(Disclaimers and disclosures.)

Here are some samples from Daimler's brief (I'm hoping someone else will type up the full text):

SCO initiated this litigation in February 2004 -- nearly a year after it brought suit against IBM. At no time did SCO suggest to this Court that its claims were unripe, or in any way related to or dependent upon the outcome of SCO's litigation against IBM. It is only now that its remaining claim about timeliness is about to proceed to trial -- without SCO meeting a single Court-ordered deadline or discovery obligation -- that SCO comes before this Court seeking a stay.
....
In other words, SCO wants to see how its bite at the IBM apple turns out before it expends any resources on the claims it has already forced DCC to defend. Courts, however, do not grant stays to promote this kind of litigation tactic -- sue, force the defendant to expend resouces, then stay the case while the plaintiff decides if it is really "worth it" to pursue the case at some unknown later date.

In conclusion, Daimler states that this motion is so ridiculous that Judge Chabot should not only deny it, but also order SCO to pay the cost of preparing the opposition memo:

The context of SCO's motion, the lack of legal authority to support it, and the absence of any plausible reason for tying the adjudication of this case to the outcome of the IBM litigation reveal SCO's motion for what it is -- a naked effort to manipulate the Court system, and DCC, for SCO's own benefit. DCC therefore respectfully requests that the Court deny SCO's Motion For Stay and award DCC its fees and costs incurred in preparing this Opposition.

I can't wait to find out whether Judge Chabot did that. Alas, I know it will probably be a couple weeks yet before I have the video of the hearing, or the written version of any order that was made at it.

At one point (page 3 footnote 2), I think Daimler lost its head in the excitement when it claimed that, in Michigan, a case cannot be stayed pending another case if there is even one respect in which the two cases are not identical. I haven't looked at the cases each side cites, but SCO seems to do a good job of jumping on that mistake. Of course, Daimler's argument can stand without that point, and it seems that SCO still couldn't find a single case to cite in which the plaintiff successfully sought a stay.

SCO admits by silence that it has indeed missed all the scheduled deadlines in the case, but it blames the whole existence of the case in the first place on Daimler's tardiness.