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Case 2:24-cv-00321-AWA-DEM Document 34 Filed 11/04/24 Page 1 of 3 PageID# 316
`
`THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`NORFOLK DIVISION
`
`
`
`
`
`
`
`Plaintiff,
`
`v.
`
`
`SOUNDCLEAR TECHNOLOGIES LLC, §
`
`
`§
`
`
`§
`
`§ Case No. 2:24-cv-00321-AWA-DEM
`§
`
`§
`
`§
`
`§
`
`§
`
`§
`
`
`
`
`GOOGLE LLC,
`
`
`
`
`Defendant.
`
`MOTION TO SEAL PORTIONS OF MEMORANDUM OF LAW IN SUPPORT OF
`GOOGLE’S MOTION TO TRANSFER TO THE NORTHERN DISTRICT OF
`CALIFORNIA UNDER 28 U.S.C. § 1404(a) AND DECLARATIONS IN SUPPORT
`
`Defendant Google LLC (“Google”), by counsel, moves this Court for leave to seal
`
`(“Motion to Seal”) portions of the Memorandum of Law in Support of Google’s Motion to Transfer
`
`to the Northern District of California under 28 U.S.C. § 1404(a) and Declarations in Support
`
`(“Portions of Memorandum in Support of Google’s Motion to Transfer and Declarations in
`
`Support”). The grounds and authorities in support of Google’s Motion to Seal are set forth in detail
`
`in the Memorandum in Support of Google’s Motion to Seal filed this same day. A Proposed Order
`
`granting the Motion to Seal is attached hereto as Exhibit A.
`
`Dated: November 4, 2024
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`/s/ Stephen E. Noona
`Stephen E. Noona (VSB No. 25367)
`KAUFMAN & CANOLES, P.C.
`150 W. Main Street, Suite 2100
`Norfolk, VA 23510-1665
`Telephone: (757) 624-3239
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`
`PAUL HASTINGS LLP
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 34 Filed 11/04/24 Page 2 of 3 PageID# 317
`
`
`
`
`
`
`
`
`
`Robert W. Unikel (pro hac vice)
`Douglas L. Sawyer (pro hac vice)
`Mark T. Smith (pro hac vice)
`71 South Wacker Drive, Suite 4500
`Chicago, IL 60606
`Telephone: (312) 499-6000
`Facsimile: (312) 499-6100
`robertunikel@paulhastings.com
`dougsawyer@paulhastings.com
`marksmith@paulhastings.com
`
`Robert Laurenzi (pro hac vice)
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 319-4090
`robertlaurenzi@paulhastings.com
`
`Joshua Yin (pro hac vice)
`1117 S. California Avenue
`Palo Alto, CA 94304
`Telephone: (650) 320-1884
`Facsimile: (650) 320-1984
`joshuayin@paulhastings.com
`
`Ariell N. Bratton (pro hac vice)
`4655 Executive Drive, Suite 350
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`ariellbratton@paulhastings.com
`
`Counsel for Defendant Google LLC
`
`
`
`
`
`2
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 34 Filed 11/04/24 Page 3 of 3 PageID# 318
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on November 4, 2024, I will electronically file the foregoing with the
`
`Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
`
`the following:
`
`Chandran B. Iyer (VSB No. 94100)
`Kevin H. Sprenger (VSB No. 98588)
`Steven Reynolds (pro hac vice)
`DAIGNAULT IYER LLP
`8229 Boone Boulevard, Suite 450
`Vienna, VA 22182
`cbiyer@daignaultiyer.com
`ksprenger@daignaultiyer.com
`sreynolds@daignaultiyer.com
`
`
`Counsel for Plaintiff SoundClear Technologies LLC
`
`
`
`
`
` /s/ Stephen E. Noona
`Stephen E. Noona (VSB No. 25367)
`KAUFMAN & CANOLES, P.C.
`150 W. Main Street, Suite 2100
`Norfolk, VA 23510-1665
`Telephone: (757) 624-3239
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`
`
`Counsel for Defendant Google LLC
`
`
`
`3
`
`

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