`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`
`
`B.E. Technology, L.L.C.,
`
`v.
`
`MICROSOFT CORPORATION,
`
`
`
`
`
` Defendant.
`
`
`
`UNOPPOSED MOTION, AND SUPPORTING MEMORANDUM, FOR EXTENSION OF
`TIME FOR MICROSOFT CORPORATION TO SERVE INITIAL
`NON-INFRINGEMENT CONTENTIONS AND THE ACCOMPANYING DOCUMENT
`PRODUCTION PER LOCAL PATENT RULES 3.3 AND 3.4
`
`COMES NOW Defendant, Microsoft Corporation, and files this unopposed motion for an
`
`extension of time for Microsoft Corporation to serve its Initial Non-Infringement Contentions
`
`and the accompanying document production, per Local Patent Rules 3.3 and 3.4, until and
`
`including February 19, 2013.
`
`In support of this motion, B.E. Technology served Initial Infringement Contentions upon
`
`Microsoft on January 7, 2013. B.E. Technology’s contentions are directed at a number of
`
`different products that were not specifically identified in the Complaint. Therefore, additional
`
`time is need for Microsoft to prepare Non-Infringement Contentions and the accompanying
`
`document production, per Local Patent Rules 3.3 and 3.4.
`
`Plaintiff does not oppose Microsoft’s request for an extension of time to serve its L.P.R.
`
`3.3 contentions and L.P.R. 3.4 production on February 19, 2013.1
`
`
`1 This motion is submitted without prejudice to any modifications to the case schedule requested
`in the parties’ Patent Local Rule 2.1(a) Joint Patent Scheduling Conference Notice. (D.I. 29).
`
`
`
`
`
` Plaintiff,
`
` Civil Action No. 2:12-cv-2829 JPM-tmp
`
`
`
`Case 2:12-cv-02829-JPM-tmp Document 35 Filed 01/28/13 Page 2 of 2 PageID 401
`
`Dated: January 28, 2013
`
`
`
`
`
`s/ Bradley E. Trammell
`
`
`
`Respectfully submitted,
`
`By:
`
`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
` abaldridge@bakerdonelson.com
`
`Kelly C. Hunsaker (Pro Hac Vice)
`Leeron G. Kalay (Pro Hac Vice)
`FISH & RICHARDSON P.C.
`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Telephone: (650) 839-5070
`hunsaker@fr.com
`kalay@fr.com
`
`Attorneys for Defendant
`MICROSOFT CORPORATION
`
`
`
`
`
`CERTIFICATE OF CONSULTATION
`
`Pursuant to Local Rule 7.2(a)(1)(B), I hereby certify that on January 25, 2013, Leeron G.
`Kalay, counsel for Defendant Microsoft Corporation, consulted via telephone with counsel for
`Plaintiff B.E. Technology, L.L.C., Craig Kaufman, who informed Mr. Kalay that Plaintiff
`does not oppose this Motion.
`
`s/ Bradley E. Trammell
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that on January 28, 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.
`
`s/ Bradley E. Trammell
`
`
`
`2
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