TEAMWORKS INNOVATIONS, INC. v. STARBUCKS CORPORATION et al
Plaintiff: Teamworks Innovations, Inc.
Defendant: JDA Software Group, Inc., Starbucks Corporation and JDA Software, Inc.
Case Number: 1:2019cv01240
Filed: December 19, 2019
Court: US District Court for the Middle District of North Carolina
Presiding Judge: L PATRICK AULD
Referring Judge: THOMAS D SCHROEDER
Nature of Suit: Trademark
Cause of Action: 15:1125
Jury Demanded By: Plaintiff
Docket Report

This docket was last retrieved on February 15, 2020. A more recent docket listing may be available from PACER.

Date Filed Document Text
February 15, 2020 TEXT ORDER denying without prejudice #59 Motion for Limited Relief from Order regarding Expedited Discovery. In #59 Motion (filed on 02/14/2020), Defendant Starbucks Corporation asks the Court to modify #39 Order (entered on 01/24/2020) to permit Defendant Starbucks to make a rolling production by 02/24/2020 (rather than by 02/14/2020) of any additional responsive documents from the EHD database for the period 01/2018 through 01/2019. In support of #59 Motion, Defendant Starbucks Corporation filed #60 Memorandum, which in turn relies on [60-1] Declaration of Amy Carrasco, [60-2] Declaration of Patrick Kelly, and [60-3] Declaration of Sebolatito Adeyemi. According to #60 Memorandum, Defendant Starbucks Corporation "has completed its review of more than 100,00 documents over the twenty-one (21) day period provided for production and will [] produc[e] the vast majority of responsive documents by [02/14/2020]," but requires "an additional week in which to complete the review and production of a select number of EHD records...." As an initial matter, although #60 Memorandum references a 21-day window for production between the issuance of #39 Order (on 01/24/2020) and the deadline set therein (of 02/14/2020), it also acknowledges that, at a hearing held on 01/15/2020, regarding Plaintiff's request for expedited discovery, the Court identified 02/14/2020 as the likely production deadline. In addition, #60 Memorandum concedes that, on 01/17/2020, Defendant Starbucks Corporation filed #33 Notice "offer[ing] to gather and produce electronic records from its Enterprise Help Desk ('EHD' aka Technology Help Desk, 'THD') that referenced [Plaintiff's] trademark for the period from January 1, 2018 through January 1, 2020." In doing so, Defendant Starbucks Corporation "noted that this category of documents implicated tens of thousands of documents[ and] that [it] was working diligently to explore whether it would be able to complete production by the February 14, 2020 deadline mentioned by the Court during the hearing...." As stated in #60 Memorandum, #33 Notice "also advised that [the] production of PCC [Partner Contact Center helpdesk] records would be complicated by the fact that (1) the number of PCC records was substantial (in the tens of thousands of documents)[ and] (2) would, given the HR [Human Resources] focus of PCC, implicate significant privacy concerns necessitating time consuming review and redaction[.]" In other words, at least a week before the entry of #39 Order, Defendant Starbucks Corporation expected to face a deadline of 02/14/2020 to produce electronic records from 01/2018 to 01/2020 from both its EHD and PCC databases, knew that such production would require substantial resources, and had begun planning for such production. As to the ultimate burden of that production, according to [60-1] Declaration (from an employee of Defendant Starbucks Corporation), gathering records from the PCC database "for the period January 1, 2019-January 1, 2020 required a total of 35-38 person hours." Similarly, according to [60-2] Declaration (from another employee of Defendant Starbucks Corporation), to gather records from the EHD database, "[t]he process... took approximately a week for one year's worth of data." According to [60-3] Declaration (from an employee of the eDiscovery contractor hired by Defendant Starbucks Corporation "to assist with the collection, review, and upcoming production of [its] records for purposes of [this] litigation"), "from the inception of the project, [the contractor] has devoted a total of 1,091.54 person hours to the project.... Since January 24, 2020, [the contractor] has coordinated the extraction and review of over 100,000 records." The foregoing showing does not suffice to warrant the requested 10-day extension of the deadline set in #39 Order, for several reasons. First, the evidence submitted by Defendant Starbucks Corporation reflects that two of its employees working a normal work-week could gather a year of records from the EHD and PCC databases, but does not explain why Defendant Starbucks failed to devote an additional employee within the three-weeks allotted to gather the year of EHD records that remain for production. Second, the evidence submitted by Defendant Starbucks Corporation regarding the hours expended by its contractor does not specify what portion of those hours actually related directly to the production of records mandated in #39 Order (as opposed to the wider litigation activities Defendant Starbucks Corporation has commissioned its contractor to perform in connection with this case). Third, Defendant Starbucks Corporation has not adequately explained why, with the combined efforts of its employees and contractor, it cannot gather, review, and produce the remaining one year of EHD records in less than 10 days (or even seven days). Issued by MAG/JUDGE L. PATRICK AULD on 02/15/2020. (AULD, L.)
February 14, 2020 Filing 61 RESPONSE in Opposition re #55 MOTION to Enforce Compliance with the Court's January 24, 2020 Order for Expedited Discovery filed by TEAMWORKS INNOVATIONS, INC. filed by STARBUCKS CORPORATION. (Attachments: #1 Declaration of Mohit Patel)(MATHESON, JULIA ANNE)
February 14, 2020 Filing 60 MEMORANDUM re #59 MOTION for Relief from Court's January 24, 2020 Order Regarding Expedited Discovery by Defendant STARBUCKS CORPORATION. (Attachments: #1 Declaration of Amy Carrasco, #2 Declaration of Patrick Kelly, #3 Declaration of Sebolatito Adeyemi)(MATHESON, JULIA ANNE)
February 14, 2020 Filing 59 MOTION for Relief from Court's January 24, 2020 Order Regarding Expedited Discovery by STARBUCKS CORPORATION. (Attachments: #1 Text of Proposed Order)(MATHESON, JULIA ANNE)
February 14, 2020 TEXT ORDER granting #56 Motion for Extension of Time. Plaintiff shall file any response to #40 Motion to Dismiss and shall answer or otherwise respond to #42 Counterclaim by 03/03/2020. The granting of this extension does not alter the prerogative of the assigned United States District Judge to schedule any hearing on #13 Motion for Preliminary Injunction at any time. Issued by MAG/JUDGE L. PATRICK AULD on 02/14/2020. (AULD, L.)
February 13, 2020 Motion Referred to MAGISTRATE JUDGE L. PATRICK AULD RE: #56 MOTION for Extension of Time. (Engle, Anita)
February 13, 2020 Filing 58 REPLY, filed by Counter Defendant TEAMWORKS INNOVATIONS, INC., Plaintiff TEAMWORKS INNOVATIONS, INC., to Response to #56 MOTION for Extension of Time filed by TEAMWORKS INNOVATIONS, INC.. (PASLEY, DAVID)
February 13, 2020 Filing 57 Joint RESPONSE by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., and STARBUCKS CORPORATION to #56 MOTION for Extension of Time. (MATHESON, JULIA ANNE) Modified docket on 2/13/2020 to match document filed. (Daniel, J)
February 11, 2020 TEXT ORDER shortening response deadline for #56 Motion for Extension of Time to Noon on 02/13/2020 and requiring Plaintiff to file any reply by 5:00 p.m. on 02/14/2020. Issued by MAG/JUDGE L. PATRICK AULD on 02/11/2020. (AULD, L.)
February 11, 2020 TEXT ORDER shortening response deadline as to #55 Motion to Enforce Compliance to 02/14/2020 and requiring Plaintiff to file any reply by 02/19/2020. Notwithstanding the pendency of #55 Motion, Defendants shall perform any searches for documents which they have agreed to perform and shall produce responsive documents located pursuant to such searches by the existing deadline. Issued by MAG/JUDGE L. PATRICK AULD on 02/11/2020. (AULD, L.)
February 10, 2020 Filing 56 MOTION for Extension of Time by TEAMWORKS INNOVATIONS, INC.. (Attachments: #1 Exhibit 46 - Correspondence Regarding Motion for Extension of Time, #2 Text of Proposed Order)(PASLEY, DAVID)
February 10, 2020 Filing 55 MOTION to Enforce Compliance with the Court's January 24, 2020 Order for Expedited Discovery by TEAMWORKS INNOVATIONS, INC.. Response to Motion due by 2/24/2020 (Attachments: #1 Exhibit 44 - 1.15.20 Hearing Evidence Notebook, #2 Exhibit 45 - Emails on Scope of Expedited Discovery)(SMITH, CHRISTOPHER)
February 7, 2020 Filing 54 NOTICE of Appearance by attorney MICHAEL GEORGE ADAMS on behalf of Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION (ADAMS, MICHAEL)
January 27, 2020 Filing 53 NOTICE of Manual Filing ECF No. 46-5 Exhibit 5 to the Declaration of Murali Sambara in Support of JDA Defendants Opposition to Plaintiffs Motion for Preliminary Injunction, and ECF No. 49-18 Exhibit 18 to the Declaration of Brendan C. Quinn in Support of Starbucks Opposition to Plaintiffs Motion for Preliminary Injunction in paper form with the Clerk's Office (MATHESON, JULIA ANNE)
January 27, 2020 Filing 52 DECLARATION of Leslie Hampel filed by Defendant STARBUCKS CORPORATION re #48 Response in Opposition to Motion for Preliminary Injunction filed by STARBUCKS CORPORATION. (MATHESON, JULIA ANNE)
January 27, 2020 Filing 51 DECLARATION of Chris Silver Smith filed by Defendant STARBUCKS CORPORATION re #48 Response in Opposition to Motion for Preliminary Injunction filed by STARBUCKS CORPORATION. (Attachments: #1 Exhibit 25, #2 Exhibit 26)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 50 DECLARATION of Amy Rotter filed by Defendant STARBUCKS CORPORATION re #48 Response in Opposition to Motion for Preliminary Injunction filed by STARBUCKS CORPORATION. (Attachments: #1 Exhibit 21, #2 Exhibit 22, #3 Exhibit 23, #4 Exhibit 24)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 49 DECLARATION OF Brendan C. Quinn filed by Defendant STARBUCKS CORPORATION re #48 Response in Opposition to Motion for Preliminary Injunction filed by STARBUCKS CORPORATION. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18, #19 Exhibit 19, #20 Exhibit 20)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 48 RESPONSE in Opposition re #14 Memorandum, filed by TEAMWORKS INNOVATIONS, INC. filed by STARBUCKS CORPORATION. Replies due by 2/21/2020 (MATHESON, JULIA ANNE)
January 27, 2020 Filing 47 Corrected document re #45 Declaration,. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 46 Corrected document re #44 Declaration,. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 45 ****FILED IN ERROR****DECLARATION filed by Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC. re #43 Response in Opposition to Motion for Preliminary Injunction filed by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(MATHESON, JULIA ANNE) Modified on 1/29/2020 to reflect filed in error per filer. See #47 . (Butler, Carol)
January 27, 2020 Filing 44 ****FILED IN ERROR*****DECLARATION filed by Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC. re #43 Response in Opposition to Motion for Preliminary Injunction filed by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7)(MATHESON, JULIA ANNE) Modified on 1/29/2020 to reflect filed in error per filer. See #46 . (Butler, Carol)
January 27, 2020 Filing 43 RESPONSE in Opposition re #13 MOTION for Preliminary Injunction filed by TEAMWORKS INNOVATIONS, INC. filed by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC.. Replies due by 2/21/2020 (MATHESON, JULIA ANNE)
January 27, 2020 Set Deadlines re #13 MOTION for Preliminary Injunction : Replies due by 2/21/2020. (Butler, Carol)
January 27, 2020 Filing 42 ANSWER to #7 Complaint, Affirmative Defenses and, Counterclaim against by STARBUCKS CORPORATION. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(MATHESON, JULIA ANNE)
January 27, 2020 Filing 41 MEMORANDUM re #40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC.. (MATHESON, JULIA ANNE)
January 24, 2020 Filing 40 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC.. (Attachments: #1 Memorandum of Law in Support of Motion to Dismiss)(MATHESON, JULIA ANNE)
January 24, 2020 TEXT ORDER re-setting the reply deadline as to #13 Motion for Preliminary Injunction to 02/21/2020, in light of #39 Order, granting in part #26 Motion for Expedited Discovery Responses. Issued by MAG/JUDGE L. PATRICK AULD on 01/24/2020. (AULD, L.)
January 24, 2020 Filing 39 MEMORANDUM OPINION AND ORDER, signed by MAG/JUDGE L. PATRICK AULD on 1/24/2020, that the instant Motion (Docket Entry #26 ) is GRANTED IN PART and DENIED IN PART, in that a decision on whether/when to hold a hearing on the PI Motion (Docket Entry #13 ) shall occur at a later date, but, on or before February 14, 2020, as set out herein. (Butler, Carol)
January 24, 2020 Opinion or Order Filing 38 ORDER signed by CHIEF JUDGE THOMAS D. SCHROEDER on 1/24/2020; that motion (Doc. #36 ) is granted in part. The word limitation applicable to Starbucks brief in response to Plaintiff's Motion for Preliminary Injunction is hereby increased to 8,000 words. (Sheets, Jamie)
January 23, 2020 Filing 37 NOTICE by TEAMWORKS INNOVATIONS, INC. re Motion Hearing, #32 Notice (Other) of the Parties' Updated Availability for Hearing (PASLEY, DAVID)
January 23, 2020 Motion Submitted to CHIEF JUDGE THOMAS D. SCHROEDER: #36 Consent MOTION for Leave to Exceed Word Limitations. (Engle, Anita)
January 22, 2020 Filing 36 MOTION for Leave to Exceed Word Limitations by STARBUCKS CORPORATION. (Attachments: #1 Text of Proposed Order)(MATHESON, JULIA ANNE)
January 20, 2020 Filing 35 NOTICE by TEAMWORKS INNOVATIONS, INC. re #33 Notice (Other), #34 Notice (Other) Supplemental Notice of Failure to Reach Agreement on Scope of Expedited Discovery (Attachments: #1 Exhibit 43, 1.17.20 Correspondence)(SMITH, CHRISTOPHER)
January 17, 2020 Filing 34 NOTICE by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION Enclosing Proposed Order to Notice Responding to Court's Minute Order Regarding Plaintiff's Motion Seeking Expedited Discovery (MATHESON, JULIA ANNE)
January 17, 2020 Filing 33 NOTICE by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION Responding to Court's Minute Order Regarding Plaintiff's Motion Seeking Expedited Discovery (Attachments: #1 Exhibit A, #2 Exhibit B)(MATHESON, JULIA ANNE)
January 17, 2020 Filing 32 NOTICE by TEAMWORKS INNOVATIONS, INC. Notice of Failure to Reach Agreement on Scope of Expedited Discovery (Attachments: #1 Exhibit 41 - 1-866-504-7368 search, #2 Exhibit 42 - Defendants' 1.16.20 letter)(PASLEY, DAVID)
January 16, 2020 Filing 31 NOTICE by TEAMWORKS INNOVATIONS, INC. re #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction, #13 MOTION for Preliminary Injunction Notice of Filing of Exhibits 39 and 40 (Attachments: #1 Exhibit 39 - Starbucks Q3 Earnings Call Transcript, #2 Exhibit 40 - Starbucks Q4 Earnings Call Transcript)(PASLEY, DAVID)
January 15, 2020 Minute Entry for proceedings held before MAG/JUDGE L. PATRICK AULD: Motion Hearing held on 1/15/2020 re #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction; Parties instructed to meet and confer by close of business on 1/17/2020, to see if they are able to reach a mutual agreement as to expedited discovery; in the event the parties are unable to reach a mutual agreement, a Notice shall be filed by close of business on 1/17/2020 indicating such, as well as their availability in February 2020; Text Order Forthcoming. (Attorney(s) Christopher Smith, Philip J. Cardinale, and David Pasley appeared on behalf of plaintiff TEAMWORKS INNOVATIONS, INC.; Attorney(s) Julia Matheson and Nicholas Lee appeared on behalf of defendants STARBUCKS CORPORATION, JDA SOFTWARE GROUP, INC., and JDA SOFTWARE, INC.; Proceedings Recorded) (Kemp, Donita)
January 14, 2020 Filing 30 RESPONSE in Opposition re #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction filed by TEAMWORKS INNOVATIONS, INC. filed by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION. Replies due by 1/28/2020 (MATHESON, JULIA ANNE)
January 13, 2020 Filing 29 DECLARATION of David Pasley filed by Plaintiff TEAMWORKS INNOVATIONS, INC. re #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction, #13 MOTION for Preliminary Injunction filed by TEAMWORKS INNOVATIONS, INC.. (Attachments: #1 Exhibit 28 - Additional Complaints to Teamworks, #2 Exhibit 29 - Google Play Reviews, #3 Exhibit 30 - Adam Cohen Linkedin, #4 Exhibit 31 - Misti Acevedo Linkedin, #5 Exhibit 32 - Nancy Alley Linkedin, #6 Exhibit 33 - Starrlette Smith Facebook, #7 Exhibit 34 - Starbucks' "Teamworks" Memes, #8 Exhibit 35 - Post with image of Starbucks' "Teamworks", #9 Exhibit 36 - Image of Starbucks' "Teamworks", #10 Exhibit 37 - Image of Teamworks' TEAMWORKS, #11 Exhibit 38 - Screenshot of Quick Reference Guide)(PASLEY, DAVID)
January 13, 2020 Filing 28 NOTICE of Appearance by attorney PHILIP J. CARDINALE, JR on behalf of Plaintiff TEAMWORKS INNOVATIONS, INC. (CARDINALE, PHILIP)
January 9, 2020 Set Hearings: Motion Hearing set for 1/15/2020 03:00 PM in Greensboro Courtroom #1A before MAG/JUDGE L. PATRICK AULD. (Garrett, Kim)
January 9, 2020 TEXT ORDER shortening the response time as to and setting a hearing on #26 Motion for Expedited Discovery Responses and Request for Hearing on #13 Motion for Preliminary Injunction, as follows: (A) Defendants shall file any response to #26 Motion by Noon on 01/14/2020; and (B) counsel for the parties shall appear for a hearing on #26 Motion at 3:00 p.m. on 01/15/2020 in Courtroom 1A of the L. Richardson Preyer United States Courthouse in Greensboro, North Carolina, at which time counsel for Plaintiff may give an oral reply to any response Defendants timely file to #26 Motion. Issued by MAG/JUDGE L. PATRICK AULD on 01/09/2020. (AULD, L.)
January 9, 2020 Motion Referred to MAGISTRATE JUDGE L. PATRICK AULDRE: #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction. (Engle, Anita)
January 9, 2020 Motion No Longer Submitted to CHIEF JUDGE THOMAS D. SCHROEDER: #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction. (Engle, Anita)
January 7, 2020 Motion Submitted to CHIEF JUDGE THOMAS D. SCHROEDER: #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction. (Engle, Anita)
January 6, 2020 Filing 27 MEMORANDUM filed by Plaintiff TEAMWORKS INNOVATIONS, INC. re #26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction filed by TEAMWORKS INNOVATIONS, INC.. (Attachments: #1 Exhibit 20 - 11/25/19 Courtesy Copies of Complaint and Discovery Requests to Starbucks, #2 Exhibit 21 - 11/25/19 Courtesy Copies of Complaint and Discovery Requests to JDA Defendants, #3 Exhibit 22 - First Set of Interrogatories to Defendant Starbucks Corporation, #4 Exhibit 23 - First Request for Production of Documents to Defendant Starbucks Corporation, #5 Exhibit 24 - First Set of Interrogatories to Defendant JDA Software, Inc., #6 Exhibit 25 - First Request for Production of Documents to Defendant JDA Software,Inc., #7 Exhibit 26 - First Set of Interrogatories to Defendant JDA Software Group, Inc., #8 Exhibit 27 - First Request for Production of Documents to Defendant JDA Software Group, Inc.)(PASLEY, DAVID)
January 6, 2020 Filing 26 MOTION to Expedite Discovery Responses and Request for Hearing on Motion for Preliminary Injunction by TEAMWORKS INNOVATIONS, INC.. (PASLEY, DAVID)
January 6, 2020 Filing 25 DEMAND for Trial by Jury by TEAMWORKS INNOVATIONS, INC.. (PASLEY, DAVID)
January 6, 2020 Filing 24 NOTICE of Appearance by attorney DAVID A. PASLEY on behalf of Plaintiff TEAMWORKS INNOVATIONS, INC. (PASLEY, DAVID)
January 2, 2020 Filing 23 NOTICE of Appearance by attorney LAUREN B. CURY on behalf of Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION (CURY, LAUREN)
December 27, 2019 Filing 22 NOTICE of Appearance by attorney BRENDAN C. QUINN on behalf of Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION (QUINN, BRENDAN)
December 27, 2019 Filing 21 NOTICE of Appearance by attorney KATHERINE BASTIAN on behalf of Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION (BASTIAN, KATHERINE)
December 27, 2019 Filing 20 NOTICE of Appearance by attorney JULIA ANNE MATHESON on behalf of Defendants JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION (MATHESON, JULIA ANNE)
December 27, 2019 Opinion or Order Filing 19 ORDER granting #15 Motion, signed by CHIEF JUDGE THOMAS D. SCHROEDER on 12/26/2019, that Defendants Starbucks Corporation, JDA Software Group, Inc., and JDA Software, Inc. shall have through and including January 27, 2020, to respond to Plaintiff's Motion for Preliminary Injunction. Responses due by 1/27/2020. (Butler, Carol)
December 23, 2019 Filing 18 AFFIDAVIT OF SERVICE as to All Defendants. (Attachments: #1 Exhibit A - Proof of 11/27/19 Service, #2 Exhibit B - Proof of 12/2/19 Service)(SMITH, CHRISTOPHER)
December 23, 2019 Motion Submitted to CHIEF JUDGE THOMAS D. SCHROEDER: #15 MOTION for Extension of Time to File Response/Reply as to #13 MOTION for Preliminary Injunction. (Engle, Anita)
December 23, 2019 Filing 17 CORPORATE DISCLOSURE STATEMENT filed pursuant to FRCP 7.1(a) by Plaintiff TEAMWORKS INNOVATIONS, INC. (SMITH, CHRISTOPHER)
December 23, 2019 Filing 16 NOTICE of Appearance by attorney CHRISTOPHER GEORGE SMITH on behalf of Plaintiff TEAMWORKS INNOVATIONS, INC. (SMITH, CHRISTOPHER)
December 23, 2019 Filing 15 MOTION for Extension of Time to File Response/Reply as to #13 MOTION for Preliminary Injunction by JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., STARBUCKS CORPORATION. (Attachments: #1 Text of Proposed Order)(LEE, NICHOLAS)
December 23, 2019 Filing 14 MEMORANDUM filed by Plaintiff TEAMWORKS INNOVATIONS, INC. re #13 MOTION for Preliminary Injunction filed by TEAMWORKS INNOVATIONS, INC.. (Attachments: #1 Affidavit of James Coffos, #2 Affidavit of Alison Pollock)(SMITH, CHRISTOPHER)
December 23, 2019 Filing 13 MOTION for Preliminary Injunction by TEAMWORKS INNOVATIONS, INC.. Response to Motion due by 1/13/2020 (SMITH, CHRISTOPHER)
December 20, 2019 Opinion or Order ORDER granting #6 Motion for Extension of Time to Answer for All Defendants. Answer due by 1/27/2020. This text order does not address Defendants' request to extend the time to answer Plaintiff's Motion for Preliminary Injunction, which was filed in Durham County. Should Plaintiff desire to pursue a Motion for Preliminary Injunction in this Court, a new motion should be filed in CM/ECF and accompanied by a brief pursuant to LR 7.3(a). Signed by John Brubaker, Clerk of Court, on 12/20/2019. (Brubaker, John)
December 20, 2019 Case ASSIGNED to CHIEF JUDGE THOMAS D. SCHROEDER and MAG/JUDGE L. PATRICK AULD. (Sheets, Jamie)
December 20, 2019 Filing 12 RESPONSE /Consent filed by Plaintiff TEAMWORKS INNOVATIONS, INC. re #6 MOTION for Extension of Time to File Answer re #1 Petition for Removal,,, and Respond to Motion for Preliminary Injunction filed by JDA SOFTWARE, INC., JDA SOFTWARE GROUP, INC., STARBUCKS CORPORATION filed by TEAMWORKS INNOVATIONS, INC.. Replies due by 1/3/2020 (SMITH, CHRISTOPHER)
December 20, 2019 CASE REFERRED to Mediation pursuant to Local Rule 83.9b of the Rules of Practice and Procedure of this Court. Please go to our website under Attorney Information for a list of mediators which must be served on all parties. (Sheets, Jamie)
December 20, 2019 Filing 10 ***FILED IN ERROR*** ECF 30 Day Notice as to Attorney CHRISTOPHER G. SMITH. ECF 30 Day Notice due by 1/21/2020. (Sheets, Jamie) Modified on 12/20/2019 to mark filed in error - attorney in system under different name. (Sheets, Jamie)
December 20, 2019 Filing 9 Notice of Right to Consent. (Attachments: #1 Consent Form) (Sheets, Jamie)
December 20, 2019 Filing 8 Summons Issued as to STARBUCKS CORPORATION, JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC. (Original document filed in Durham County Superior Court, Case Number 19CVS4455, issued 11/22/2019 and listed as Exhibits B and C to the Petition for Removal) (Sheets, Jamie)
December 20, 2019 Filing 7 COMPLAINT against STARBUCKS CORPORATION, JDA SOFTWARE GROUP, INC., JDA SOFTWARE, INC., filed by TEAMWORKS INNOVATIONS, INC. (Original document filed in Durham County Superior Court, Case Number 19CVS4455 and listed as Exhibit A to the Petition for Removal) (Sheets, Jamie)
December 19, 2019 Filing 6 MOTION for Extension of Time to File Answer re #1 Petition for Removal,,, and Respond to Motion for Preliminary Injunction by JDA Software Group, Inc., JDA Software, Inc., Starbucks Corporation. (Attachments: #1 Exhibit A - June 29, 2019 Letter, #2 Exhibit B - July 12, 2019 Letter, #3 Exhibit C - July 16, 2019 Letter, #4 Text of Proposed Order)(LEE, NICHOLAS)
December 19, 2019 Filing 5 Corporate Disclosure Statement by JDA Software Group, Inc. identifying Corporate Parent RP Crown Parent, LLC, Corporate Parent RP Crown Holding, LLC, Corporate Parent Red Prairie Holding, Inc. for JDA Software Group, Inc... (LEE, NICHOLAS)
December 19, 2019 Filing 4 Corporate Disclosure Statement by JDA Software, Inc. identifying Corporate Parent JDA Software Group, Inc., Corporate Parent RP Crown Parent, LLC, Corporate Parent RP Crown Holding, LLC, Corporate Parent Red Prairie Holding, LLC for JDA Software, Inc... (LEE, NICHOLAS)
December 19, 2019 Filing 3 Corporate Disclosure Statement by Starbucks Corporation. (LEE, NICHOLAS)
December 19, 2019 Filing 2 NOTICE of Appearance by attorney NICHOLAS H. LEE on behalf of Defendants JDA Software Group, Inc., JDA Software, Inc., Starbucks Corporation (LEE, NICHOLAS)
December 19, 2019 Filing 1 PETITION FOR REMOVAL against Teamworks Innovations, Inc. ( Filing fee $ 400 receipt number 0418-2718806.), filed by JDA Software, Inc., JDA Software Group, Inc., Starbucks Corporation. (Attachments: #1 Exhibit A- State Court Complaint, #2 Exhibit B - State Court Summons for Starbucks Corp and JDA Software Group, #3 Exhibit C - State Court Summons for JDA Software, Inc., #4 Exhibit D - Notice of Designation to NC Business Court, #5 Exhibit E - Designation Order, #6 Exhibit F - Assignment Order, #7 Exhibit G - Certification of Payment, #8 Exhibit H - Plaintiff's Motion for Preliminary Injunction, #9 Exhibit H1 - Plaintiff's Memorandum in Support of Preliminary Injunction, #10 Exhibit H2 - State Court Notice of Filing, #11 Exhibit H3 - Affidavit of James Coffos, #12 Exhibit H4 - Affidavit of Alison Pollock)(LEE, NICHOLAS)

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Defendant: JDA Software Group, Inc.
Represented By: NICHOLAS H. LEE
Represented By: BRENDAN C. QUINN
Represented By: MICHAEL GEORGE ADAMS
Represented By: JULIA ANNE MATHESON
Represented By: LAUREN B. CURY
Represented By: KATHERINE BASTIAN
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Defendant: Starbucks Corporation
Represented By: NICHOLAS H. LEE
Represented By: BRENDAN C. QUINN
Represented By: MICHAEL GEORGE ADAMS
Represented By: JULIA ANNE MATHESON
Represented By: LAUREN B. CURY
Represented By: KATHERINE BASTIAN
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Defendant: JDA Software, Inc.
Represented By: NICHOLAS H. LEE
Represented By: BRENDAN C. QUINN
Represented By: MICHAEL GEORGE ADAMS
Represented By: JULIA ANNE MATHESON
Represented By: LAUREN B. CURY
Represented By: KATHERINE BASTIAN
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Plaintiff: Teamworks Innovations, Inc.
Represented By: PHILIP J. CARDINALE, JR.
Represented By: DAVID A. PASLEY
Represented By: CHRISTOPHER GEORGE SMITH
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