`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`NORFOLK DIVISION
`
`SOUNDCLEAR TECHNOLOGIES, LLC,
`
` v.
`
`GOOGLE LLC,
`
`
`Plaintiff,
`
`Defendant.
`
`Case No. 2:24-cv-00321-AWA-DEM
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`CONSENT MOTION TO EXTEND TIME FOR PLAINTIFF
`TO RESPOND TO DEFENDANT GOOGLE’S MOTION TO TRANSFER TO THE
`NORTHERN DISTRICT OF CALIFORNIA UNDER 28 U.S.C. § 1404(a)
`
`Plaintiff SoundClear Technologies, LLC (“Plaintiff”), by its counsel, pursuant to Local
`
`Rule 7, hereby moves the Court for a three (3) week extension of time for Plaintiff to respond to
`
`Google’s Motion to Transfer to the Northern District of California Under 28 U.S.C. § 1404(a)
`
`(“MTT”) in this lawsuit. In support of this Motion, Plaintiff states as follows:
`
`1.
`
`2.
`
`Defendant filed the MTT on November 4, 2024.
`
`Plaintiff’s response to the MTT is currently due on Monday November 18, 2024.
`
`Thus, the time for responding to the MTT has not yet passed.
`
`3.
`
`This is a lawsuit for patent infringement involving three patents relating to
`
`systems and methods for automatic volume control in electronic devices, condition notification
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 58 Filed 11/13/24 Page 2 of 5 PageID# 556
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`methods and systems in electronic devices, and noise reduction systems and methods in
`
`electronic devices. The MTT raises issues that implicate all three patents.
`
`4.
`
`Plaintiff has conferred with Defendant about this motion. Defendant does not
`
`oppose the extension. Plaintiff seeks the extension to investigate the claims of the MTT and
`
`accommodate the availability of filing and support staff. Thus, good cause exists for this
`
`extension.
`
`5.
`
`The parties agree to a mutual three (3) week extension of time. The mutual
`
`extension provides Plaintiff’s response due on Monday December 9, 2024 and Defendant’s reply
`
`due on Monday January 6, 2025.
`
`6.
`
`No extension of time has previously been sought for responding to the MTT. This
`
`request for an extension of time is not made for the purpose of delay. The extension will not
`
`materially change any other pretrial deadline and will not affect the Court’s administration of this
`
`matter.
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`Accordingly, Plaintiff respectfully requests the Court to grant this Motion and enter the
`
`proposed Order filed herewith extending the time in which Plaintiff shall respond to the MTT to
`
`and through December 9, 2024, with Defendant’s reply brief due January 6, 2025.
`
`2
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 58 Filed 11/13/24 Page 3 of 5 PageID# 557
`
`Respectfully submitted,
`
`
`
` By: /s/ Kevin H. Sprenger
`Ronald M Daignault (pro hac vice to be filed)*
`Chandran B. Iyer (VA Bar No. 94100)
`Steven J. Reynolds*
`Kevin H. Sprenger (VA Bar No. 98588)
`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`sreynolds@daignaultiyer.com
`ksprenger@daignaultiyer.com
`DAIGNAULT IYER LLP
`8229 Boone Boulevard – Suite 450
`Vienna, VA 22182
`Tel.: (202) 330-1666
`
`Attorneys for Plaintiff SoundClear Technologies LLC
`
`*Not admitted to practice in Virginia
`
`Dated: November 13, 2024
`
`
`
`
`
`3
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 58 Filed 11/13/24 Page 4 of 5 PageID# 558
`
`CERTIFICATE OF SERVICE
`
`
`
`I certify that on November 13, 2024, I electronically filed the foregoing Consent Motion
`
`to Extend Time for Plaintiff to Respond to Defendant Google’s Motion to Transfer to the
`
`Northern District of California Under 28 U.S.C. § 1404(a) with the Clerk of Court using the
`
`CM/ECF system, which will then send a notification of such filing (NEF) to all counsel of
`
`record.
`
`
`
`
`
`
`
` By: /s/Kevin H. Sprenger
`Kevin H. Sprenger (VA Bar No. 98488)
`ksprenger@daignaultiyer.com
`DAIGNAULT IYER LLP
`8229 Boone Boulevard – Suite 450
`Vienna, VA 22182
`Tel.: (703) 712-1145
`
`Attorney for Plaintiff SoundClear Technologies LLC
`
`4
`
`
`
`Case 2:24-cv-00321-AWA-DEM Document 58 Filed 11/13/24 Page 5 of 5 PageID# 559
`Case 2:24-cv-00321-AWA-DEM Document 58 Filed 11/13/24 Page 5 of 5 PagelD# 559
`
`
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`5
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