IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

KEVIN CHAMBERLAIN, an individual, NED 

NEWCOMER, an individual, and JERALD

ADLER, an individual, on their own behalf and 

on behalf of all others similarly situated,

Case No. 4:10-cv-00477-SPM-WCS

Plaintiffs,

v.

INTEGRACLICK, INC., a Delaware 

corporation, d/b/a CLICKBOOTH, 

1021018 ALBERTA, LTD, a Canadian 

company, d/b/a JUST THINK MEDIA d/b/a 

FAREND SERVICES LIMITED, 

Defendants.

________________________________________/

STIPULATION EXTENDING PLAINTIFFS’ DEADLINE TO RESPOND IN 

OPPOSITION TO DEFENDANT INTEGRACLICK, INC.’S MOTION TO 

DISMISS CLASS ACTION COMPLAINT AND TO STRIKE CLASS ALLEGATIONS

Pursuant to Local Rule 6.1, Plaintiffs Kevin Chamberlain, Ned Newcomer, and Jerald 

Adler, and Defendant Integraclick, Inc. (“Defendant” or “Integraclick”) (collectively referred to 

herein as the “Parties”), by and through their undersigned counsel, hereby submit this Stipulation 

Extending Plaintiffs’ Deadline to Respond in Opposition to Defendant Integraclick, Inc.’s 

Motion to Dismiss Class Action Complaint and to Strike Class Allegations. In support of this 

stipulation, the Parties state as follows:

WHEREAS, on October 28, 2010, Defendant 1021018 Alberta, Ltd. removed Plaintiffs' 

initial complaint to this Court, (Dkt. No. 1.);

WHEREAS, on November 10, 2010, Defendant moved to dismiss Plaintiffs’ complaint 

and strike the class allegations contained therein, (Dkt. No. 8);

Case 4:10-cv-00477-SPM -WCS Document 13-1 Filed 11/23/10 Page 1 of 3
WHEREAS, Plaintiffs’ current deadline to respond in opposition to Defendant’s motion 

to dismiss and to strike class allegations is November 24, 2010; 

WHEREAS, Plaintiffs are currently reviewing the arguments made in Defendant’s 

motion and require additional time to prepare an adequate response;

WHEREAS, the Parties have conferred telephonically regarding Plaintiffs’ need for 

additional time to prepare a response to Defendant’s motion;

WHEREAS, the Parties have agreed that Plaintiffs may have an extension of time 

through and including December 17, 2010, to file their opposition to Defendant’s motion to 

dismiss and to strike class allegations;

WHEREAS, the Parties have further agreed that following the filing of Plaintiffs’ 

opposition, Defendant shall have through and including January 14, 2011, to reply in support of 

its motion, upon a showing of good cause and leave of the Court; and

WHEREAS, good cause exists for the extension of time proposed herein.

NOW THEREFORE, the Parties, by and through their undersigned counsel, hereby 

STIPULATE and AGREE as follows: 

1. Plaintiffs shall have an extension of time through and including December 17, 

2010, to respond to Defendant Integraclick, Inc.’s Motion to Dismiss Class Action Complaint 

and to Strike Class Allegations, (Dkt. No. 8);

2. Defendant Integraclick, Inc. shall have through and including January 14, 2011, to 

reply in support of its motion, upon a showing of good cause and leave of the Court; and

3. All other briefing deadlines with respect to Defendant Integraclick, Inc.’s Motion 

to Dismiss Class Action Complaint and to Strike Class Allegations are hereby vacated.

IT IS SO STIPULATED.

Case 4:10-cv-00477-SPM -WCS Document 13-1 Filed 11/23/10 Page 2 of 3
Dated: November 23, 2010

 Respectfully submitted,

KEVIN CHAMBERLAIN, NED 

NEWCOMER, AND JERALD ADLER,

individually and on behalf of all other similarly 

situated,

By:/s/ David P. Healy

INTEGRACLICK, INC.

By:/s/ J. Martin Hayes

David P. Healy (0940410)

2846-B Remington Green Circle

Tallahassee, Florida 32308 

dhealy@davidhealylaw.com

 J. Martin Hayes (971766)

 AKERMAN SENTERFITT

 106 East College Avenue

 Tallahassee, Florida 32301

 martin.hayes@akerman.com

IT SO ORDERED this _____ day of _______, 2010.

HONORABLE STEPHEAN P. MICKLE

Case 4:10-cv-00477-SPM -WCS Document 13-1 Filed 11/23/10 Page 3 of 3