`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`RICHMOND DIVISION
`
`SOUNDCLEAR TECHNOLOGIES, LLC,
`
` v.
`
`GOOGLE LLC,
`
`
`Plaintiff,
`
`Defendant.
`
`Case No. 3:24-cv-00540-MHL
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`CONSENT MOTION TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO
`DEFENDANT’S MOTION TO DISMISS PLAINTIFF’S COMPLAINT
`UNDER RULE 12(b)(6)
`
`Plaintiff SoundClear Technologies, LLC (“Plaintiff”), by its counsel, pursuant to Local
`
`Rule 7, hereby moves the Court for a one (1) business day extension of time for Plaintiff to
`
`respond to Defendant’s Motion to Dismiss Plaintiff’s Complaint Under Rule 12(b)(6) (“MTD”)
`
`in this lawsuit. In support of this Motion, Plaintiff states as follows:
`
`1.
`
`2.
`
`Defendant filed the MTD on September 30, 2024.
`
`Plaintiff’s response to the MTD is currently due on Friday October 11, 2024.
`
`Thus, the time for responding to the MTD has not yet passed.
`
`3.
`
`This is a lawsuit for patent infringement involving three patents relating to
`
`systems and methods for controlling voice and other output content from electronic devices, and
`
`
`
`Case 3:24-cv-00540-MHL Document 26 Filed 10/10/24 Page 2 of 4 PageID# 198
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`systems and methods for controlling touch panel devices. The MTD raises issues that implicate
`
`all three patents.
`
`4.
`
`Plaintiff has conferred with Defendant about this motion. Defendant does not
`
`oppose the extension. Both parties agree that the proposed one (1) business day extension for
`
`Plaintiff’s response and Defendant’s reply is necessary to accommodate the availability of
`
`Plaintiff’s counsel and filing support staff.
`
`5.
`
`A one (1) business day extension of Plaintiff’s time in which to respond to the
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`MTD would make Plaintiff’s response due on Tuesday October 15, 2024 (in view of the
`
`Columbus Day court holiday on Monday October 14th).
`
`6.
`
`Plaintiff has agreed to Defendant’s request for a reciprocal one (1) business day
`
`extension for Defendant’s anticipated reply brief. That would make Defendant’s reply brief due
`
`on Tuesday October 22, 2024.
`
`7.
`
`No extension of time has previously been sought for responding to the MTD. This
`
`request for an extension of time is not made for the purpose of delay. A one (1) business day
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`extension will not materially change any other pretrial deadline and will not affect the Court’s
`
`administration of this matter.
`
`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 MTD to
`
`and through October 15, 2024, with Defendant’s reply brief due October 22, 2024.
`
`2
`
`
`
`Case 3:24-cv-00540-MHL Document 26 Filed 10/10/24 Page 3 of 4 PageID# 199
`
`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: October 10, 2024
`
`
`
`
`
`3
`
`
`
`Case 3:24-cv-00540-MHL Document 26 Filed 10/10/24 Page 4 of 4 PageID# 200
`
`CERTIFICATE OF SERVICE
`
`
`
`I certify that on October 10, 2024, I electronically filed the foregoing Consent Motion to
`
`Extend Time for Plaintiff to Respond to Defendant’s Motion to Dismiss Plaintiff’s Complaint
`
`Under Rule 12(b)(6) 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
`
`
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