-
123456789
101112131415161718192021222324252627
HonorableRichardA.Jones
INTHEUNITEDSTATESDISTRICTCOURTFORTHEWESTERNDISTRICTOFWASHINGTON
DallasBuyersClub,LLC,
Plaintiffv.
DOES110,
Defendants.
CaseNo.14cv1819RAJ
REQUESTTOSUBMITRESPONSETOMOTIONFORDEFAULTJUDGMENT
Noted:January29,2016
REQUEST TO SUBMIT RESPONSE TOMOTION FOR DEFAULT JUDGMENT
Plaintiff in the above-captioned matter has now moved for a
defaultjudgment against Defendant Eric Nydam. (Dkt 47). Plaintiffs
motion,undersigned counsel believes, is somewhat slanted with
respect to the truestate of the law regarding copyright
infringement actions like this one.Undersigned counsel respectfully
requests leave to submit a very brief (fewerthan five pages)
response to Plaintiffs motion by Wednesday, February 3,2016.
Undersigned counsel believes that additional information should
bebrought to the Courts attention to assist the Court in fashioning
a default
Request to RespondCase No. 14-cv-1819-RAJ Page 1
WHITAKER LAW GROUP1218 Third Ave, Suite 1809
Seattle, WA 98101(206) 436-8500
Case 2:14-cv-01819-RAJ Document 50 Filed 01/29/16 Page 1 of
3
-
123456789
101112131415161718192021222324252627
judgment that is fair not only to Plaintiff in this action but
also to the publicin general. For example, just yesterday the
Internet Policy Task Force of theDepartment of Commerce issued a
lengthy white paper that specificallyaddresses considerations that
should be given by courts when makingstatutory damages awards in
cases exactly like this one.
The response would be submitted solely on behalf of
undersignedcounsel and not on behalf of Defendant Eric Nydam.
However, undersignedcounsel states that he does represent several
defendants in matters such asthis (including other subscribers in
this particular action) but undersignedcounsel does not now, nor
has he ever, represented or even spoken withDefendant Eric Nydam or
anyone acting as his agent.
Dated: January 29, 2016 Respectfully submitted,
/s/ JohnWhitaker
JohnWhitakerWHITAKERLAWGROUP1218ThirdAvenue,Suite1809Seattle,WA98101p:(206)4368500f:(206)6942203e:[email protected]
Request to RespondCase No. 14-cv-1819-RAJ Page 2
WHITAKER LAW GROUP1218 Third Ave, Suite 1809
Seattle, WA 98101(206) 436-8500
Case 2:14-cv-01819-RAJ Document 50 Filed 01/29/16 Page 2 of
3
-
123456789
101112131415161718192021222324252627
CERTIFICATEOFSERVICE
The undersigned attests that the foregoing document has been
servedon all parties of record via the Court's ECF service system
on the dateindicated below.
Dated: January 29, 2016 /s/ John Whitaker John Whitaker
Request to RespondCase No. 14-cv-1819-RAJ Page 3
WHITAKER LAW GROUP1218 Third Ave, Suite 1809
Seattle, WA 98101(206) 436-8500
Case 2:14-cv-01819-RAJ Document 50 Filed 01/29/16 Page 3 of
3
