XpresSpa Group Inc (XSPA)

[ThinkingMan]

Pacer #808

UNOPPOSED MOTION AND MEMORANDUM IN SUPPORT OF UNOPPOSED
MOTION TO STAY EXECUTION OF JUDGMENT PENDING DISPOSITION OF A
MOTION
The Defendants AOL Inc. (“AOL”), IAC Search & Media, Inc. (“IAC Search & Media”),
Gannett Co., Inc. (“Gannett”), Target Corporation (“Target”), and Google Inc. (“Google”)
(collectively “Defendants”), by counsel, file this unopposed motion to stay execution of
judgment pursuant to Rule 62(b) of the Federal Rules of Civil Procedure.
On November 21, 2012, the Court entered a Final Judgment. (D.N. 801.) Prior to the
jury’s verdict and the Court’s entry of judgment, Defendants filed several Motions for Judgment
as a Matter of Law pursuant to Fed. R. Civ. P. 50(a). (See, e.g., D.N. 751, 753, 772, 775.)
Defendants intend to file post-judgment motions with the Court, including renewed Motions for

Judgment as a Matter of Law pursuant to Fed. R. Civ. P. 50(b). Accordingly, pursuant to Fed. R.
Civ. P. 62(b), Defendants file this motion requesting that the Court stay any proceedings to
execute on or enforce the Final Judgment against Defendants pending disposition of all such
motions.
Counsel for Defendants has conferred with counsel for Plaintiff I/P Engine, Inc. (“I/P
Engine”), and I/P Engine does not oppose the relief requested by Defendants.
Case 2:11-cv-00512-RAJ-TEM Document 808 Filed 12/03/12 Page 1 of 5 PageID# 209312
WHEREFORE, the Defendants, by counsel, request that this Court enter the proposed
agreed order attached as Exhibit 1 staying any proceedings to execute on or enforce the Final
Judgment against Defendants pending resolution of any post-judgment motions timely filed in
this case.
DATED: December 3, 2012

[PROPOSED] AGREED ORDER GRANTING UNOPPOSED MOTION TO STAY
EXECUTION OF JUDGMENT PENDING DISPOSITION OF A MOTION
On this day came the Defendants AOL Inc. (“AOL”), IAC Search & Media, Inc. (“IAC
Search & Media”), Gannett Co., Inc. (“Gannett”), Target Corporation (“Target”), and Google
Inc. (“Google”) (collectively “Defendants”), by counsel, upon their Motion To Stay Execution of
Judgment Pending Disposition of a Motion pursuant to Rule 62(b) of the Federal Rules of Civil
Procedure, upon joint representation of counsel and for good cause shown, it is
ORDERED that the Defendants’ Motion To Stay Execution of Judgment Pending
Disposition of a Motion is granted, and any proceedings to execute on or enforce the Final
Judgment against Defendants shall be stayed pending resolution of any post-judgment motions
timely filed in this case, and for 14 days thereafter.
Dated: December ____, 2012 Entered: _____/_____/____


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