Case: 25-1010 Document: 16 Page: 1 Filed: 03/26/2025
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`2025-1010, -1011, -1012, -1020, -1030
`United S tates Court of Appeals
`for the F ederal Circuit
`
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`FLYPSI, INC., DBA FLYP,
`Appellant
`
`v.
`GOOGLE LLC,
`Appellee
`
`Appeal from the United States Patent and Trademark Office,
`Patent Trial and Appeal Board in Nos. IPR2023-00357, IPR2023-00358,
`IPR2023-00359, IPR2023-00360, IPR2023-00361.
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`APPELLEE’S UNOPPOSED MOTION FOR
`EXTENSION OF TIME TO FILE ITS RESPONSE BRIEF
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`March 26, 2025
`
`Naveen Modi
`Joseph E. Palys
`
`Daniel Zeilberger
`
`PAUL HASTINGS LLP
`2050 M Street, N.W.
`Washington, D.C. 20036
`Tel.: (202) 551-1700
`
`Counsel for Appellee Google LLC
`
`
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`2025-1010, -1011, -1012, -1020, -1030
`United S tates Court of Appeals
`for the F ederal Circuit
`
`
`FLYPSI, INC., DBA FLYP,
`Appellant
`
`v.
`GOOGLE LLC,
`Appellee
`
`Appeal from the United States Patent and Trademark Office,
`Patent Trial and Appeal Board in Nos. IPR2023-00357, IPR2023-00358,
`IPR2023-00359, IPR2023-00360, IPR2023-00361.
`
`APPELLEE’S UNOPPOSED MOTION FOR
`EXTENSION OF TIME TO FILE ITS RESPONSE BRIEF
`
`
`
`
`
`
`
`
`
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`
`
`March 26, 2025
`
`Naveen Modi
`Joseph E. Palys
`
`Daniel Zeilberger
`
`PAUL HASTINGS LLP
`2050 M Street, N.W.
`Washington, D.C. 20036
`Tel.: (202) 551-1700
`
`Counsel for Appellee Google LLC
`
`
`
`Case: 25-1010 Document: 16 Page: 2 Filed: 03/26/2025
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`Pursuant to Rules 26(b) and 27 of the Federal Rules of Appellate Procedure
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`and Federal Circuit Rules 26(b) and 27, Appellee Google LLC (“Google”)
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`respectfully submits this motion for an extension of time of thirty (30) days to file
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`its response brief in this appeal. Google’s response brief is currently due on April
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`14, 2025. If the Court grants this request, the due date for Google’s response brief
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`would extend to May 14, 2025. Counsel for Google consulted with counsel for
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`Appellant Flypsi, Inc. (“Flyp”) and counsel for Flyp does not oppose this request.
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`This is Google’s first request for an extension of time in this appeal. Good
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`cause exists to grant the requested extension. The extension is necessary in light of
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`the pre-existing professional obligations of Google’s counsel in other matters
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`before this Court, other federal courts, and before the Patent Trial and Appeal
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`Board. A declaration supporting these facts accompanies this motion.
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`This request for an extension of time is made in good faith by counsel and
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`not for the purpose of delay or other procedural advantage. The requested
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`extension would enable counsel to brief adequately the issues involved in this case,
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`and to consult with the client. The requested extension of time is reasonable under
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`the circumstances.
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`1
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`Case: 25-1010 Document: 16 Page: 3 Filed: 03/26/2025
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`For the reasons stated above, Google respectfully requests that this
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`unopposed motion for an extension of briefing time be granted, and that the filing
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`date for Google’s response brief be extended to May 14, 2025.
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`Dated: March 26, 2025
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`Respectfully submitted,
`
`
`
`
`
`/s/Naveen Modi
`Naveen Modi
`Joseph E. Palys
`Daniel Zeilberger
`PAUL HASTINGS LLP
`2050 M Street, N.W.
`Washington, D.C. 20036
`(202) 551-1700
`
`Counsel for Appellee Google LLC
`
`
`
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`2
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`
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`Case: 25-1010 Document: 16 Page: 4 Filed: 03/26/2025
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` CERTIFICATE OF INTEREST
`Counsel for Google LLC certifies the following:
`1. Provide the full names of all entities represented by undersigned counsel in this
`case.
`Google LLC
`2. Provide the full names of all real parties in interest for the entities. Do not list
`the real parties if they are the same as the entities.
`None
`3. Provide the full names of all parent corporations for the entities and all publicly
`held companies that own 10% or more stock in the entities.
`XXVI Holdings Inc.; Alphabet Inc.
`4. List all law firms, partners, and associates that (a) appeared for the entities in
`the originating court or agency or (b) are expected to appear in this court for the
`entities. Do not include those who have already entered an appearance in this
`court.
`Paul Hastings: Howard Herr, Puja Patel
`5. Other than the originating case(s) for this case, are there related or prior art
`cases that meet the criteria under Fed. Cir. R. 47.5(a).
`See Dkt. No. 10
`6. Provide any information required under Fed. R. App. P. 26.1(b) (organizational
`victims in criminal cases) and 26.1(c) (bankruptcy case debtors and trustees).
`Not applicable.
`March 26, 2025
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`
`
`
`/s/ Naveen Modi
`Naveen Modi
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`
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`Case: 25-1010 Document: 16 Page: 5 Filed: 03/26/2025
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`
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`2025-1010, -1011, -1012, -1020, -1030
`United S tates Court of Appeals
`for the F ederal Circuit
`
`
`FLYPSI, INC., DBA FLYP,
`Appellant
`v.
`GOOGLE LLC,
`Appellee
`
`
`
`
`
`Appeal from the United States Patent and Trademark Office,
`Patent Trial and Appeal Board in Nos. IPR2023-00357, IPR2023-00358,
`IPR2023-00359, IPR2023-00360, IPR2023-00361.
`
`APPELLEE’S UNOPPOSED MOTION FOR
`EXTENSION OF TIME TO FILE ITS RESPONSE BRIEF
`______________________
`
`DECLARATION OF NAVEEN MODI
`
`
`
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`1.
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`I am a partner with Paul Hastings LLP (“Paul Hastings”) and counsel
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`for Appellee Google LLC (“Google”) in this appeal. I am submitting this
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`declaration of counsel in accordance with Federal Circuit Rule 26(b)(3) and in
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`support of Appellee’s Unopposed Motion for Extension of Time to File Its
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`Response Brief.
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`2.
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`Under the existing schedule, Google’s response brief is due on April
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`
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`
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`Case: 25-1010 Document: 16 Page: 6 Filed: 03/26/2025
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`14, 2025. Google requests an extension of thirty (30) days, until May 14, 2025.
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`3.
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`4.
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`This is Google’s first request for additional time in this appeal.
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`Counsel for Google consulted with counsel for Appellant Flypsi, Inc.
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`counsel for Appellant has indicated that they do not oppose this motion.
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`5.
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`This request for an extension of time is made in good faith and not for
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`the purpose of delay or other procedural advantage.
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`6.
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`The requested 30-day extension of time is needed to allow adequate
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`time for counsel to prepare Google’s response brief and to provide sufficient time
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`for review and comment. The requested additional time is needed to accommodate
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`pre-existing professional obligations in several pending and active matters before
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`this Court, various district courts, and the Patent Trial and Appeal Board.
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`7.
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`The requested extension of time would enable counsel to brief
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`adequately the issues involved, and to consult with the client.
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`8.
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`In accordance with 28 U.S.C. § 1746, I declare under penalty of
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`perjury that the foregoing is true and correct.
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` /s/Naveen Modi
`Naveen Modi
`
`
`
`
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`Date: March 26, 2025
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`Case: 25-1010 Document: 16 Page: 7 Filed: 03/26/2025
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`CERTIFICATE OF COMPLIANCE WITH TYPE-VOLUME
`LIMITATION, TYPEFACE REQUIREMENTS AND TYPE STYLE
`REQUIREMENTS
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`1. This motion complies with the type-volume limitation of Federal Rule of
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`Appellate Procedure 27(d)(2)(A).
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`The motion contains 245 words, excluding the parts of the motion exempted
`by Federal Circuit Rule 27(d).
`2. This motion complies with the typeface and type style requirements of
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`Federal Rule of Appellate Procedure 27(d)(1)(E).
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`The motion has been prepared in a proportionally spaced typeface using
`MS Word 2013 in a 14 point Times New Roman font.
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`Date: March 26, 2025
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`BY:
`
`
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`/s/Naveen Modi
`
`Naveen Modi
`PAUL HASTINGS LLP
`2050 M Street, N.W.
`Washington, D.C. 20036
`Tel.: (202) 551-1700
`Fax: (202) 551-1705
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