PAGE 1 –UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE CLAIMS ELECTION

John Mansfield, OSB No. 055390 

MansfieldLaw 

121 SW Morrison Ave., Suite 400 

Portland, OR 97204 

Telephone: 971.271.8615 

john@mansfieldlaw.net 

Jonathan Baker (appearing pro hac vice) 

FARNEY DANIELS PC 

411 Borel Avenue, Suite 350 

San Mateo, California 94402 

Telephone: (424) 278-5200 

jbaker@farneydaniels.com 

[Additional Counsel listed on signature page] 

Attorneys for Plaintiff Memory Integrity, LLC 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

MEMORY INTEGRITY, LLC, 

Plaintiff, 

v. 

INTEL CORPORATION, 

Defendant. 

Case No. 3:15-cv-00262-SI

UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO SERVE 

CLAIMS ELECTION 

JURY TRIAL DEMANDED 

Plaintiff Memory Integrity, LLC (“MI” or “Plaintiff”) respectfully submits this 

Unopposed Motion for Extension of Time to Serve Claims Election. MI seeks a one-week 

extension of time to serve its election of fifteen asserted claims required under this Court’s 

October 30, 2015 order (Dkt. No. 152). Under the current deadline, MI’s response is due by 

Case 3:15-cv-00262-SI Document 155 Filed 11/06/15 Page 1 of 4
PAGE 2 –UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE CLAIMS ELECTION

November 13, 2015. MI seeks an extension of time to serve its election of fifteen asserted 

claims to 9 am PST on November 20, 2015. In support, Plaintiff states as follows: 

1. Counsel for Plaintiff has a number of hearings and case deadlines during the 

period provided in the Court’s order, including oral argument of an appeal and the 

deadline for submitting an appeal brief in another matter; 

2. In light of these commitments, it will unmanageable to make the election of 

fifteen asserted claims by the original deadline; 

3. Counsel for Plaintiff is authorized by counsel for Intel to state the following: 

“Based upon MI’s counsel’s statements that they have other professional 

commitments which will make complying with the Court’s deadline 

unmanageable, Intel does not oppose MI’s request to extend the deadline to 

identify the 15 asserted claims to November 20 provided that MI does so no later 

than 9:00 am PST on the 20th.” 

WHEREFORE, Plaintiff respectfully requests that the Court extend the time to serve 

Plaintiff’s election of 15 asserted claims in the above-captioned case to 9 am PST on November 

20, 2015. 

Case 3:15-cv-00262-SI Document 155 Filed 11/06/15 Page 2 of 4
PAGE 3 –UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE CLAIMS ELECTION

Dated: November 6, 2015 Respectfully submitted, 

/s/ Jonathan Baker 

Jonathan Baker (appearing pro hac vice) 

Michael Saunders (appearing pro hac vice) 

Gurtej Singh (appearing pro hac vice) 

FARNEY DANIELS PC 

411 Borel Avenue, Suite 350 

San Mateo, California 94402 

Telephone: (424) 278-5200 

jbaker@farneydaniels.com 

msaunders@farneydaniels.com 

tsingh@farneydaniels.com 

John Mansfield, OSB No. 055390 

MANSFIELDLAW

121 SW Morrison Ave., Suite 400 

Portland, OR 97204 

Telephone: 971.271.8615 

john@mansfieldlaw.net 

Attorneys for Plaintiff

Memory Integrity, LLC

CERTIFICATE OF CONFERFENCE 

On November 4, 2015, counsel for Plaintiff conferred with counsel for Defendant 

regarding Plaintiff’s Motion for Extension of Time to Serve Claims Election. Counsel for 

Defendant confirmed that the Defendant does not oppose Plaintiff’s motion for extension of 

time. 

Dated: November 6, 2015 

/s/ Jonathan Baker 

Jonathan Baker (appearing pro hac vice) 

Attorney for Plaintiff, Memory Integrity, LLC 

Case 3:15-cv-00262-SI Document 155 Filed 11/06/15 Page 3 of 4
PAGE 4 –UNOPPOSED MOTION FOR EXTENSION OF TIME TO SERVE CLAIMS ELECTION

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed the foregoing document with the Clerk of the 

Court using the CM/ECF system, which will send notification of such filing to all interested 

parties. 

Dated: November 6, 2015 

/s/ Jonathan Baker 

Jonathan Baker (appearing pro hac vice) 

Attorney for Plaintiff, Memory Integrity, LLC 

Case 3:15-cv-00262-SI Document 155 Filed 11/06/15 Page 4 of 4