`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Flypsi, Inc.,
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`v.
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`Dialpad, Inc.,
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`Plaintiff,
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`Defendant.
`
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`Civil Action No. 6:21-cv-00642-ADA
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`Jury Trial Requested
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`UNOPPOSED MOTION FOR EXTENSION OF TIME
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`Defendant Dialpad, Inc. (“Dialpad”) files this Unopposed Motion for Extension of Time
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`to answer, move, or otherwise respond to Plaintiff Flypsi, Inc.’s Original Complaint for Patent
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`Infringement (“Complaint”).
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`Plaintiff filed its Complaint against Dialpad on June 21, 2021. Dialpad was served on June
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`23, 2021. Dialpad currently has a deadline of July 14, 2021 to answer, move, or otherwise respond
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`to the Complaint. The parties met and conferred regarding a short, 30 day extension of Dialpad’s
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`current July 14, 2021 deadline as Dialpad recently retained counsel to represent it in this matter
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`and Plaintiff is unopposed. Dialpad requests that the Court extend the deadline for Dialpad to
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`answer or otherwise respond to the Complaint up to and including August 13,2021. Dialpad does
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`not make this request for the purpose of delay, but so that justice may be efficiently served.
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`Accordingly, Dialpad requests that the Court grant this Motion and extend the time for it
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`to answer, move, or otherwise respond to Plaintiff’s Complaint to August 13, 2021.
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`
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`Case 6:21-cv-00642-ADA Document 12 Filed 07/14/21 Page 2 of 3
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`Date: July 14, 2021
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`Respectfully submitted,
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`
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`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
`Texas Bar No. 24088913
`elizabeth.chiaviello@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1717 Main Street, Suite 3200
`Dallas, Texas 75201-7347
`T. (214) 466-4000
`F. (214) 466-4001
`
`Robert C. Bertin*
`D.C. Bar No. 469582
`robert.bertin@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, D.C. 20004
`Telephone: (202) 739-3000
`Facsimile: (202) 739-3001
`
`*Pro hac vice to be filed
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`Attorneys for Dialpad, Inc.
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`CERTIFICATE OF SERVICE
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`The undersigned counsel hereby certifies that on July 14, 2021, a true and correct copy of
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`the foregoing response was served on all counsel of record who have appeared in this case via the
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`Court’s CM/ECF system per Local Rule CV-5.
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`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
`
`2
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`
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`Case 6:21-cv-00642-ADA Document 12 Filed 07/14/21 Page 3 of 3
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`CERTIFICATE OF CONFERENCE
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`I hereby certify that on July 14 , 2021 counsel for Defendant conferred with Plaintiff’s
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`counsel on this Motion, and Plaintiff’s counsel does not oppose a 30 day extension of Defendant’s
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`current July 14, 2021 deadline to answer, move, or otherwise respond to the Complaint.
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`
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`/s/ Elizabeth M. Chiaviello
`Elizabeth M. Chiaviello
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`3
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