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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Plaintiff
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`GESTURE TECHNOLOGY PARTNERS,
`LLC,
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`v.
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`APPLE INC.,
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`Defendant.
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`___________________________________
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`CIVIL ACTION NO: 6:21-cv-00121
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`DEFENDANT APPLE INC.’S UNOPPOSED MOTION TO EXTEND TIME TO
`ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFFS’ COMPLAINT
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`Defendant Apple Inc. (“Apple”) hereby moves the Court for an order extending the time
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`for Apple to answer, move, or otherwise respond to Plaintiff Gesture Technology Partner’s
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`(“Plaintiff”) Complaint (Dkt. 1).
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`The deadline for Apple to answer, move, or otherwise respond to Plaintiffs’ Complaint is
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`currently February 27, 2021. Apple requests an extension of time to answer, move, or otherwise
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`respond to Plaintiff’s Complaint to Monday, March 29, 2021. Plaintiff does not oppose Apple’s
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`request.
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`The request for extension contained in this motion is the first request by Apple for an
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`extension of time to answer, move, or otherwise respond. The request for an extension is not
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`sought for purposes of delay and will not affect any other case deadlines.
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`For these reasons, Apple respectfully requests that the Court extend the deadline for Apple
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`to answer, move, or otherwise respond to Plaintiff’s Complaint to Monday, March 29, 2021.
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`EAST\179530137.1
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`Case 6:21-cv-00121-ADA Document 8 Filed 02/22/21 Page 2 of 3
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`Dated: February 22, 2021
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`Respectfully submitted,
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`/s/ John M. Guaragna
`John M. Guaragna
`Texas Bar No 24043308
`DLA PIPER LLP (US)
`401 Congress Avenue, Suite 2500
`Austin, TX 78701-3799
`Tel: 512.457.7125
`Fax: 512.457.7001
`john.guaragna@dlapiper.com
`
`Michael Jay (pro hac vice to be filed)
`DLA Piper LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`Los Angeles, CA 90067-4704
`
`Catherine Huang (pro hac vice to be filed)
`DLA Piper LLP (US)
`401 B Street, Suite 1700
`San Diego, CA 92101-4297
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`Christopher Deck (pro hac vice to be filed)
`DLA Piper LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110-1447
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`ATTORNEYS FOR DEFENDANT
`APPLE INC.
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that counsel for Defendant, Apple Inc. conferred by e-mail with Plaintiff’s
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`counsel on February 19, 2021. Plaintiff has agreed to Apple’s request for an extension of the time
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`to answer, move, or otherwise respond to Plaintiff’s’ Complaint to Monday, March 29, 2021.
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`/s/ John M. Guaragna
`John M. Guaragna
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`EAST\179530137.1
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`- 2 -
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`Case 6:21-cv-00121-ADA Document 8 Filed 02/22/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 22nd day of February 2021, I electronically filed the foregoing
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`with the Clerk of Court using the CM/ECF system which will send notification of such filing via
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`electronic mail to all counsel of record. Any other counsel of record will be served by first class
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`U.S. mail.
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`/s/ John M. Guaragna
`John M. Guaragna
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`EAST\179530137.1
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`- 3 -
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