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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`FLYPSI, INC. (D/B/A FLYP),
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`Plaintiff,
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`Civil Action No. 6:21-cv-642-ADA
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`vs.
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`DIALPAD, INC.,
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`Defendant.
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`JURY TRIAL DEMANDED
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`FLYP’S UNOPPOSED NOTICE FOR EXTENSION OF TIME
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`Pursuant to the Court’s August 11, 2021, Standing Order Regarding Joint or Unopposed
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`Request to Change Deadlines, Flypsi, Inc. (“Flyp”) files this Unopposed Notice for Extension of
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`Time to regarding Flyp’s Preliminary Infringement Contention deadline and Dialpad’s Preliminary
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`Invalidity Contention deadline.
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`The parties filed their Notice of Readiness on August 20, 2021. By operation of the Court’s
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`standing orders, the Case Management Conference is set for September 3, 2021, and Flyp’s
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`Preliminary Infringement Contentions are presumptively due one-week before the Conference on
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`August 27, 2021. The parties have agreed to a one-week extension of the Preliminary Infringement
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`Contention deadline to September 3, 2021, and a reciprocal one-week extension of the Preliminary
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`Invalidity Contention deadline, which will be set forth in the parties’ Agreed Scheduling Order as
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`November 5, 2021. The requested extensions are agreed and will not change the date for any
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`hearing, any final submission to the Court related to a hearing, or the trial.
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`Case 6:21-cv-00642-ADA Document 17 Filed 08/27/21 Page 2 of 3
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`Accordingly, Flyp requests that the Court extend and set the deadline for Flyp’s
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`Preliminary Infringement Contentions to September 3, 2021, and Dialpad’s Preliminary Invalidity
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`Respectfully submitted,
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`/s/ Michael A. Bittner
`Thomas M. Melsheimer
`Texas Bar No. 13922550
`tmelsheimer@winston.com
`M. Brett Johnson
`Texas Bar No. 00790975
`mbjohnson@winston.com
`Michael A. Bittner
`Texas Bar No. 24064905
`mbittner@winston.com
`Chad Walker
`Texas Bar No. 24056484
`cbwalker@winston.com
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`WINSTON & STRAWN LLP
`2121 North Pearl Street, Suite 900
`Dallas, TX 75201
`Telephone: (214) 453-6500
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`Matthew R. McCullough
`California Bar No. 301330
`mrmccullough@winston.com
`WINSTON & STRAWN LLP
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`Telephone: (650) 858-6500
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`William M. Logan
`Texas Bar No. 24106214
`wlogan@winston.com
`WINSTON & STRAWN LLP
`800 Capitol Street, Suite 2400
`Houston, TX 77002
`Telephone: (713) 651-2766
`ATTORNEYS FOR PLAINTIFF
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`Contention deadline to November 5, 2021.
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`DATED: August 27, 2021
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`Case 6:21-cv-00642-ADA Document 17 Filed 08/27/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that a copy of the foregoing document was filed electronically in
`compliance with Local Rule CV-5. Therefore, this document was served on all counsel who are
`deemed to have consented to electronic service. Administrative Policies and Procedures for
`Electronic Filing in Civil and Criminal Cases, Western District of Texas, Section 14.
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`/s/ Michael A. Bittner
`Michael A. Bittner
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`CERTIFICATE OF CONFERENCE
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`The undersigned hereby certifies that counsel has complied with the meet and confer
`requirements of Local Rule CV-7(g). Counsel for both parties discussed the issues presented here
`via telephone on August 19, 2021, and via email on August 26, 2021. Dialpad indicated that it
`was not opposed to the relief sought herein.
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`/s/ Michael A. Bittner
`Michael A. Bittner
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