`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`
`
`
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`
`
`CASE NO. 2:22-cv-00198
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`ADIDAS AG; ADIDAS INTERNATIONAL
`MARKETING B.V.; ADIDAS AMERICA, INC.;
`and RUNTASTIC GMBH
`
`
`
`
`v.
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`NIKE, INC.,
`
`Plaintiffs,
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`Defendant.
`
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`DEFENDANT NIKE, INC.’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO
`ANSWER OR OTHERWISE RESPOND TO COMPLAINT
`
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`Defendant Nike, Inc. (“Nike”) hereby moves the Court for an order extending the time for
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`
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`Nike to answer or otherwise respond to adidas AG, adidas International Marketing B.V., adidas
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`America, Inc., and runtastic GmbH’s (collectively, “Plaintiffs”) Complaint for Patent Infringement
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`(Dkt. 1). The deadline for Nike to answer or otherwise respond to Plaintiffs’ Complaint is currently
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`August 5, 2022. Nike requests a 21-day extension of time to further investigate and prepare a
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`response to the Complaint, which would reset Nike’s time to answer or otherwise respond to
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`Plaintiffs’ Complaint to August 26, 2022. Plaintiffs do not oppose Nike’s request, the request is
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`not sought for purposes of delay, and the request will not affect any other case deadlines.
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`Therefore, Nike respectfully requests that the Court extend the deadline for Nike to answer or
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`otherwise respond to Plaintiffs’ Complaint to August 26, 2022.
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`WEST\299559654.1
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`
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`Case 2:22-cv-00198-JRG Document 26 Filed 08/03/22 Page 2 of 3 PageID #: 748
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`
`
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`Dated: August 3, 2022
`
` Respectfully submitted,
`
`By: /s/ G. Blake Thompson
`G. Blake Thompson
`State Bar No. 24042033
`Blake@TheMannFirm.com
`J. Mark Mann
`State Bar No. 12926150
`Mark@TheMannFirm.com
`MANN | TINDEL | THOMPSON
`201 East Howard
`Henderson, Texas 75654
`(903) 657-8540
`(903) 657-6003 (fax)
`
`Richard Mulloy (to be admitted pro hac vice)
`richard.mulloy@us.dlapiper.com
`Edward H. Sikorski (to be admitted pro hac vice)
`ed.sikorski@us.dlapiper.com
`Tiffany Miller (to be admitted pro hac vice)
`tiffany.miller@us.dlapiper.com
`Peter P. Maggiore (to be admitted pro hac vice)
`peter.maggiore@us.dlapiper.com
`Catherine Huang (to be admitted pro hac vice)
`catherine.huang@us.dlapiper.com
`DLA Piper LLP (US)
`401 B Street, Suite 1700
`San Diego, California 92101
`Phone: 619.699.2700
`
`John M. Guaragna
`john.guaragna@us.dlapiper.com
`Texas Bar No. 24043308
`DLA Piper LLP (US)
`303 Colorado St., Suite 3000
`Austin, Texas 78701
`Phone: 512.457.7000
`
`ATTORNEYS FOR DEFENDANT NIKE, INC.
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`- 2 -
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`WEST\299559654.1
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`Case 2:22-cv-00198-JRG Document 26 Filed 08/03/22 Page 3 of 3 PageID #: 749
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`
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing document was filed electronically on August 3, 2022, pursuant
`
`to Local Rule CV-5(c) and has been served on all counsel whom have consented to electronic
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`service via electronic mail. Any other counsel of record will be served by first class U.S. mail on
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`this same date.
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`
` /s/ G. Blake Thompson
`G. Blake Thompson
`
`
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`
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`CERTIFICATE OF CONFERENCE
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`Pursuant to Local Rule CV-7(i), counsel for Nike and counsel for adidas have complied
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`with the meet and confer requirement in Local Rule CV-7(h) in a good-faith effort to resolve the
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`matter presented herein. Counsel for adidas does not oppose the instant Motion.
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` /s/ G. Blake Thompson
`G. Blake Thompson
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`WEST\299559654.1
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`- 3 -
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