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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`7-Eleven, Inc.,
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` Defendant.
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`Civil Action No.
`3:22-cv-02868
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`Jury Trial Demanded
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO
`DEFENDANT’S MOTION TO DISMISS
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`Plaintiff R2 Solutions LLC (“R2” or “Plaintiff”) respectfully requests a seven-day
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`extension of time to file a response to Defendant’s Motion to Dismiss. ECF 11. Currently,
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`Plaintiff’s Response to the Motion to Dismiss is due March 10, 2023. Plaintiff requests an
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`extension up to and through March 17, 2023, to file its response.
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`Good cause exists for the requested extension. The patents at issue in Defendant’s Motion
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`to Dismiss overlap significantly with the patents at issue in another motion to dismiss in a
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`parallel litigation. See R2 Solutions LLC v. Southwest Airlines Co., Civil Action No. 3:22-cv-
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`02869, ECF 14 (N.D. Tex. Feb. 21, 2023). Plaintiff is also filing an unopposed request for
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`extension of time in that case to extend the response deadline to March 17, 2023. Plaintiff
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`believes that aligning the response deadlines is efficient because there is extensive overlap
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`between the motions. Counsel for Plaintiff also seeks the requested extensions because of
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`scheduling conflicts in other cases and limited availability of counsel because of a pre-planned
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`family vacation.
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`Counsel for Plaintiff has conferred with counsel for Defendant, and Defendant is not
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`Case 3:22-cv-02868-S Document 18 Filed 03/07/23 Page 2 of 3 PageID 332
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`opposed to the extension of time sought in this motion.
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`Dated: March 7, 2023
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`Respectfully submitted,
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`/s/ Carder W. Brooks
`EDWARD R. NELSON III
`State Bar No. 00797142
`ed@nelbum.com
`BRENT N. BUMGARDNER
`State Bar No. 00795272
`brent@nelbum.com
`CHRISTOPHER G. GRANAGHAN
`State Bar No. 24078585
`chris@nelbum.com
`JOHN P. MURPHY
`State Bar No. 24056024
`murphy@nelbum.com
`CARDER W. BROOKS
`State Bar No. 24105536
`carder@nelbum.com
`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
`Fort Worth, Texas 76107
`817.377.9111
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`COUNSEL FOR PLAINTIFF
`R2 SOLUTIONS LLC
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the above and foregoing document has been
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`served on all counsel of record via the Court’s ECF system on March 7, 2023.
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`/s/ Carder W. Brooks
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`2
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`Case 3:22-cv-02868-S Document 18 Filed 03/07/23 Page 3 of 3 PageID 333
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that Counsel for Plaintiff and Counsel for Defendant have complied with
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`the meet and confer requirement in Local Rule 7.1. Defendant is unopposed to the relief sought
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`herein.
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`/s/ Carder W. Brooks
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