Case 2:14-cv-01819-RAJ Document 50 Filed 01/29/16 Page 1 of 3

HonorableRichardA.Jones

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INTHEUNITEDSTATESDISTRICTCOURT
FORTHEWESTERNDISTRICTOFWASHINGTON
DallasBuyersClub,LLC,
CaseNo.14cv1819RAJ

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v.

Plaintiff

DOES110,
Defendants.

REQUESTTOSUBMIT
RESPONSETOMOTIONFOR
DEFAULTJUDGMENT
Noted:January29,2016

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REQUEST TO SUBMIT RESPONSE TO

MOTION FOR DEFAULT JUDGMENT
Plaintiff in the above-captioned matter has now moved for a default
judgment against Defendant Eric Nydam.

(Dkt 47).

Plaintiffs motion,

undersigned counsel believes, is somewhat slanted with respect to the true

state of the law regarding copyright infringement actions like this one.
Undersigned counsel respectfully requests leave to submit a very brief (fewer
than five pages) response to Plaintiffs motion by Wednesday, February 3,
2016. Undersigned counsel believes that additional information should be
brought to the Courts attention to assist the Court in fashioning a default

Request to Respond
Case No. 14-cv-1819-RAJ

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WHITAKER LAW GROUP

1218 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

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judgment that is fair not only to Plaintiff in this action but also to the public
in general. For example, just yesterday the Internet Policy Task Force of the
Department of Commerce issued a lengthy white paper that specifically
addresses considerations that should be given by courts when making
statutory damages awards in cases exactly like this one.
The response would be submitted solely on behalf of undersigned
counsel and not on behalf of Defendant Eric Nydam. However, undersigned
counsel states that he does represent several defendants in matters such as
this (including other subscribers in this particular action) but undersigned
counsel does not now, nor has he ever, represented or even spoken with
Defendant Eric Nydam or anyone acting as his agent.
Dated: January 29, 2016

Respectfully submitted,

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/s/

JohnWhitaker

JohnWhitaker
WHITAKERLAWGROUP
1218ThirdAvenue,Suite1809
Seattle,WA98101
p:(206)4368500
f:(206)6942203
e:john@wlawgrp.com

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Request to Respond
Case No. 14-cv-1819-RAJ

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WHITAKER LAW GROUP

1218 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

CERTIFICATEOFSERVICE

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The undersigned attests that the foregoing document has been served

on all parties of record via the Court's ECF service system on the date

indicated below.

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Dated: January 29, 2016

/s/ John Whitaker

John Whitaker

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Request to Respond
Case No. 14-cv-1819-RAJ

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WHITAKER LAW GROUP

1218 Third Ave, Suite 1809
Seattle, WA 98101
(206) 436-8500