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

MOTION

N.D. Ill.June 13, 2008

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION INTELLECT WIRELESS, INC., Plaintiff, v. MOTOROLA, INC., LG ELECTRONICS, INC., and SANYO ELECTRIC CO. LTD. Defendants. ) ) ) ) ) ) ) ) ) ) ) No. 08 CV 1350 AGREED MOTION TO EXTEND TIME FOR DEFENDANT LG ELECTRONICS, INC. TO RESPOND TO THE COMPLAINT Defendant LG Electronics, Inc., pursuant to Fed. R. Civ. P. 6(b)(1), respectfully requests an extension of time to respond to Plaintiff's complaint. In support of its motion, LG states as follows: 1. LG's Intellectual Property Center received Plaintiff’s complaint and summons in Korea through the Hague Convention on June 2, 2008. 2. LG needs until August 30, 2008 to investigate the allegations and provide a meaningful response. 3. Counsel for Plaintiff was contacted about the extension, and has agreed to this request for additional time. 4. LG is based in Korea and during the summer many of LG's executives and employees are difficult to reach. Case 1:08-cv-01350 Document 29 Filed 06/13/2008 Page 1 of 3 5. Defense counsel is flying to Korea to confer with LG the week of June 16th, however, it will take time to contact the relevant personnel and collect the information necessary to properly respond to the complaint. WHEREFORE, Defendant LG Electronics, Inc., respectfully requests that this court extend the time LG has to respond to the complaint until August 30, 2008. Respectfully submitted, LG ELECTRONICS, INC., /s/ Christopher Carmichael Christopher J. Murdoch Christopher W. Carmichael HOLLAND & KNIGHT LLP 131 S. Dearborn St., 30th Flr. Chicago, Illinois 60603 Tel: (312) 263-3600 Fax: (312) 578-6666 christopher.murdoch@hklaw.com christopher.carmichael@hklaw.com - 2 - Case 1:08-cv-01350 Document 29 Filed 06/13/2008 Page 2 of 3 CERTIFICATE OF SERVICE The undersigned hereby certifies that on June 13, 2008, the foregoing Agreed Motion to Extend Time for Defendant LG Electronics, Inc. to Respond to the Complaint was filed with Clerk of the Court using the CM/ECF System, which automatically transmitted a Notice of Electronic Filing to all ECF registrants. /s/Christopher Carmichael _ # 5405906_v1 Case 1:08-cv-01350 Document 29 Filed 06/13/2008 Page 3 of 3