`
`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.
`
`DEFENDANT GOOGLE LLC’S CONSENT MOTION TO WITHDRAW MOTION TO SEAL,
`REFILE PUBLIC DOCUMENTS AND EXHIBITS, AND MEMORANDUM IN SUPPORT
`
`Defendant Google LLC (“Google”), by counsel, moves this Court to withdraw its Motion
`
`to Seal and for leave to substitute public documents for those filed under seal. In support of this
`
`consent motion, Google states as follows:
`
`1.
`
` On November 4, 2024, Google filed its motion to transfer this case to the Northern
`
`District of California (ECF NO. 38). In connection with the Motion to Transfer, Google filed a
`
`motion to seal (ECF No. 34) portions of its memorandum in support of the Motion to Transfer and
`
`three declarations filed in support (“Proposed Sealed Materials”) (ECF Nos. 39-42 and sealed at
`
`44-47).
`
`2.
`
`Thereafter, the parties met and conferred and, without waiving either parties’ rights,
`
`the parties have agreed that Google may file the Proposed Sealed Materials publicly for purposes
`
`of the Motion to Transfer. Both parties agree that reaching this agreement will simplify the
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`briefing of the motion. They further agree that the filing shall not prejudice either party’s rights in
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`filing future pleadings either under seal or publicly in this and other litigations.
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`
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 55 Filed 11/11/24 Page 2 of 4 PageID# 496
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`
`
`3.
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`Pursuant to the parties’ agreement and approval of this Court, Google will withdraw
`
`its Motion to Seal and refile public versions of the Proposed Sealed Materials. A Proposed Agreed
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`Order is attached as Exbibit 1 withdrawing the Motion to Seal and allowing Google to refile the
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`Proposed Sealed Materials in unredacted form.
`
`Dated: November 11, 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
`
`Robert W. Unikel (pro hac vice)
`Douglas L. Sawyer (pro hac vice)
`Mark T. Smith (pro hac vice)
`PAUL HASTINGS LLP
`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)
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 318-6000
`Facsimile: (212) 319-4090
`robertlaurenzi@paulhastings.com
`
`Joshua Yin (pro hac vice)
`PAUL HASTINGS LLP
`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)
`PAUL HASTINGS LLP
`4655 Executive Drive, Suite 350
`
`
`
`2
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 55 Filed 11/11/24 Page 3 of 4 PageID# 497
`
`
`
`
`
`
`
`San Diego, CA 92121
`Telephone: (858) 458-3000
`Facsimile: (858) 458-3005
`ariellbratton@paulhastings.com
`
`Counsel for Defendant Google LLC
`
`
`
`
`
`3
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`
`
`Case 2:24-cv-00321-AWA-DEM Document 55 Filed 11/11/24 Page 4 of 4 PageID# 498
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on November 11, 2024, I will electronically file the foregoing with the
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`Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
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`the following:
`
`Chandran B. Iyer (VSB No. 94100)
`Steven Reynolds (pro hac vice)
`James J. Hatton (pro hac vice)
`Matthew Harkins (pro hac vice)
`DAIGNAULT IYER LLP
`8229 Boone Boulevard, Suite 450
`Vienna, VA 22182
`cbiyer@daignaultiyer.com
`sreynolds@daignaultiyer.com
`jhatton@daignaultiyer.com
`mharkins@daignaultiyer.com
`
`Kevin H. Sprenger (VSB No. 98588)
`DAIGNAULT IYER LLP
`8618 Westwood Center Drive, Suite 150
`Vienna, VA 22182
`Telephone: (703) 712-1145
`ksprenger@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
`
`
`
`30117596v1
`
`4
`
`
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