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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 regarding Flyp’s Deadline to Answer or Otherwise Respond to Dialpad, Inc.’s (“Dialpad”)
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`Counterclaims filed on January 18, 2022 (Dkt. No. 34).
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`It is unclear whether the Rule 12 or Rule 15 deadline to respond applies here due to the fact
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`that Dialpad introduced new counterclaims in its recent pleading. Out of an abundance of caution,
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`counsel for Flyp conferred with counsel for Dialpad via telephone on January 27, 2022. The parties
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`agreed that a 21-day deadline could apply here such that Flyp’s deadline to answer or otherwise
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`respond to would be due by agreement on February 8, 2022.
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`Accordingly, Flyp requests that the Court set or extend Flyp’s Deadline to Answer or
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`Otherwise Respond to Dialpad, Inc.’s Counterclaims to February 8, 2022.
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`Case 6:21-cv-00642-ADA Document 36 Filed 01/28/22 Page 2 of 3
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`Respectfully submitted,
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`/s/ Thomas M. Melsheimer
`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
`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
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`ATTORNEYS FOR PLAINTIFF
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`DATED: January 28, 2022
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`Case 6:21-cv-00642-ADA Document 36 Filed 01/28/22 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 January 27, 2022. 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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