1st Technology LLC v. IQ-Ludorum, PLC, et al Doc.

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Case 2:06-cv-00323-LDG-RJJ Document 23 Filed 07/25/2006 Page 1 of 3

1 JOANNA S. KISHNER, ESQ.

State Bar No. 5037
2
joanna.kishner@dlapiper.com
3 PAUL T. TRIMMER, ESQ.
State Bar No. 9291
4 paul.trimmer@dlapiper.com
DLA PIPER RUDNICK GRAY CARY US LLP
5 3960 Howard Hughes Parkway
6 Suite 400
Las Vegas, Nevada 89109
7 (702) 737-3433

8 Attorneys for Defendant

IQ-LUDORUM PLC
9

10 UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
11
1ST TECHNOLOGY LLC, )
12 )
13 Plaintiff, )
)
14 v. ) Case No.: 2:06-cv-00323-LDG-RJJ
)
15 IQ-LUDORUM PLC, PLAYTECH )
CYPRUS LTD., TILTWARE LLC, and )
16
KOLYMA CORPORATION, A.V.V., )
17 )
Defendants. )
18 )
19 STIPULATION AND REQUEST TO EXTEND TIME FOR DEFENDANT IQ-
20 LUDORUM PLC TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
(Third Request)
21
It is hereby requested by Defendant in this case, IQ-Ludorum PLC (hereinafter referred
22
to as "Defendant") through its respective counsel, that Defendant shall have until August 1,
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24 2006, in which to file a Motion to Dismiss, answer, plead or otherwise respond to Plaintiff’s

25 Complaint, with Defendant specially reserving any jurisdictional defenses.

26 1. This is an action for alleged patent infringement.
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2. This is the third request for an extension of time for Defendant to answer, plead
28
or otherwise respond to Plaintiff’s Complaint.

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 Case 2:06-cv-00323-LDG-RJJ Document 23 Filed 07/25/2006 Page 2 of 3

3. Plaintiffs filed a Complaint on March 15, 2006.

1
4. A previous stipulated request for an extension of time for Defendant to answer,
2

3 plead or otherwise respond to Plaintiff’s Complaint set the due date for Defendant’s response

4 as July 25, 2006.

5 5. An additional extension is necessary for counsel to continue settlement
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negotiations. The parties have initiated communications in an effort to resolve this matter
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pursuant to settlement and have made good progress in their efforts. In the past few days, the
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parties have exchanged settlement offers that would resolve all of the issues in the case, and
9

10 those offers are under consideration. The requested extension will allow the parties to continue

11 to focus on these discussions.

12 6. Counsel for Defendant spoke with Plaintiff’s counsel who is in agreement with
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the request for an extension until August 1, 2006 for Defendant to answer, plead or otherwise
14
respond to Plaintiff’s Complaint.
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7. This request is made in good faith and not for the purpose of delay.
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17 Dated this 25th day July, 2006.

18 DLA PIPER RUDNICK HUTCHINSON & STEFFEN, LLC

GRAY CARY US LLP
19

20 /s/ Joanna S. Kishner /s/ L. Kristopher Rath

Joanna S. Kishner, Esq. L. Kristopher Rath, Esq.
21 Paul T. Trimmer, Esq. Peccole Professional Park
3960 Howard Hughes Parkway 10080 Alta Drive
22 Suite 400 Suite 200
Las Vegas, Nevada 89109 Las Vegas, Nevada 89145
23
Attorneys for Defendant Attorneys for Plaintiff
24 IQ-Ludorum PLC

25
IT IS SO ORDERED.
26

27
Judge, U.S. District Court
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Dated:

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 Case 2:06-cv-00323-LDG-RJJ Document 23 Filed 07/25/2006 Page 3 of 3

1 CERTIFICATE OF SERVICE
2
Pursuant to Special Order #109, counsel of record registered for the CM/ECF system
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have been served with the foregoing Stipulation and Request to Extend Time for Defendant
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IQ-Ludorum PLC to Answer or Otherwise Respond to Complaint by electronic means. In
5

6 addition, pursuant to Fed. R. Civ. P. 5(b), I hereby certify that the service of the same was

7 made this day by depositing a true copy of the same for mailing at Las Vegas, Nevada,

8 addressed to:
9
Michael J. McCue, Esq.
10 Lewis & Roca
3993 Howard Hughes Parkway
11 Suite 600
Las Vegas, Nevada 89109
12

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this 25th day of July, 2006.
14

15 /s/ Paul Trimmer

An Employee Of DLA Piper Rudnick
16
Gray Cary US LLP
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