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Case 2:14-cv-00061-JRG-RSP Document 12 Filed 02/17/14 Page 1 of 3 PageID #: 405
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Civil Action No. 2:14-CV-0061
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`JURY TRIAL DEMANDED
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`CONTENTGUARD HOLDINGS, INC.,
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` Plaintiff,
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`v.
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`GOOGLE INC.,
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` Defendant.
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`DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION
`OF TIME TO FILE RESPONSE TO PLAINTIFF’S ORIGINAL COMPLAINT
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`TO THE HONORABLE COURT:
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`Defendant Google Inc., files this Unopposed Motion for an Extension of Time to
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`Respond to ContentGuard Holdings, Inc.’s Original Complaint. Counsel for both parties have
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`agreed to extend the answer date to April 11, 2014.
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`Good cause exists for an extension of time to answer since the Court has ordered an
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`answer in another ContentGuard case styled Civil Action No. 2:13-cv-1112 with an answer date
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`of April 11, 2014. It is anticipated that ContentGuard will seek consolidation of this case and
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`Civil Action No. 2:13-cv-1112. The Defendants are likely to oppose such a motion. By allowing
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`both cases to answer on the same date creates judicial economy and allows the parties to evaluate
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`their respective positions.
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`PREMISES CONSIDERED, Defendant Google Inc., requests that the time to answer,
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`move or otherwise respond to Plaintiffs’ Original Complaint be extended up to and including
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`April 11, 2014 and for such other and further relief as the Court deems suitable and just.
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`Motion for Extension of Time
`To Respond to Complaint
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`Page 1 of 3
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`Case 2:14-cv-00061-JRG-RSP Document 12 Filed 02/17/14 Page 2 of 3 PageID #: 406
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`Dated: February 17, 2014
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`Respectfully Submitted:
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`MANN | TINDEL | THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`(903) 657-8540
`(903) 657-6003 (fax)
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`/s/ J. Mark Mann
` By:
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` J. Mark Mann
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` State Bar No. 12926150
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` G. Blake Thompson
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` State Bar No. 24042033
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`ATTORNEYS FOR GOOGLE, INC.
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel has complied with the meet and confer requirement in Local
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`Rule CV-7(h) and this Court’s Orders, and this motion is unopposed. The parties met and
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`conferred on February 17, 2014. The parties were able to agree that the relief sought by this
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`motion should be granted, and agreed that this motion is necessary to resolve the dispute.
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`/s/ J. Mark Mann
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`J. Mark Mann
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`Motion for Extension of Time
`To Respond to Complaint
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`Page 2 of 3
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`Case 2:14-cv-00061-JRG-RSP Document 12 Filed 02/17/14 Page 3 of 3 PageID #: 407
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who have consented to electronic service are
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`being served with a copy of this document via the Court’s CM/ECF system per Local Rule CV-
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`5(a)(3) on this the 17th day of February, 2014.
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`/s/ J. Mark Mann
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`J. Mark Mann
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`Motion for Extension of Time
`To Respond to Complaint
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`Page 3 of 3

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