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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`NORFOLK DIVISION
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`SOUNDCLEAR TECHNOLOGIES LLC,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`Case No. 2:24-cv-00321-AWA-DEM
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`JURY TRIAL DEMANDED
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`PLAINTIFF SOUNDCLEAR’S MOTION TO CONDUCT VENUE DISCOVERY
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`Plaintiff SoundClear Technologies, LLC (“SoundClear”), by its counsel, respectfully
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`moves this Court, pursuant to Rule 26 of the Federal Rules of Civil Procedure and the Court’s
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`inherent authority over discovery, for an Order granting it leave to conduct limited venue-based
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`discovery. The grounds for this motion are fully set forth in SoundClear’s Memorandum in
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`Support of its Motion for Venue Discovery, which is filed contemporaneously herewith.
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`Dated: January 23, 2025
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`Respectfully submitted,
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`By: /s/ Chandran B. Iyer
`Ronald M. Daignault (pro hac vice)*
`Chandran B. Iyer (VA Bar No. 94100)
`Steven J. Reynolds (pro hac vice)*
`Hoda Rifai-Bashjawish (pro hac vice)*
`Kevin H. Sprenger (VA Bar No. 98588)
`Austin Ciuffo (pro hac vice)*
`Matthew R. Harkins (pro hac vice)*
`James Hatton (pro hac vice)*
`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`sreynolds@daignaultiyer.com
`hrifai-bashjawish@daignaultiyer.com
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`1
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`Case 2:24-cv-00321-AWA-DEM Document 69 Filed 01/23/25 Page 2 of 3 PageID# 1303
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`ksprenger@daignaultiyer.com
`aciuffo@daignaultiyer.com
`mharkins@daignaultiyer.com
`jhatton@daignaultiyer.com
`DAIGNAULT IYER LLP
`8229 Boone Boulevard – Suite 450
`Vienna, VA 22182
`Tel.: (202) 330-1666
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`Attorneys for Plaintiff SoundClear Technologies
`LLC
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`*Not admitted to practice in Virginia
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`2
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`Case 2:24-cv-00321-AWA-DEM Document 69 Filed 01/23/25 Page 3 of 3 PageID# 1304
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`CERTIFICATE OF SERVICE
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`I certify that on January 23, 2025, I electronically filed the foregoing with the Clerk of
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`Court using the CM/ECF system, which will then send a notification of such filing (NEF) to all
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`counsel of record.
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`
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`By:
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`/s/ Chandran B. Iyer
`Chandran B. Iyer (VA Bar No. 94100)
`cbiyer@daignaultiyer.com
`DAIGNAULT IYER LLP
`8229 Boone Boulevard – Suite 450
`Vienna, VA 22182
`Tel.: (202) 330-1666
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`Attorney for Plaintiff SoundClear Technologies LLC
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`3
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