Match Group, LLC v. Bumble Trading Inc.

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

Unopposed MOTION for Extension of Time to File Answer or Otherwise Respond to Match Group, LLC's Second Amended Complaint by Bumble Trading Inc.

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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC, Plaintiff/Counter-Defendant, Case No.: 6:18-cv-00080-ADA vs. JURY TRIAL DEMANDED BUMBLE TRADING, INC., Defendant/Counter-Plaintiff. DEFENDANT BUMBLE TRADING, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO MATCH GROUP, LLC'S SECOND AMENDED COMPLAINT Defendant Bumble Trading, Inc. ("Bumble") hereby files this Unopposed Motion for Extension of Time to Answer or Otherwise Respond to Plaintiff Match Group, LLC's ("Match") Second Amended Complaint. In accordance with the parties' agreement, Match will soon file a motion for leave to amend its Second Amended Complaint. See No. 6:18-cv-350 at Dkt. No. 68. Given that the new complaint would moot any response to the Second Amended Complaint, Bumble requests an extension to respond to the Second Amended Complaint until after Match's motion is resolved. The parties have met and conferred, and Match is unopposed to the relief requested herein. Bumble therefore respectfully requests that the Court grant this extension of time and that Bumble's response (if any is required) to Match's Second Amended Complaint be due 14 days after Match's motion for leave to amend its Complaint, as contemplated in 18-cv-350 Dkt. 68, is resolved. Dated: March 8, 2019 Respectfully submitted, By: /s/ Matthew D. Caplan Joseph M. Drayton (Pro Hac Vice) NY Bar No. 2875318 COOLEY LLP 1114 Avenue of the Americas New York, NY 10036 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 jdrayton@cooley.com Rose S. Whelan (Pro Hac Vice) DC Bar No. 999367 COOLEY LLP 1299 Pennsylvania Ave., NW Suite 700 Washington, DC 20004 Tel: (202) 842-7800 Fax: (202) 842-7899 rwhelan@cooley.com Michael G. Rhodes (Pro Hac Vice) CA Bar No. 116127 Matthew D. Caplan (Pro Hac Vice) CA Bar No. 260388 COOLEY LLP 101 California Street, 5th Floor San Francisco, CA 94111-5800 Telephone (415) 693-2000 Facsimile: (415) 693-2222 mrhodes@cooley.com mcaplan@cooley.com Deron R Dacus (TX 00790553) THE DACUS FIRM, P.C. 821 ESE Loop 323, Suite 430 Tyler, TX 75701 Telephone: 903-705-1117 Facsimile: 903-581-2543 ddacus@dacusfirm.com Attorneys for Defendant/Counter-Plaintiff: Bumble Trading, Inc. -2- CERTIFICATE OF CONFERENCE On the 6th day of March 2019, the undersigned counsel conferred with opposing counsel concerning the relief sought in this Motion, and was advised that opposing counsel did not oppose this motion. /s/ Matthew D. Caplan Matthew D. Caplan -3- CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically with the Clerk of Court using the CM/ECF system, which will send notification of such filing to all counsel of record on March 8, 2019. /s/ Matthew D. Caplan Matthew D. Caplan 200156748 -4-