Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Fifth MOTION for Extension of Time to File Answer re {{10}} Amended Complaint by Bumble Trading Inc. Motions referred to Judge Jeffrey C. Manske.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC, Complainant, Civil Action No. 6:18-cv-00080 v. JURY TRIAL BUMBLE TRADING INC., Defendant. DEFENDANT'S FIFTH UNOPPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER AMENDED COMPLAINT Now comes, Defendant Bumble Trading Inc., and respectfully moves this Court to grant Defendant an extension until September 30, 2018 in which to answer or otherwise respond to Plaintiff's Amended Complaint. In support hereof, Defendant shows the Court as follows: 1. The parties' previously agreed to and the Court granted four extensions of time to answer or otherwise respond to Plaintiff's Amended Complaint. Defendant's response to Plaintiff's Amended Complaint is currently due August 31, 2018. 2. The parties have mutually agreed to a further extension to answer until September 30, 2018. 3. Counsel for Defendant conferred with counsel for Plaintiff on August 27, 2018. Counsel for Plaintiff confirmed that Plaintiff does not oppose the motion to extend time to answer or otherwise respond to Plaintiff's Amended Complaint, up to and including September 30, 2018. 4. Defendant makes this request in the interest of judicial economy. This request will not unduly delay these proceedings nor cause Plaintiff any hardship. 1 WHEREFORE, the Defendant moves the Court to allow Defendant until September 30, 2018 to answer or otherwise respond to Plaintiff's Amended Complaint. Dated: August 29, 2018 Respectfully Submitted, /s/ Joseph Drayton Joseph Drayton (Pro Hac Vice) COOLEY LLP 1114 Avenue of the Americas New York, New York 10036-7798 Phone: (212) 479-6000 Facsimile: (212) 479-6275 Email: jdrayton@cooley.com Rose Whelan (Pro Hac Vice) COOLEY LLP 1299 Pennsylvania Ave. NW, Suite 700 Washington, DC 20004 Phone: (202) 842-7800 Fascimile: (202) 842-7899 Email: rwhelan@cooley.com Deron R. Dacus The Dacus Firm, PC 821 ESE Loop 323, Suite 430 Tyler, TX 75701 Tel: (903) 705-1117 Fax: (903) 581-2543 Email: ddacus@dacusfirm.com 2 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 August 29, 2018. /s/ Joseph Dratyon Joseph Drayton 3