________________________________________________ 

________________________________________________ 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 1 of 7 * PUBLIC *; 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED BY ANGI. DOCKET NO. 9407 

COMPLAINT COUNSEL’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO 

MOVE TO COMPEL DISCOVERY RESPONSES 

Complaint Counsel respectfully move to extend the time by which Complaint Counsel 

must move to compel Respondent’s responses to Complaint Counsel’s First Set of 

Interrogatories and First Set of Requests for Production of Documents (hereafter, “First Set of 

Discovery Requests”), and to amend Paragraph 8 of the Scheduling Order to extend the time by 

which either party must move to compel any future responses to discovery requests. Respondent 

does not oppose this motion. 

Complaint Counsel served their First Set of Discovery Responses on Respondent on 

April 18, 2022. Respondent served its Responses and Objections to Complaint Counsel’s First 

Set of Interrogatories and First Set of Requests for Production of Documents (hereafter, 

“Responses and Objections”) on Complaint Counsel by email on May 18, 2022. In its Responses 

and Objections, Respondent stated that it intended to produce certain documents responsive to 

some of the Requests and, with respect to other Requests, it was willing to meet and confer to 

better understand what additional documents should be produced. 

On June 8, 2022, Complaint Counsel received Respondent’s first production of 

documents, which Complaint Counsel understand are responsive to the Requests. On June 10, 

- 1 -

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 2 of 7 * PUBLIC *; 

2022, Complaint Counsel and Respondent (collectively, “the Parties”) held an initial meet and 

confer conference regarding the Responses and Objections, during which Respondent stated that 

it intended to produce additional documents, and during which the Parties agreed to continue to 

meet and confer regarding the Responses and Objections. 

Pursuant to the Scheduling Order entered in this matter, because Respondent served the 

Responses and Objections via email on May 18, 2022, any motion by Complaint Counsel to 

compel responses to its First Set of Discovery Requests must be filed by June 21, 2022. See 

Scheduling Order, ¶ 8 (setting deadline as “within 30 days of service of the responses and/or 

objections to the discovery requests”); 16 C.F.R.§ 4.3(c) (adding one day for email service); 16 

C.F.R. § 4.3(a) (when deadline falls on a Saturday, Sunday, or national holiday, deadline moves 

to the next following non-holiday business day). The Parties expect that neither Respondent’s 

production of responsive documents nor the meet and confer process will be completed by that 

date. 

Because Respondent has represented that certain additional documents are forthcoming, 

because the Parties have agreed to continue to meet and confer about the Responses and 

Objections, and to avoid burdening the Court with a motion to compel that is otherwise 

potentially avoidable via the meet and confer process, Complaint Counsel request, and 

Respondent does not oppose, an extension of the date by which Complaint Counsel must move 

to compel responses to its First Set of Discovery Requests as follows: 

Any motion to compel responses to the First Set of Discovery Requests shall be 

filed within 30 days of after Respondent represents that its responses thereto are 

complete or within 20 days after the close of discovery, whichever first occurs; 

except that, where the parties have been engaging in negotiations over a discovery 

dispute, including negotiations with any nonparty with regard to a subpoena, the 

deadline for the motion to compel shall be within 5 days of reaching an impasse. 

- 2 -

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 3 of 7 * PUBLIC *; 

Similarly, to avoid burdening the Court in general with any future motion to compel that 

is otherwise potentially avoidable via the meet and confer process, Complaint Counsel also 

request, and Respondent does not oppose, to amend Paragraph 8 of the Scheduling Order as 

follows: 

Compliance with the scheduled end of discovery requires that the parties serve 

subpoenas and discovery requests sufficiently in advance of the discovery cut-off 

and that all responses and objections will be due on or before that date, unless 

otherwise noted. Any motion to compel responses to discovery requests, or to 

seek certification of a request for court enforcement of a nonparty subpoena, shall 

be filed within 30 days of when the responding party declines to make a 

production or answer an interrogatory, in whole or in part, and no further 

conferral between the parties is planned on the issue, service of the responses 

and/or objections to the discovery requests or within 20 days after the close of 

discovery, whichever first occurs; except that, where the parties have been 

engaging in negotiations over a discovery dispute, including negotiations with any 

nonparty with regard to a subpoena, the deadline for the motion to compel shall 

be within 5 days of reaching an impasse. 

Complaint Counsel have met and conferred with Respondent, and as reflected herein, 

Respondent does not oppose the proposed extension and amendment to the Scheduling Order. 

No party will suffer any undue prejudice from the requested proposed extension and amendment 

to the Scheduling Order. Moreover, the requested proposed extension and amendment to the 

Scheduling Order will not delay other procedural deadlines or the hearing date set for 

November 9, 2022. 

For these reasons, Complaint Counsel respectfully request that the Court enter the 

attached proposed Order. 

- 3 -

PUBLIC
 

 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 4 of 7 * PUBLIC *; 

Respectfully submitted, 

Dated: June 14, 2022 s/ Sophia H. Calderón 

Sophia H. Calderón 

Colin D. A. MacDonald 

Breena M. Roos 

M. Elizabeth Howe 

Federal Trade Commission 

Northwest Region 

915 Second Ave., Suite 2896 

Seattle, WA 98174 

Tel.: (206) 220-6350 

Fax: (206) 220-6366 

Email: scalderon@ftc.gov 

cmacdonald@ftc.gov 

broos@ftc.gov 

mhowe@ftc.gov 

Counsel Supporting the Complaint 

- 4 -

PUBLIC
________________________________________________ 

________________________________________________ 

FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 5 of 7 * PUBLIC *; 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., a corporation, 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED BY ANGI. DOCKET NO. 9407 

[PROPOSED] ORDER 

Having carefully considered Complaint Counsel’s Unopposed Motion for Extension of 

Time to Move to Compel Discovery Responses, it is hereby 

ORDERED as follows: 

Any motion to compel responses to Complaint Counsel’s First Set of Interrogatories or 

Complaint Counsel’s First Set of Requests for Production of Documents shall be filed within 30 

days of after Respondent represents that its responses thereto are complete or within 20 days 

after the close of discovery, whichever first occurs; except that, where the parties have been 

engaging in negotiations over a discovery dispute, including negotiations with any nonparty with 

regard to a subpoena, the deadline for the motion to compel shall be within 5 days of reaching an 

impasse. 

Paragraph 8 of the Scheduling Order is amended as to read as follows: 

Compliance with the scheduled end of discovery requires that the parties serve 

subpoenas and discovery requests sufficiently in advance of the discovery cut-off 

and that all responses and objections will be due on or before that date, unless 

otherwise noted. Any motion to compel responses to discovery requests, or to 

seek certification of a request for court enforcement of a nonparty subpoena, shall 

be filed within 30 days of when the responding party declines to make a 

production or answer an interrogatory, in whole or in part, and no further 

conferral between the parties is planned on the issue, or within 20 days after the 

close of discovery, whichever first occurs; except that, where the parties have 

- 1 -

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 6 of 7 * PUBLIC *; 

been engaging in negotiations over a discovery dispute, including negotiations 

with any nonparty with regard to a subpoena, the deadline for the motion to 

compel shall be within 5 days of reaching an impasse. 

ORDERED: 

D. Michael Chappell 

Chief Administrative Law Judge 

Date: 

- 2 -

PUBLIC
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 6/14/2022 | Document No. 604878 | PAGE Page 7 of 7 * PUBLIC *; 

CERTIFICATE OF SERVICE 

I hereby certify that on June 14, 2022, I filed the foregoing document electronically using 

the FTC’s E-Filing system, which will send notification of such filing to: 

April Tabor 

Office of the Secretary 

Federal Trade Commission 

Constitution Center 

400 Seventh Street, SW, Suite 5610 

Washington, D.C. 20024 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

I further certify that on June 14, 2022, I caused the foregoing document to be served via 

email to: 

William A. Burck 

Dawn Y. Yamane Hewett 

Kyra R. Simon 

Quinn Emanuel Urquhart & Sullivan, LLP 

1300 I Street NW, 9th Floor 

Washington, DC 20005 

(202) 538-8000 

williamburck@quinnemanuel.com 

dawnhewett@quinnemanuel.com 

kyrasimon@quinnemanuel.com 

Counsel for Respondent HomeAdvisor, Inc. 

Dated: June 14, 2022 

Stephen R. Neuwirth 

Jennifer J. Barrett 

Neil T. Phillips 

George T. Phillips 

Jared Ruocco 

Kathryn D. Bonacorsi 

Quinn Emanuel Urquhart & Sullivan, LLP 

51 Madison Avenue, 22nd Floor 

New York, NY 10010 

(212) 849-7000 

stephenneuwirth@quinnemanuel.com 

jenniferbarrett@quinnemanuel.com 

neilphillips@quinnemanuel.com 

georgephillips@quinnemanuel.com 

jaredruocco@quinnemanuel.com 

kathrynbonacorsi@quinnemanuel.com 

By: s/ Sophia H. Calderón 

Sophia H. Calderón 

Counsel Supporting the Complaint 

PUBLIC