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

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

LETTER MOTION for Leave to File Excess Pages and Exhibits for Defendants' Responsive Claim Construction Brief addressed to Judge Richard J. Sullivan from Marshall Beil (on behalf of all Defendants) dated August 3, 2015. Document filed by Apple, Inc.

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McGuire Woods LLP 1345 Avenue of the Americas Seventh Floor New York, NY 10105-0106 Phone: 212.548.2100 Fax: 212.548.2150 www.mcguirewoods.com Marshall Bej] Direct: 212.548.7004 Direct: 212.548.7004 | MCGUIREWOODS mbeil@mcguirewoods.com August 3, 2015 Via ECF and Email (sullivannysdchambers@uysd.uscourts.gov) Honorable Richard J. Sullivan United States District Judge Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 IXI Mobile (R&D) Ltd., et al. v. BlackBerry Ltd., et al., 14-cv-4428 (RJS) IXI Mobile (R&D) Ltd., et al., v. Apple Inc., 14-cv-7954 (RJS) IXI Mobile (R&D) Ltd., et al., v. Samsung Elecs. Co., Ltd., 14-cv-4355 (RJS) Dear Judge Sullivan: I write on behalf of Defendants Apple, Blackberry, and Samsung in the above captioned matters. Your Honor previously granted an unopposed request by IXI for 5 additional pages for IXI's Opening Claim Construction Brief and 5 additional pages for IXI's supporting expert declaration. Defendants' Responsive Claim Construction Brief is due on August 7, 2015. Defendants request a similar increase of 5 pages for each of their claim construction briefs and supporting expert declarations, respectively (in addition to the default 25 pages for the brief and 10 pages for the declaration). Defendants also request an additional five exhibits in addition to the default limit of 15. Good cause exists for these additional pages and exhibits in order for defendants to respond to opening submissions from IXI of the same size and to address the 11 disputed claim terms. As stated in IXI's previous letter regarding its requested extension, IXI does not oppose this request for additional pages. IXI similarly does not oppose the Defendants' request for five additional exhibits. Thank you for your consideration. Respectfully submitted, Wastill Marshall Beil For BlackBerry and on behalf of all Defendants cc: All Counsel Atlanta Austin Baltimore Brussels Charlotte Charlottesville Chicago Dallas Houston jacksonville (London Los Angeles - Century City Los Angeles - Downtown New York Norfolk | Pittsburgh | Raleigh Richmond | Tysons Corner Washington, D.C. | Wilmington