`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`
`
`Civil Action No. 2:12-cv-2829 SHM tmp
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`v.
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`MICROSOFT CORPORATION,
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`Defendant.
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`JOINT MOTION, AND SUPPORTING MEMORANDUM, FOR EXTENSION OF TIME
`TO RESPOND TO THE COMPLAINT AND TO SET DEADLINE FOR INITIAL
`INFRINGEMENT CONTENTIONS
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`
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`COME NOW Plaintiff, B.E. Technology, LLC, and Defendant, Microsoft Corporation,
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`and jointly move the Court as follows: 1) for an extension of time to December 31, 2012 for
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`Microsoft Corporation to file a response to the Complaint for Patent Infringement; and 2) to set
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`the deadline for submission of Initial Infringement Contentions to January 7, 2013.
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`In support of this motion, Microsoft was served on October 10, 2012 (Dkt. No. 14). The
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`patents at issue are quite lengthy and the initial investigation concerning them will take some
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`time. Therefore, additional time is needed to adequately prepare a response. Plaintiff agrees
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`with this request for an extension of time to December 31, 2012, for Microsoft to file a response
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`to the complaint.
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`Additionally, pursuant to Local Patent Rule 3.1, the Initial Infringement Contentions are
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`due within seven days after a responsive pleading is filed. The parties request that January 7,
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`2013 be set as the deadline for submitting Initial Infringement Contentions (seven days after
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` M
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` BET 2355741 v1
`0-0 10/25/2012
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`
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`Case 2:12-cv-02829-SHM-tmp Document 17 Filed 10/26/12 Page 2 of 3 PageID 98
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`December 31, 2012). Defendant agrees with this request to set a January 7, 2013 deadline for the
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`submission of Initial Infringement Contentions.1
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`Dated: October 26, 2012
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`Respectfully submitted,
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`
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`s/ Bradley E. Trammell
`Bradley E. Trammell (TN #13980)
`Adam Baldridge (TN #023488)
`Baker, Donelson, Bearman, Caldwell &
`Berkowitz, P.C.
`165 Madison Avenue, Suite 2000
`Memphis, TN 38103
`Telephone: 901.577.2121
`Email: btrammell@bakerdonelson.com
`
`Of Counsel:
`Kelly C. Hunsaker (CA Bar No. 168307)
`Leeron G. Kalay (CA Bar No. 23359)
`FISH & RICHARDSON P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Telephone: (650) 839-5070
`hunsaker@fr.com
`kalay@fr.com
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`Attorneys for Defendant
`MICROSOFT CORPORATION
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`
`
`s/ Craig Kaufman
`Robert E. Freitas (CA Bar No. 80948)
`Craig R. Kaufman (CA Bar No. 159458)
`FREITAS TSENG & KAUFMAN, LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`Telephone: (605) 593-6300
`Facsimile: (605) 593-6301
`rfreitas@ftklaw.com
`ckaufman@ftklaw.com
`
`Richard M. Carter (TN B.P.R. #7285)
`Adam C. Simpson (TN B.P.R. #24705)
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`1 These extensions/deadlines take into consideration holidays in November and December.
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`M BET 2355741 v1
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`2
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`Case 2:12-cv-02829-SHM-tmp Document 17 Filed 10/26/12 Page 3 of 3 PageID 99
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`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
`asimpson@martintate.com
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`Attorneys for Plaintiff
`B.E. TECHNOLOGY, L.L.C.
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify that on October 26, 2012, 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/ Bradley E. Trammell
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`M BET 2355741 v1
`0-0 10/25/2012
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`3
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