Ixi Mobile (R&D) Ltd. et al v. Apple, Inc.

Northern District of California, cand-4:2015-cv-03755

LETTER MOTION for Extension of Time to File Answer re: 1 Complaint, addressed to Judge Richard J. Sullivan from Greg Chuebon dated October 22, 2014. Document filed by Apple, Inc.

Interested in this case?

Current View

Full Text

SIMPSON THACHER & BARTLETT LLP 425 LEXINGTON AVENUE NEW YORK, NY 10017-3954 (212) 455-2000 FACSIMILE (212) 455-2502 DIRECT DIAL NUMBER E-MAIL ADDRESS (212) 455-3353 gchuebon@stblaw.com VIA ECF AND EMAIL (sullivannysdchambers@nysd.uscourts.gov) October 22, 2014 Re: IXI Mobile (R&D) Ltd. v. Apple Inc., 14-cv-7954 (RJS) (DCF) Honorable Richard J. Sullivan United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Dear Judge Sullivan: Simpson Thacher & Bartlett LLP will be representing defendant Apple Inc. ("Apple") in the above-referenced case. I write pursuant to Rule l.D of Your Honor's Individual Rules to request a 31-day extension of Apple's time to respond to the complaint, from October 24 to November 24, 2014. The parties have not previously requested an extension of this deadline. We understand that there are two possibly related cases currently pending before Your Honor, those of IXI Mobile (R&D) Ltd. v. Blackberry Ltd., 14-cv-4428 (RJS) (DCF) (the "Blackberry Litigation") and IXI Mobile (R&D) Ltd. v. Samsung Electronics Co., Ltd., 14-cv-4355 (RJS) (DCF) (the "Samsung Litigation"). We also understand that in those cases Your Honor ordered the parties "to confer with counsel for the defendant in the newly-filed related case and to submit a revised case management plan and joint letter no later than" November 7, 2014. Apple will coordinate with the parties in the Blackberry Litigation and Samsung Litigation to provide input on their case management plan and joint letter requested by the Court on November 7, 2014. Plaintiffs' counsel has graciously informed me that they have no objection to this request for an extension. Respectfully submitted, /s/ Greg Chuebon Greg Chuebon BEIJING HONG KONG HOUSTON LONDON LOS ANGELES PALO ALTO S ÃO P A U L O SEOUL TOKYO WASHINGTON, D.C. SIMPSON THACHER & BARTLETT LLP Honorable Richard J. Sullivan -2- October 22, 2014 cc: Thomas Steven Biemer, Esq. Gregory A. Blue, Esq. Joshua D. Wolson, Esq. John J. Higson, Esq.