Beneficial Innovations, Inc. v. Blockdot, Inc. et al - 30

							Beneficial Innovations, Inc. v. Blockdot, Inc. et al                                                            Doc. 30
                   Case 2:07-cv-00263-TJW-CE           Document 30   Filed 07/31/2007    Page 1 of 3



                                         IN THE UNITED STATES DISTRICT COURT
                                          FOR THE EASTERN DISTRICT OF TEXAS
                                                  MARSHALL DIVISION


               BENEFICIAL INNOVATIONS, INC.,

                                Plaintiff,
                                                              Civil Action No. 2:07-cv-263 (TJW/CE)
                        v.
                                                              JURY TRIAL DEMANDED
               BLOCKDOT, INC., a Texas Corporation;
               CAREERBUILDER, LLC., a Delaware
               corporation; CNET NETWORK, INC., a
               Delaware corporation; DIGG, INC., a
               Delaware corporation; EBAUM'S WORLD,
               INC., a New York corporation; JABEZ
               NETWORKS, INC., a Tennessee corporation;
               THE NEW YORK TIMES COMPANY, a New
               York corporation; THE WASHINGTON POST
               COMPANY; a Delaware Corporation; THE
               WEATHER CHANNEL INTERACTIVE,
               INC., a Georgia corporation,

                                Defendants.


                  DIGG INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH TO
                  ANSWER, MOVE OR OTHERWISE RESPOND TO BENEFICIAL INNOVATION,
                     INC.'S FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT




               LIBA/1818072.1


                                                                                                      Dockets.Justia.com
    Case 2:07-cv-00263-TJW-CE             Document 30        Filed 07/31/2007     Page 2 of 3



         Defendant DIGG, INC., without waiving any defenses or any matters that might be

presented pursuant to Federal Rule of Civil Procedure 12(b) or any other rule or law, files this

unopposed motion for extension of time in which to answer, move, or otherwise respond to

Beneficial Innovation, Inc.'s First Amended Complaint for Patent Infringement and would

respectfully show the Court as follows:

         DIGG, INC. has requested and Plaintiff has agreed to an extension of DIGG’S INC.’s

time to respond in any manner whatsoever including answer, motion or other pleading of any

type to Plaintiff’s Amended Complaint. Specifically, DIGG, INC. requests, and BENEFICIAL

INNOVATIONS, INC. does not oppose, an additional extension of time up to and including

August 31, 2007.

         A proposed Order granting this unopposed motion is attached for the Court’s

convenience.

                                                     Respectfully submitted,



                                                     /s/ D. Stuart Bartow
                                                     Byron W. Cooper
                                                     CA State Bar No. 166578
                                                     BCooper@goodwinprocter.com
                                                     D. Stuart Bartow
                                                     CA State Bar No. 233107
                                                     SBartow@goodwinprocter.com
                                                     GOODWIN PROCTER LLP
                                                     530 Lytton Avenue
                                                     Palo Alto, California 94301
                                                     Tel.: 650.617.3300
                                                     Fax: 650.617.3281

                                                     Attorneys for Defendant
                                                     DIGG, INC., a Delaware corporation


Dated: July 31, 2007


                                                 1
LIBA/1818072.1
    Case 2:07-cv-00263-TJW-CE             Document 30       Filed 07/31/2007       Page 3 of 3



                                 CERTIFICATE OF SERVICE

         This is to certify that all counsel of record who are deemed to have consented to

electronic service are being served with a copy of this document via the Court’s CM/ECF system

per Local Rule CV-5(a)(3) on this 31st day of July, 2007. Any other counsel of record will be

served by first class mail.



                                                       /s/ D. Stuart Bartow
                                                         D. Stuart Bartow




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LIBA/1818072.1