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    22-01-31 VW Motion For Extension of Time

    Uploaded by

    Florian Mueller
    January 31, 2022 motion for extension of time by Volkswagen to answer or otherwise respond to Acer's patent infringement complaint in the Eastern District of Virginia

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    22-01-31 VW Motion For Extension of Time

    Uploaded by

    Florian Mueller
    5K views3 pages
    January 31, 2022 motion for extension of time by Volkswagen to answer or otherwise respond to Acer's patent infringement complaint in the Eastern District of Virginia

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    22-01-31 VW Motion for Extension of Time

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    January 31, 2022 motion for extension of time by Volkswagen to answer or otherwise respond to Acer's patent infringement complaint in the Eastern District of Virginia

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    5K views3 pages

    22-01-31 VW Motion For Extension of Time

    Uploaded by

    Florian Mueller
    January 31, 2022 motion for extension of time by Volkswagen to answer or otherwise respond to Acer's patent infringement complaint in the Eastern District of Virginia

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
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    The document discusses an unopposed motion for an extension of time for the defendant Volkswagen Group of America to respond to a complaint filed by the plaintiff Acer, Incorporated.

    The case is about a complaint filed by Acer, Incorporated against Volkswagen AG and Volkswagen Group of America, Inc.

    The defendant Volkswagen Group of America is requesting the court to grant an extension of time up to and including March 9th to answer, plead, or otherwise respond to the complaint.

    Case 1:21-cv-01390-PTG-IDD Document 23 Filed 01/31/22 Page 1 of 3 PageID# 88

    IN THE UNITED STATES DISTRICT COURT


    FOR THE EASTERN DISTRICT OF VIRGINIA

    Acer, Inc.,
    C.A. No. 1:21-cv-01390
    Plaintiff,

    v.

    Volkswagen, AG and Volkswagen Group of


    America, Inc.,

    Defendants.

    UNOPPOSED MOTION FOR EXTENSION OF TIME FOR


    DEFENDANT TO RESPOND TO COMPLAINT

    Defendant Volkswagen Group of America, Inc. (“VWGoA”), by counsel and pursuant to

    Fed. R. Civ. P. 6(b)(1) and Local Civil Rule 7(F)(2)(b), files this unopposed motion for an

    extension of time up to and including Wednesday, March 9, to answer, plead, or otherwise

    respond to the Complaint filed by Plaintiff Acer, Incorporated. Defendant states as follows:

    VWGoA’s response to the Complaint is currently due on February 7, 2022. Good cause

    exists for this Court to grant this second extension because the parties are in negotiations to settle

    all matters in controversy between them. VWGoA respectfully requests that this Court grant the

    requested extension to allow the parties to more effectively continue with negotiations and

    finalize an agreement. Counsel for VWGoA has spoken with Plaintiff’s counsel, and Plaintiff

    does not oppose Defendant’s request for an extension of time. This extension does not present a

    risk of prejudice to Acer, Inc. and will preserve the parties’ and the Court’s resources. As no

    other responsive motions are pending before the Court, an extension will not significantly delay

    the proceedings.

    -1-
    Case 1:21-cv-01390-PTG-IDD Document 23 Filed 01/31/22 Page 2 of 3 PageID# 89

    WHEREFORE, Defendant VWGoA respectfully requests that the Court enter the

    attached order granting VWGoA an extension of time through and including March 9, 2022 to

    answer, plead, or otherwise respond to the Complaint.

    Dated: January 31, 2022 Respectfully submitted,

    By: /s/ Daniel E. Yonan

    Daniel E. Yonan (VA Bar No. 46019)


    Michael Specht
    Uma Everett
    Nicholas J. Nowak
    STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C
    1100 New York Avenue NW, Suite 600
    Washington, DC 20005
    (202) 371-2600

    Attorneys for Defendant

    -2-
    Case 1:21-cv-01390-PTG-IDD Document 23 Filed 01/31/22 Page 3 of 3 PageID# 90

    CERTIFICATE OF SERVICE

    I hereby certify that on January 31, 2022, a true and correct copy of the foregoing was

    served using the Court’s CM/ECF system, with electronic notification of such filing to all

    counsel of record.

    /s/ Daniel E. Yonan

    Daniel E. Yonan
    VA Bar No. 46019
    STERNE, KESSLER, GOLDSTEIN & FOX
    P.L.L.C
    1100 New York Avenue NW, Suite 600
    Washington, DC 20005
    (202) 371-2600

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