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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`______________________________________________________________________________
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff/Counter-Defendant,
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`No. 2:12-cv-02781-JPM-cgc
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`JURY DEMAND
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`v.
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`GROUPON, INC.,
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`Defendant/Counterclaimant.
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`______________________________________________________________________________
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`UNOPPOSED MOTION OF PLAINTIFF B.E. TECHNOLOGY, LLC
`FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT GROUPON’S
`MOTION TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a)
`______________________________________________________________________________
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`Comes now Plaintiff B.E. Technology, LLC (“B.E. Technology”), by and through the
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`undersigned counsel, and files its Unopposed Motion for Extension of Time to Respond to the
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`Motion to Transfer Venue Pursuant to 28 U.S.C. 1404(a) filed by Defendant Groupon, Inc.
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`(“Groupon”) at D.E. 21. In support of its Unopposed Motion, B.E. Technology requests an
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`additional three (3) days, through and including Thursday, January 31, 2013, in which time to
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`respond in opposition to Groupon’s Motion to Transfer Venue. B.E. Technology requests this
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`additional three days in order to give it and its counsel time to adequately finalize its response to
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`Groupon’s Motion. As B.E. Technology’s Motion for Extension is unopposed by Groupon and
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`good cause exists for the extension, B.E. Technology requests that the Court allow it an
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`additional three days, through and including Thursday, January 31, 2013, in which time to
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`respond in opposition to Groupon’s motion.
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`Case 2:12-cv-02781-JPM-cgc Document 25 Filed 01/28/13 Page 2 of 3 PageID 178
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`LOCAL RULE 7.2 CERTIFICATE OF CONSULTATION
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`On January 28, 2013, Richard M. Carter, Esq., counsel for B.E. Technology, contacted
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`John Golwen, Esq., counsel for Groupon, via electronic mail regarding the requested extension.
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`Mr. Golwen responded by electronic mail that Groupon would not oppose the request.
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`Respectfully submitted,
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`s/ Adam C. Simpson
`Richard M. Carter (TN B.P.R. #7285)
`Adam C. Simpson (TN B.P.R. #24705)
`MARTIN, TATE, MORROW & MARSTON, P.C.
`6410 Poplar Avenue, Suite 1000
`Memphis, TN 38119-4839
`Telephone: (901) 522-9000
`Facsimile: (901) 527-3746
`rcarter@martintate.com
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`Robert E. Freitas (CA Bar No. 80948)
`Craig R. Kaufman (CA Bar No. 15945)
`James Lin (CA Bar No. 241472)
`Qudus B. Olaniran (CA Bar No. 267838)
`Daniel J. Weinberg (CA Bar No. 227159)
`FREITAS TSENG & KAUFMAN LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`Telephone: (650) 593-6300
`Facsimile: (650) 593-6301
`rfreitas@ftklaw.com
`ckaufman@ftklaw.com
`jlin@ftklaw.com
`qolaniran@ftklaw.com
`dweinberg@ftklaw.com
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`Attorneys for B. E. Technology, L.L.C.
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`2
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`Case 2:12-cv-02781-JPM-cgc Document 25 Filed 01/28/13 Page 3 of 3 PageID 179
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`CERTIFICATE OF SERVICE
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`I hereby certify that on January 28, 2013, a true and correct copy of the foregoing
`document was electronically filed with the United States District Court for the Western District
`of Tennessee, and was served on all counsel by the Court's electronic filing notification or via
`email.
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`s/ Adam C. Simpson
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`3
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