`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`PAYRANGE INC.,
`
`Plaintiff,
`
`v.
`
`CARD CONCEPTS INC.,
`
`Defendant.
`
`Civil Action No.: 1:24-cv-00339-OLG
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`JURY TRIAL DEMANDED
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`UNOPPOSED MOTION FOR THIRD EXTENSION OF TIME TO
`RESPOND TO FIRST AMENDED COMPLAINT
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`Plaintiff PayRange Inc. (“PayRange”) files this Unopposed Motion for Third Extension
`
`of Time for Defendant Card Concepts Inc. (“CCI”) to Answer or Otherwise Respond to
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`Plaintiff’s Amended Complaint, showing the Court as follows:
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`1.
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`CCI was served with the Complaint in this matter on September 18, 2024, making
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`the deadline to respond October 9, 2024.
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`2.
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`PayRange filed its Amended Complaint on September 17, 2024, and served CCI
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`by mail on September 23, 2024.
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`3.
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`The parties filed a first motion for a 30-day extension of the deadline for CCI to
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`respond to the Amended Complaint. The Court granted the motion, extending the deadline to
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`Friday, November 8, 2024.
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`4.
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`The parties filed a second motion for a 30-day extension of the deadline for CCI
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`to respond to the Amended Complaint. The Court granted the motion, extending the deadline to
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`Monday, December 9, 2024.
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`
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`Case 6:24-cv-00339-OLG Document 14 Filed 12/06/24 Page 2 of 3
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`5.
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`The parties are currently actively engaged in settlement discussions. The parties
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`therefore seek an additional 30-day extension for CCI to respond to the Amended Complaint,
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`making the new deadline to Wednesday, January 8, 2025.
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`Dated: December 6, 2024
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`Respectfully submitted,
`
`By: /s/ Ryan R. Smith
`
`James C. Yoon (Admitted to Practice WDTX;
`CA State Bar No. 177155)
`Ryan R. Smith (Admitted to Practice WDTX;
`CA State Bar No. 229323)
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Telephone: (650) 493-9300
`Facsimile: (650) 565-5100
`Email: jyoon@wsgr.com, rsmith@wsgr.com
`
`Jamie Y. Otto (Admitted to Practice WDTX;
`CA State Bar No. 295099)
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`953 East Third Street, Suite 100
`Los Angeles, CA 94304-1050
`Telephone: (323) 210-2900
`Facsimile: (866) 974-7329
`Email: jotto@wsgr.com
`
`ATTORNEYS FOR PLAINTIFF PAYRANGE
`INC.
`
`
`
`Case 6:24-cv-00339-OLG Document 14 Filed 12/06/24 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing document was served to all
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`counsel of record who are deemed to have consented to electronic service via the Court’s
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`CM/ECF system.
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`Dated: December 6, 2024
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`/s/ Ryan R. Smith
`Ryan R. Smith
`
`