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Case 3:24-cv-00540-MHL Document 28 Filed 10/11/24 Page 1 of 4 PageID# 277
`
`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
`
`
`
`
`
`
`NOTICE OF WITHDRAWAL OF 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 withdraws its Consent Motion to Extend Time for Plaintiff to Respond to
`
`Defendant’s Motion to Dismiss Plaintiff’s Complaint Under Rule 12(b)(6) (“MTE”) in this
`
`lawsuit.
`
`Plaintiff states as follows:
`
`1.
`
`2.
`
`Plaintiff filed the MTE (D.I. 26) on October 10, 2024.
`
`The MTE requested a one (1) business day extension for Plaintiff’s response to
`
`Defendant’s Motion to Dismiss (D.I. 16) (“MTD”) and Defendant’s anticipated reply to
`
`accommodate the availability of Plaintiff’s counsel and filing support staff.
`
`
`
`

`

`Case 3:24-cv-00540-MHL Document 28 Filed 10/11/24 Page 2 of 4 PageID# 278
`
`3.
`
`Plaintiff filed its Opposition (D.I. 27) to the MTD on October 11, 2024, thereby
`
`meeting the original deadline for filing its response.
`
`4.
`
`As of the filing of Plaintiff’s Opposition and this Notice, the Court has not yet
`
`ruled on the MTE.
`
`5.
`
`As Plaintiff met the original filing deadline for its response to Defendant’s MTD,
`
`the MTE is no longer necessary. Plaintiff hereby withdraws the MTE.
`
`Respectfully submitted,
`
`Dated: October 11, 2024
`
`
`
`
`
`
`
` 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
`
`2
`
`

`

`Case 3:24-cv-00540-MHL Document 28 Filed 10/11/24 Page 3 of 4 PageID# 279
`
`CERTIFICATE OF SERVICE
`
`
`
`I certify that on October 11, 2024, I electronically filed the foregoing Notice of
`
`Withdrawal of 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
`
`3
`
`

`

`Case 3:24-cv-00540-MHL Document 28 Filed 10/11/24 Page 4 of 4 PageID# 280
`Case 3:24-cv-00540-MHL Document 28 Filed 10/11/24 Page 4 of 4 PagelD# 280
`
`
`
`4
`
`

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