Data Scape Limited v. Dell Technologies, Inc. et al

Western District of Texas, txwd-6:2019-cv-00129

Unopposed MOTION for Extension of Time to File Response/Reply as to [38] MOTION to Dismiss Inequitable Conduct Counterclaim and Strike Inequitable Conduct Affirmative Defense by Dell Inc., Dell Technologies, Inc., EMC Corporation.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, Plaintiff, v. C.A. No. 6:19-cv-00129-ADA DELL TECHNOLOGIES INC., DELL INC., and EMC CORPORATION, Defendants. UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE Defendants Dell Technologies Inc., Dell Inc., and EMC Corporation ("Defendants") file this Unopposed Motion for Extension of Time to File Response to Plaintiff's Motion to Dismiss Inequitable Conduct Counterclaim and Strike Inequitable Conduct Affirmative Defense (Dkt. 38) filed May 13, 2019. Defendants request an extension to file a response up to and including May 28, 2019. Counsel for Defendants conferred with counsel for Plaintiff who stated that Plaintiff does not oppose this request. WHEREFORE, Defendants respectfully request that the Court grant this motion and enter an order extending the time for Defendants to respond to Plaintiff's Motion up to and including May 28, 2019. 1 Dated: May 16, 2019 Respectfully submitted, /s/ Deron R. Dacus Deron R. Dacus Texas Bar No. 790553 THE DACUS FIRM, P.C. 821 ESE Loop 323, Suite 430 Tyler, TX 75701 Telephone: (903) 705-1117 Fax: (903) 581-2543 ddacus@dacusfirm.com Cynthia D. Vreeland Texas Bar No. 20625150 Shirley X. Li Cantin Massachusetts Bar No. 675377 WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Telephone: (617) 526-6000 Fax: (617) 526-5000 Cynthia.Vreeland@wilmerhale.com Shirley.Cantin@wilmerhale.com E. Ross Cohen D.C. Bar No. 1542122 WILMER CUTLER PICKERING HALE AND DORR LLP 1875 Pennsylvania Avenue NW Washington, DC 20006 Telephone: (202) 663-6000 Fax: (202) 663-6363 Ross.Cohen@wilmerhale.com Attorneys for Dell Technologies Inc., Dell Inc., and EMC Corporation 2 CERTIFICATE OF CONFERENCE In accordance with Local Rule CV-7(i), counsel for the parties have conferred and Plaintiff does not oppose this Motion. /s/ Deron R. Dacus Deron R. Dacus CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing document has been served on all counsel of record via the Court's ECF system on May 16, 2019. /s/ Deron R. Dacus Deron R. Dacus 3