Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 1 of 14 PageID#
`1967
`
`
`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.
`
`GOOGLE LLC’S RESPONSE TO SOUNDCLEAR TECHNOLOGIES, LLC’S
`OBJECTIONS TO THE MAGISTRATE JUDGE’S ORDER REGARDING MOTION TO
`CONDUCT VENUE DISCOVERY (DKT. 78)
`
`
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 2 of 14 PageID#
`1968
`
`TABLE OF CONTENTS
`
`
`Page
`
`
`GOOGLE LLC’S RESPONSE TO SOUNDCLEAR TECHNOLOGIES, LLC’S OBJECTIONS
`TO THE MAGISTRATE JUDGE’S ORDER REGARDING MOTION TO CONDUCT
`VENUE DISCOVERY (DKT. 78) ................................................................................................. 1
`
`I.
`
`II.
`
`III.
`
`IV.
`
`INTRODUCTION .......................................................................................................................... 1
`
`PROCEDURAL BACKGROUND ................................................................................................. 3
`
`THE STANDARD OF REVIEW ................................................................................................... 3
`
`SOUNDCLEAR OFFERS NO BASIS UNDER RULE 72(A) TO SET ASIDE
`MAGISTRATE JUDGE MILLER’S RULING .............................................................................. 4
`
`A.
`
`B.
`
`C.
`
`Magistrate Judge Miller Appropriately Addressed SoundClear’s Circular
`Argument About “Opinion” Testimony ............................................................................. 4
`
`Google Did Not Waive Privilege Concerning the Communications Between
`Outside Counsel and Google for the Investigation ............................................................ 6
`
`Magistrate Judge Miller Did Not Exceed the Scope of his Referral .................................. 8
`
`V.
`
`CONCLUSION ............................................................................................................................... 9
`
`
`
`
`
`
`
`
`-i-
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`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 3 of 14 PageID#
`1969
`
`
`TABLE OF AUTHORITIES
`
`
`
`Page(s)
`
`Cases
`
`Attard Indus. v. U.S. Fire Ins. Co.,
`No. 1:10-cv-121, 2010 U.S. Dist. LEXIS 80785 (E.D. Va. Aug. 5, 2010) ........................................ 3, 4
`
`Bruce v. Hartford,
`21 F. Supp. 3d 590 (E.D. Va. 2014) ....................................................................................................... 3
`
`CertusView Techs., LLC v. S&N Locating Servs., LLC,
`107 F. Supp. 3d 500 (E.D. Va. 2015) ..................................................................................................... 4
`
`Connelly v. Volkswagen Group of America, Inc.,
`No. 1:19-cv-1487, 2023 U.S. Dist. LEXIS 197929 (E.D. Va. Nov. 3, 2023) ........................................ 5
`
`In re EchoStar Communications Corp.,
`448 F.3d 1294 (Fed. Cir. 2006). ............................................................................................................. 8
`
`HSBC Bank USA, N.A. v. Resh,
`No. 3:12-cv-00668, 2014 U.S. Dist. LEXIS 10176 (S.D. W. Va. Jan. 28, 2014) .................................. 3
`
`Malibu Media, LLC v. John Does 1-23,
`878 F. Supp. 2d 628 (E.D. Va. 2012) ..................................................................................................... 4
`
`Monarch Networking Sols. LLC v. Juniper Networks, Inc.,
`No. 1:23-cv-670, 2023 U.S. Dist. LEXIS 237871 (E.D. Va. Oct. 3, 2023) ............................... 2, 6, 7, 8
`
`In re Royal Ahold N.V. Sec. & ERISA Litig.,
`230 F.R.D. 433 (D. Md. 2005) ............................................................................................................... 8
`
`United States v. Jones,
`696 F.2d 1069 (4th Cir. 1982) ................................................................................................................ 8
`
`United States v. U.S. Gypsum Co.,
`333 U.S. 364 (1948) ............................................................................................................................... 3
`
`Other Authorities
`
`Fed. R. Civ. P. 72(a) ..................................................................................................................................... 3
`
`
`
`
`
`
`
`
`-ii-
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`
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 4 of 14 PageID#
`1970
`
`
`I.
`
`INTRODUCTION
`
`The Court received 80 pages of briefing on SoundClear’s motion for venue discovery, held
`
`a hearing, understood and considered the parties’ arguments, and made the correct ruling.
`
`Magistrate Judge Miller held that “[a]bsent any facts suggesting Google misrepresented its
`
`findings,” there is “no reason to conduct discovery on the methods of Google’s investigation . . . .”
`
`See Mem. Order, Dkt. 78 at 3 (“Order”). SoundClear concedes that there are no such facts. Pl.’s
`
`Objs. to Mag. J. Mem. Order, Dkt. 82 at 10 (“Objs.”). The Court found that “the information
`
`Plaintiff requests would not necessarily alter the outcome of the Motion to Transfer Venue” where
`
`the record is already replete with 674 pages of exhibits. Id. SoundClear also acknowledges that
`
`Google has already provided answers to the questions SoundClear would seek in venue discovery.
`
`Transcript regarding Hearing on Motion for Venue Discovery, Dkt. 82-1 (“Hr’g Tr.”) at 6:2-6. The
`
`Court found SoundClear’s questions themselves to be “circular” and subsequently concluded
`
`venue discovery was not warranted. See id. at 6:7-19. The well-reasoned decision is neither
`
`erroneous nor contrary to law and should be affirmed.
`
`Ignoring all that, SoundClear accuses Magistrate Judge Miller of not addressing its main
`
`point, which is a convoluted argument that the Google declarations contain opinions, and
`
`SoundClear wants to explore the foundation for those opinions. SoundClear even misleadingly
`
`implies the Court adopted SoundClear’s argument that Google’s declarants were offering
`
`opinions. See Objs. 10 (SoundClear claiming that “[t]he Court acknowledged that characterizations
`
`based upon an investigation may be opinions”). But, in reality, the Court considered and properly
`
`rejected SoundClear’s argument because the declarations include only factual testimony. See
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`Order 2-3; Hr’g Tr. 5:6-11 (“[B]ut the declarants themselves are not offering statements of
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`opinion[.]”). SoundClear admits it does not seek to ask questions attempting to rebut any of the
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`facts presented by Google’s declarants. Objs. 10.
`
`1
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`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 5 of 14 PageID#
`1971
`
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`SoundClear further unfairly accuses Magistrate Judge Miller of provoking Google’s
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`outside counsel into a subject-matter waiver of privilege during argument and acting outside the
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`scope of his statutory authority because he read the underlying motion to transfer briefing. All of
`
`this is nonsense. Magistrate Judge Miller clearly understood the facts and the law, acted within the
`
`scope of his referral, and rendered the correct decision. And Google did not waive privilege.
`
`SoundClear’s objection is not just an attack on Magistrate Judge Miller; it is an attack on
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`Google’s outside counsel. Boiled down, SoundClear’s argument is that Google’s outside counsel
`
`fraudulently instructed Google to identify only employees who live in the preferred transferee
`
`district. As counsel admitted during the hearing, SoundClear has no basis to make such an
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`egregious accusation yet believes it should be permitted to conduct venue discovery to explore this
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`unsubstantiated and unwarranted accusation against counsel. Objs. 7. As the Court stated,
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`“SoundClear has offered nothing beyond . . . bare allegations and conclusory assertions that it
`
`believes Google did not provide all of the teams involved in the accused products.” Order 2
`
`(internal quotations omitted). Magistrate Judge Miller’s ruling is consistent with applicable law:
`
`as stated in Monarch, “[p]ermitting discovery (or discrediting evidence) because one party lacks
`
`equal access to information would either unduly delay resolution of venue or else leave a court
`
`devoid of evidence.” Monarch Networking Sols. LLC v. Juniper Networks, Inc., No. 1:23-cv-670,
`
`2023 U.S. Dist. LEXIS 237871, at *19 (E.D. Va. Oct. 3, 2023). Despite SoundClear’s contrary
`
`assertions (Objs. 3 n.1), Monarch controls this matter. SoundClear cites no law and has no facts to
`
`support its arguments.
`
`The Court exercised its discretion based on settled law and denied SoundClear’s request
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`for venue discovery. SoundClear’s objection should be overruled, and Magistrate Judge Miller’s
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`recommendation should be adopted in full.
`
`2
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`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 6 of 14 PageID#
`1972
`
`
`II.
`
`PROCEDURAL BACKGROUND
`
`On November 4, 2024, Google filed a motion to transfer. Dkt. 38. As Magistrate Judge
`
`Miller noted, that briefing resulted in 674 pages of factual record available to this Court to
`
`determine whether to transfer this case. See Hr’g Tr. 3:24-4:9. In opposing Google’s motion to
`
`transfer, SoundClear argued it should be awarded venue discovery. Dkt. 61 at 9-10. Then, after
`
`briefing on the motion to transfer closed, SoundClear filed a separate motion for venue discovery.
`
`Dkt. 69. The Court referred SoundClear’s motion for venue discovery to Magistrate Judge Miller,
`
`who held a hearing on March 5, 2025. After reading all of the briefing and hearing argument,
`
`Magistrate Judge Miller held that there is “no basis to permit venue discovery” and denied
`
`SoundClear’s motion. Order 4.
`
`III.
`
`THE STANDARD OF REVIEW
`
`Rule 72(a) empowers a district court to overturn a magistrate judge’s ruling only when part
`
`of the order is (1) clearly erroneous; or (2) contrary to law. Fed. R. Civ. P. 72(a). For factual
`
`findings, a “finding is ‘clearly erroneous’ when although there is evidence to support it, the
`
`reviewing court on the entire evidence is left with the definite and firm conviction that a mistake
`
`has been committed.” United States v. U.S. Gypsum Co., 333 U.S. 364, 395 (1948); see also Attard
`
`Indus. v. U.S. Fire Ins. Co., No. 1:10-cv-121, 2010 U.S. Dist. LEXIS 80785, at *4 (E.D. Va. Aug.
`
`5, 2010).
`
`Clearly erroneous and contrary to law are not synonymous standards. See HSBC Bank USA,
`
`N.A. v. Resh, No. 3:12-cv-00668, 2014 U.S. Dist. LEXIS 10176, at *18-19 (S.D. W. Va. Jan. 28,
`
`2014). “For questions of law there is no practical difference between review under Rule 72(a)’s
`
`contrary to law standard and [a] de novo standard.” Bruce v. Hartford, 21 F. Supp. 3d 590, 594
`
`(E.D. Va. 2014) (alteration in original). Therefore, a magistrate judge’s order is contrary to law
`
`when the order “fails to apply or misapplies relevant statutes, case law, or rules of procedure.”
`
`3
`
`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 7 of 14 PageID#
`1973
`
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`Attard Indus., 2010 U.S. Dist. LEXIS 80785, at *5 (citation omitted). As a result, the clearly
`
`erroneous standard applies when reviewing the factual portions of the Magistrate Judge’s order
`
`while contrary-to-law applies when reviewing legal conclusions. However, regardless of whether
`
`considering a legal or factual issue, “altering a magistrate judge’s non-dispositive orders is
`
`‘extremely difficult to justify’” and courts in this district have afforded magistrate judges broad
`
`deference. CertusView Techs., LLC v. S&N Locating Servs., LLC, 107 F. Supp. 3d 500, 504 (E.D.
`
`Va. 2015) (Davis, J.) (cleaned up); Malibu Media, LLC v. John Does 1-23, 878 F. Supp. 2d 628,
`
`629 (E.D. Va. 2012) (Hilton, J.) (citation omitted).
`
`IV.
`
`SOUNDCLEAR OFFERS NO BASIS UNDER RULE 72(A) TO SET ASIDE
`MAGISTRATE JUDGE MILLER’S RULING
`
`SoundClear does not meet the strict standard for overturning a magistrate judge’s ruling.
`
`SoundClear identifies no finding in Magistrate Judge Miller’s Order that was “clearly erroneous,”
`
`and fails to identify a single error of law. Instead, SoundClear (A) wrongly claims that Magistrate
`
`Judge Miller did not address “the lay opinion issue,” (B) asserts that Google waived privilege, and
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`(C) accuses Magistrate Judge Miller of exceeding the scope of his statutory authority by making
`
`rulings on the motion to transfer.
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`None of the foregoing actually occurred. The Court appropriately considered the parties’
`
`arguments and denied pointless venue discovery.
`
`A. Magistrate Judge Miller Appropriately Addressed SoundClear’s
`Circular Argument About “Opinion” Testimony
`
`SoundClear asserts that the Court failed to address whether venue discovery is warranted
`
`because SoundClear wants to explore the foundation for supposed opinions offered by the Google
`
`declarants on what is relevant to this case. SoundClear attacks counsel without more, claiming it
`
`is “inconceivable that Google paid expensive, outside, New York-based litigation counsel to
`
`participate in a purely objective exercise.” Objs. 7. SoundClear further attacks Magistrate Judge
`
`4
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`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 8 of 14 PageID#
`1974
`
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`Miller, suggesting when confronted with SoundClear’s argument, he “pivoted, confusingly, to an
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`unrelated matter.” See Objs. 11.
`
`But the Court addressed SoundClear’s erroneous arguments. The Court and SoundClear’s
`
`attorney had an extensive back and forth on whether Google’s declarations stating which teams
`
`are “relevant” amounted to an opinion. See Hr’g Tr. 4:10-9:7. SoundClear implies the Court
`
`adopted SoundClear’s argument that Google’s declarants were offering opinions when the Court
`
`in fact rejected SoundClear’s argument. Compare Objs. 10 (SoundClear claiming that “[t]he Court
`
`acknowledged that characterizations based upon an investigation may be opinions”) with Order 2-
`
`3; Hr’g Tr. 5:6-11 (“[B]ut the declarants themselves are not offering statements of opinion[.]”).
`
`The Court further found that SoundClear’s proposed venue discovery exploring the basis of the
`
`alleged relevancy opinions to be “circular,” as SoundClear determined relevancy in its complaint
`
`by identifying specific products and features as infringing. Hr’g Tr. 6:7-9. Far from ignoring it,
`
`the Court thoroughly considered and rejected SoundClear’s argument.
`
`This situation is like Connelly v. Volkswagen Group of America, Inc., where the plaintiffs
`
`attempted to argue that the Court’s failure to consider and subsequently reject one of plaintiff’s
`
`arguments in writing amounted to clear error. No. 1:19-cv-1487 (RDA/IDD), 2023 U.S. Dist.
`
`LEXIS 197929, at *13 (E.D. Va. Nov. 3, 2023). This Court rejected that argument as flawed and
`
`disingenuous because during the hearing, the Magistrate Judge “specifically addressed the
`
`arguments.” Id. The same is true here. SoundClear cannot show, based on the transcript of the
`
`proceedings, that the Court did not consider SoundClear’s argument on “opinion” testimony. As
`
`SoundClear notes, the Court’s “Order incorporates the findings and conclusions rendered at the
`
`hearing.” Objs. 9; Order 1 (“The court heard oral argument on the motion, and for the reasons
`
`stated on the record and briefly explained below, DENIES SoundClear’s Motion to Conduct Venue
`
`5
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 9 of 14 PageID#
`1975
`
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`Discovery.”).
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`In light of the Court correctly finding that SoundClear’s “opinion testimony” argument
`
`does not hold water, SoundClear’s remaining arguments amount to thinly veiled allegations of
`
`fraud. Objs. 7. SoundClear obfuscates on this issue because it has no basis to assert fraud. Any
`
`assertions of bad-faith on Google’s part are hypothetical and speculative. See Hr’g Tr. 7:14-8:6.
`
`Again, the court’s ruling in Monarch is directly applicable to the facts at hand. Monarch, 2023
`
`U.S. Dist. LEXIS 237871, at *19.
`
`B.
`
`Google Did Not Waive Privilege Concerning the Communications
`Between Outside Counsel and Google for the Investigation
`
`SoundClear asserts that by answering Magistrate Judge Miller’s question during argument,
`
`Google waived privilege for subject matter relating to “the way Google’s outside litigation counsel
`
`conducted its investigation.” Objs. 7. As an initial matter, this Court need not even reach this issue.
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`As SoundClear conceded, no facts suggest that Google misrepresented its findings. Order 2-3.
`
`Magistrate Judge Miller recognized that “resolution of motions to transfer venue . . . necessarily
`
`require a court to rely on parties accurately to disclose the facts underlying the motions they file
`
`as most, if not all, of the relevant facts are [often] exclusively controlled by one of the parties.”
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`Order 3 (quoting Monarch, 2023 U.S. Dist. LEXIS 237871, at *19). And the Court was clear that
`
`the information SoundClear requested “would not necessarily alter the outcome of the Motion to
`
`Transfer Venue.” Id. at 3-4. Accordingly, the details of Google’s investigation–whether privileged
`
`or not–are immaterial to the motion to transfer.
`
`Regardless, Google did not waive privilege. The investigation involved attorney client
`
`communications and was performed at the direction of counsel for the purpose of litigation.
`
`SoundClear argues that privilege was waived when Google responded to the Court’s question
`
`asking whether Google attempted to “tilt the scale” in favor of transfer when it “went looking for
`
`6
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 10 of 14 PageID#
`1976
`
`
`people working on the product.” Hr’g Tr. 10:12-15. The answer is “no.” Id. at 10:18. In so
`
`answering, Google’s counsel confirmed that no fraud was committed. Google then simply stated
`
`that it asked engineers to aid in supporting where individuals are located, as required by Monarch.
`
`Hr’g Tr. 10:21-11:5. Monarch, 2023 U.S. Dist. LEXIS 237871, at *19 (“The only ‘reliable
`
`information’ to make such a determination typically comes ‘in affidavit form’ based on facts
`
`exclusively controlled by one party.”).
`
`In concocting this thinly constructed waiver argument, SoundClear ignores that the
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`information provided in Google’s response was already presented in the transfer briefing (Hr’g Tr.
`
`10:18-23) and the declarations (id. at 11:4-5) themselves, which Google made clear in its response
`
`to the Court’s question at the hearing. In particular, Google explained that SoundClear, not Google,
`
`determined what was relevant when it defined the accused functionalities in its complaint. Hr’g
`
`Tr. 10:20-23; Dkt. 71 at 2-3, 9. In its motion to transfer, Google recited what it understood the
`
`accused functionalities to be with cites to the complaint. Dkt. 57-1 at 2-9. SoundClear has never
`
`claimed that Google misstated, misunderstood, or omitted relevant accused functionality. Then,
`
`Google identified individuals with material information based on the accused functionalities. See
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`id. at 5-9 (mapping each person to their knowledge about accused functionalities with citations to
`
`the complaint). As is clear from the declarations filed in support of the motion to transfer, the
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`declarants identified what material information those employees have and where they are located,
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`regardless of whether they were in California, Virginia, or elsewhere. Id. Because these facts,
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`which are clear from the motion to transfer briefing, were merely recited at the hearing, no
`
`privileged information was disclosed.
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`Google simply confirmed that its investigation proceeded exactly as courts in this district
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`require–by seeking declarations about the location of likely witnesses with material information.
`
`7
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`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 11 of 14 PageID#
`1977
`
`
`It is unclear how Google could submit declarations without asking declarants to provide them.
`
`Monarch, 2023 U.S. Dist. LEXIS 237871, at *19. Accordingly, this minimal disclosure is not
`
`“inconsistent with maintaining the confidential nature of the attorney-client relationship[.]” United
`
`States v. Jones, 696 F.2d 1069, 1072 (4th Cir. 1982). It was simply a disclosure of steps that
`
`necessarily had to occur to provide the requisite information for a motion to transfer.
`
`Finally, SoundClear’s cited authority does not support its flawed subject matter waiver
`
`argument. The court in In re EchoStar Communications Corp. found that “when EchoStar chose
`
`to rely on the advice of in-house counsel, it waived the attorney-client privilege with regard to any
`
`attorney-client communications relating to the same subject matter . . . .” 448 F.3d 1294, 1299
`
`(Fed. Cir. 2006). No advice of counsel defense is at issue here. In re Royal Ahold N.V. Sec. &
`
`ERISA Litig., 230 F.R.D. 433 (D. Md. 2005) is even less applicable. There, the court considered
`
`whether a public disclosure in the form of SEC filings and other internal reports produced to the
`
`Plaintiffs waived work product protection and did not relate to privileged communications
`
`surrounding the investigation at all. Id. at 437. Unlike here, the produced disclosures “largely”
`
`revealed the underlying work product by “rely[ing] heavily” and “in some instances quot[ing]
`
`from” it. Id. at 436. These facts are completely distinct from Google responding in the negative to
`
`hypothetical allegations of a fraudulent investigation and do not demonstrate a subject matter
`
`waiver.
`
`SoundClear’s privilege waiver argument is not factually or legally supported.
`
`C. Magistrate Judge Miller Did Not Exceed the Scope of his Referral
`
`SoundClear wrongly suggests that the Court made a factual finding related to Google’s
`
`motion to transfer (Objs. 9-10). The Court was explicit: “no one’s asked me to weigh in on the
`
`venue motion, and I am not. But because your motion that I am deciding implicates the briefing
`
`on that motion, I did look at it[.]” Hr’g Tr. 9:9-12.
`
`8
`
`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 12 of 14 PageID#
`1978
`
`
`SoundClear complains that the Court acknowledged that Google has agreed to litigate in
`
`this District in other cases. That acknowledgement was warranted because SoundClear has
`
`repeatedly suggested that Google’s counsel manufactured justifications to not litigate in the
`
`Eastern District of Virginia. See Hr’g Tr. 7:14-8:6 (constructing a “hypothetical” accusing
`
`Google’s counsel–by name–of directing Google to conduct a fraudulent investigation which will
`
`result in declarations that support a motion to transfer to the Northern District of California); Objs.
`
`7 (SoundClear claiming that it would be “inconceivable” that Google’s counsel would engage in
`
`an objective, ethical investigation of where potentially relevant witnesses may reside). Given that
`
`SoundClear has repeatedly pushed the idea that Google likely went to great lengths to manufacture
`
`incomplete declarations, the Court pointed out that Google has agreed to litigate in the Eastern
`
`District of Virginia in other cases, which undermines SoundClear’s imaginary accusations of
`
`fraud. Hr’g Tr. 14:6-14. The Court acted within the scope of its referral and only made findings
`
`when relevant to the motion assigned to it.
`
`V.
`
`CONCLUSION
`
`For the foregoing reasons, SoundClear’s objections to Magistrate Judge Miller’s order
`
`denying their Motion to Conduct Venue Discovery should be overruled.
`
`
`
`
`
`Dated: March 28, 2025
`
`
`
`
`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
`
`
`9
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`

`

`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 13 of 14 PageID#
`1979
`
`
`PAUL HASTINGS LLP
`
`
`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
`
`
`10
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`

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`Case 2:24-cv-00321-AWA-DEM Document 83 Filed 03/28/25 Page 14 of 14 PageID#
`1980
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 28, 2025, 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:
`
`
`Ronald M. Daignault (pro hac vice)
`Chandran B. Iyer (VSB No. 94100)
`Steven J. Reynolds (pro hac vice)
`Shailendra Maheshwari (pro hac vice)
`Kevin H. Sprenger (VSB No. 98588)
`Austin J. Ciuffo (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
`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`sreynolds@diagnaultiyer.com
`smaheshwari@daignaultiyer.com
`ksprenger@daignaultiyer.com
`aciuffo@daignaultiyer.com
`jhatton@daignaultiyer.com
`mharkins@daignaultiyer.com
`
`Counsel for Plaintiff SoundClear Technologies LLC
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` /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
`
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`Counsel for Defendant Google LLC
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