Intellect Wireless, Inc. v. LG Electronics, Inc. et al

MOTION

N.D. Ill.May 22, 2008

1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS INTELLECT WIRELESS, INC., ) ) Plaintiff, ) ) v. ) Civil Action No. 08-CV-1350 ) ) Judge James F. Holderman MOTOROLA, INC., ) Magistrate Judge Morton Denlow LG ELECTRONICS, INC., and ) SANYO ELECTRIC CO. LTD. ) ) Defendants. ) SANYO ELECTRIC CO., LTD.’S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Defendant Sanyo Electric Co., Ltd. (“Sanyo Electric”), by and through its attorneys, Katten Muchin Rosenman LLP, and pursuant to Federal Rules of Civil Procedure 6(a) and 12(a), moves this Court for an extension of time to respond to Intellect Wireless, Inc.’s (“Plaintiff”) Complaint. In support of its Motion, Sanyo Electric states as follows: 1. On March 6, 2008, Plaintiff filed its Complaint alleging infringement of United States Patent Numbers 7,266,186 and 7,310,416. 2. On May 7, 2008, Sanyo Electric was served with Plaintiff’s Complaint. 3. Pursuant to Federal Rule of Civil Procedure 12(a)(1)(A), Sanyo Electric’s response to Plaintiff’s Complaint is due on May 27, 2008. 4. Counsel for Sanyo Electric contacted counsel for Plaintiff regarding a 30-day extension of time to respond to the Complaint, whereupon counsel for Plaintiff agreed to said 30- day extension. Case 1:08-cv-01350 Document 25 Filed 05/22/2008 Page 1 of 2 2 5. Sanyo Electric’s agreement with Plaintiff should not be construed as a waiver of any other rights or defenses, including, for instance, Sanyo Electric’s right to file counterclaims, affirmative defenses, or to otherwise challenge the validity of the subject patent. WHEREFORE, Sanyo Electric requests that the Court enter an order extending its time for answering Plaintiff’s Amended Complaint to June 26, 2007. DATED: May 22, 2008 __/s/ Michael A. Dorfman____________ Timothy J. Vezeau Michael A. Dorfman Breighanne A. Eggert KATTEN MUCHIN ROSENMAN LLP 525 W. Monroe Street Chicago, Illinois 60661 Telephone: 312-902-5200 Facsimile: 312-902-1061 Attorneys for Sanyo Electric Co., Ltd. Case 1:08-cv-01350 Document 25 Filed 05/22/2008 Page 2 of 2