Intellect Wireless, Inc. v. LG Electronics, Inc. et alMOTIONN.D. Ill.June 23, 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 A SECOND 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 a second 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. Counsel for Sanyo Electric and Plaintiff agreed to a 30-day extension of time for Sanyo Electric to respond to the Complaint. This Court granted the 30-day extension, setting the date for Sanyo Electric’s response as June 26, 2008. See Docket No. 27. 4. Subsequently, Defendant LG Electronics, Inc. (“LG”) requested and was granted a 30-day extension of time to respond to the Complaint, setting the date for LG’s response as August 29, 2008. See Docket Nos. 29 and 33. Case 1:08-cv-01350 Document 34 Filed 06/23/2008 Page 1 of 2 2 5. To conform with LG’s extension, counsel for Sanyo Electric requested an additional extension of time until August 29, 2008, in which to answer Plaintiff’s Complaint or otherwise plead. Counsel for Plaintiff agreed to this extension of time. 6. 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 Complaint to August 29, 2008. DATED: June 23, 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 34 Filed 06/23/2008 Page 2 of 2