))))))))))
`
`
`LINKEDIN CORPORATION
`
`
`v.
`
`Defendant.
`
`
`
`
`
`
`DEFENDANT LINKEDIN CORPORATION’S MOTION TO STAY
`PROCEEDINGS PENDING RESOLUTION OF ITS MOTION TO
`TRANSFER VENUE (WITH CERTIFICATE OF CONSULTATION)
`Defendant LinkedIn Corporation respectfully moves this Court to stay all proceedings in
`
`this case, including proceedings called for in the Local Patent Rules, pending resolution of
`
`LinkedIn Corporation’s motion to transfer this case to the Northern District of California, pursu-
`
`ant to 28 U.S.C. § 1404(a). The facts and legal authorities supporting this relief are set forth in
`
`the accompanying memorandum. As set forth in the Certificate of Consultation below, plaintiff
`
`has advised that while it cannot consent to this motion, it “will not actively oppose” it.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`s/Glen G. Reid, Jr.
`Glen G. Reid, Jr. (#8184)
`WYATT, TARRANT & COMBS, LLP
`1715 Aaron Brenner Dr., Suite 800
`Memphis, TN 38120-4367
`Phone: 901.537.1000
`Facsimile: 901.537.1010
`greid@wyattfirm.com
`
`
`s/Mark Vorder-Bruegge, Jr.
`Mark Vorder-Bruegge, Jr. (#06389)
`WYATT, TARRANT & COMBS, LLP
`1715 Aaron Brenner Dr., Suite 800
`Memphis, TN 38120-4367
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case 2:12-cv-02772-JPM-tmp Document 37 Filed 02/11/13 Page 2 of 3 PageID 347
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Phone: 901.537.1000
`Facsimile: 901.537.1010
`mvorder-bruegge@wyattfirm.com
`
`-and-
`
`J. David Hadden
`Darren F. Donnelly
`Saina S. Shamilov
`Ryan J. Marton
`Clifford Webb
`Justin G. Hulse
`FENWICK & WEST LLP
`801 California Street, 6th Floor
`Mountain View, CA 94041
`Phone: 650.988-8500
`Facsimile: 650.938.5200
`dhadden@fenwick.com
`ddonnelly@fenwick.com
`sshamilov@fenwick.com
`rmarton@fenwick.com
`cwebb@fenwick.com
`jhulse@fenwick.com
`
`Attorneys for Defendant
`LINKEDIN CORP.
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF CONSULTATION
`
`The undersigned attorney hereby certifies that prior to the filing of the foregoing motion,
`
`substantive consultation was held between the undersigned and Richard Carter, counsel for
`
`plaintiff B.E. Technology, over multiple days culminating in a telephone discussion on February
`
`7, 2013. At that time, B.E. Technology indicated that it would continue to oppose stay motions
`
`of the foregoing type in this and related cases. On the next afternoon, the Court granted several
`
`virtually identical motions for stay in related cases, and the undersigned re-contacted Mr. Carter
`
`to determine whether plaintiff would reconsider. At 3:16 p.m. on this date, February 11, Mr.
`
`-2-
`
`
`
`Case 2:12-cv-02772-JPM-tmp Document 37 Filed 02/11/13 Page 3 of 3 PageID 348
`
`
`Carter advised that in light of the Court’s rulings on the other stay motions, plaintiff cannot con-
`
`sent to but “will not actively oppose” this stay motion.
`
`
`
`
`
`s/Mark Vorder-Bruegge, Jr.
`Mark Vorder-Bruegge, Jr.
`
`
`
`CERTIFICATE OF SERVICE
`
`The foregoing document was filed under the Court’s CM/ECF system, automatically ef-
`
`fecting service on counsel of record for all other parties who have appeared in this action on the
`
`date of such service.
`
`60323896.1
`
`s/Mark Vorder-Bruegge, Jr.
`Mark Vorder-Bruegge, Jr.
`
`
`
`
`
`
`-3-
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
