Free Request for Default - District Court of Delaware - Delaware

Case 1:07-cv-00096-MPT

Document 5

Filed 04/16/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE WORLD WIDE LICENSES, LTD., a Hong Kong corporation, Plaintiff, v. POLAROID CONSUMER ELECTRONICS, LLC f/k/a PETTERS CONSUMER BRANDS, LLC, a Delaware company, Defendant. : : : : : : : : : : : : : : :

C.A. No. 07-96 (***)

JURY TRIAL DEMANDED

MOTION FOR ENTRY OF DEFAULT Pursuant to Rule 55(a) of the Federal Rules of Civil Procedure, Plaintiff, World Wide Licenses, Ltd. ("WWL"), respectfully requests entry by the Clerk of Court of the default of defendant, Polaroid Consumer Electronics, LLC f/k/a Petters Consumer Brands, LLC ("Defendant"). WWL states as follows in support of its request: 1. On February 20, 2007, WWL initiated this proceeding by the filing of its

Complaint against Defendant. 2. Thereafter, as appears on the Return of Service filed in this action, WWL served

Defendant with the summons and Complaint on March 20, 2007, through in-hand service upon the Defendant's registered agent, National Registered Agents, 160 Greentree Drive, Dover, Delaware. 3. As reflected on this Court's docket, and as stated in the Summons, Defendant was

required to answer the Complaint by April 9, 2007.

Case 1:07-cv-00096-MPT

Document 5

Filed 04/16/2007

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4. the Complaint. 5.

To date, Defendant has not appeared, moved, answered or otherwise responded to

Rule 55(a) provides for the entry of default due to the failure of a party to plead or

otherwise defend an action. 6. This Court's docket reflects the failure of Defendant to plead or otherwise defend

and its failure to answer the summons. Accordingly, this Court should enter a default against Defendant pursuant to Fed. R. Civ. P. 55(a). WHEREFORE, WWL respectfully requests that the Clerk enter the default of Polaroid Consumer Electronics, LLC f/k/a Petters Consumer Brands, LLC, and grant WWL such other and further relief as the Court deems just and proper.

Dated: April 16, 2007

DUANE MORRIS LLP /s/ Matt Neiderman Matt Neiderman (Del. Bar No. 4018) Kathaleen McCormick (Del. Bar No. 4579) 1100 N. Market St., Suite 1200 Wilmington, Delaware 19801 302.657.4900 302.657.4901 fax [email protected] OF COUNSEL: Michael R. Gottfried Darlene D. Moreau DUANE MORRIS LLP 470 Atlantic Avenue Boston, MA 02210 857.488.4200 857.488.4201 fax [email protected] [email protected]

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