`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`Richmond Division
`
`
`SOUNDCLEAR TECHNOLOGIES LLC,
`
`
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`
`
`
`
`
`
`
`
`
`
`
`Civil Action No. 3:24-cv-00540 (MHL)
`
`Defendant.
`
`
`CONSENT MOTION FOR EXTENSION OF TIME FOR GOOGLE LLC TO FILE
`RESPONSIVE PLEADINGS TO COMPLAINT AND MEMORANDUM IN SUPPORT
`
`
`
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`Defendant Google LLC (“Google”), by counsel, by special appearance, and without
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`waiving any jurisdiction, venue, or other challenges, moves this Court for an extension of time
`
`through September 30, 2024, to answer, plead, claim, move or otherwise respond to the Complaint
`
`filed by SoundClear Technologies LLC (“SoundClear”), and in support thereof states as follows:
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`
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`1.
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`On July 25, 2024, SoundClear filed its Complaint for patent infringement against
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`Google (ECF No. 1). On or about July 31, 2024, SoundClear served its Complaint upon Google’s
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`registered agent.
`
`
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`2.
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`Under Rule 12 of the Federal Rules of Civil Procedure, Google’s responsive
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`pleadings are not due until August 21, 2024.
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`
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`3.
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`Google has requested and SoundClear has agreed to allow Google an extension of
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`time through and including September 30, 2024, for Google to answer, plead, claim, move or
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`otherwise respond to the Complaint filed by SoundClear. The proposed extension is necessary to
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`allow Google to investigate the matter and will not cause delay or prejudice to either party.
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`
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`
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`Case 3:24-cv-00540-MHL Document 12 Filed 08/09/24 Page 2 of 3 PageID# 126
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`4.
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`Attached as Exhibit 1 is a proposed agreed order granting Google an extension of
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`time through and September 30, 2024, to answer, plead, claim, move or otherwise respond to the
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`Complaint filed by SoundClear.
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`
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`5.
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`Under this Court’s Standing Order and because the parties have consented to this
`
`motion, no hearing will be requested. Should the Court deem a hearing necessary, the parties will
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`appear before the Court on an appropriate date.
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`
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`WHEREFORE, Google, by counsel, requests that this Court enter the attached proposed
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`agreed order granting Google an extension of time through and including September 30, 2024, to
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`answer, plead, claim, move or otherwise respond to the Complaint.
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`
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`Dated: August 9, 2024
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`
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`
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`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
`
`Counsel for Google LLC
`
`
`
`2
`
`
`
`Case 3:24-cv-00540-MHL Document 12 Filed 08/09/24 Page 3 of 3 PageID# 127
`
`
`
`CERTIFICATE OF SERVICE
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`I hereby certify that on August 9, 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:
`
`Kevin H. Sprenger (VSB No. 98588)
`Ramachandran Iyer (VSB No. 94100)
`DAIGNAULT IYER LLP
`8229 Boone Boulevard, Suite 450
`Vienna, VA 22182
`Telephone: (703) 712-1145
`ksprenger@daignaultiyer.com
`cbiyer@daignaultiyer.com
`
`Counsel for SoundClear Technologies LLC
`
`
`
`
`22744268.v2
`
`
`
` /s/ Stephen E. Noona
`
`Stephen E. Noona (VSB No. 25367)
`KAUFMAN & CANOLES, P.C.
`150 West Main Street, Suite 2100
`Norfolk, VA 23510
`Telephone: (757) 624-3239
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`
`Counsel for Google LLC
`
`
`
`3
`
`
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