`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`AQUA CONNECT, INC. a Nevada corporation,
`and STRATEGIC TECHNOLOGY PARTNERS,
`LLC, a Nevada limited liability company,
`
`Plaintiffs,
`
`v.
`
`TEAMVIEWER US, LLC,
`
`VB Assets, LLC,,
`
`Defendant.
`
`Plaintiff,
`
`v.
`Amazon.com, Inc.; Amazon.com LLC; Amazon
`Web Services, Inc.; A2Z Development Center,
`Inc. d/b/a Lab126; Rawles LLC; AMZN Mobile
`LLC; AMZN Mobile 2 LLC; Amazon.com
`Services, Inc. f/k/a Amazon Fulfillment Services,
`Inc.; and Amazon Digital Services LLC,
`Defendant.
`
`C.A. No. 18-01572-MN
`
`C.A. No. 19-1410-MN
`
`JOINT REQUEST TO CONVERT HEARING FROM IN-PERSON
`TO REMOTE PROCEEDING
`Pursuant to the July 9, 2020 Order (D.I. 132, C.A. No. 18-1572-MN; D.I. 47, C.A. No.
`
`19-1410-MN), the Court has set an Omnibus Hearing for August 20, 2020 at 10:00 a.m. on two
`
`motions: Motion for Judgment on the Pleadings (D.I. 71 in C.A. No. 18-1572-MN); and Motion
`
`to Dismiss for Failure to State a Claim (D.I. 25 in C.A. No. 19-01410-MN).
`
`The parties have conferred regarding on-going concerns with COVID-19, and the parties
`
`(other than VB Assets, LLC, the plaintiff in C.A. No. 19-01410-MN, which does not oppose the
`
`request) respectfully request that the in-person hearing be converted to a remote hearing. Several
`
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`EAST\175863180.1
`
`
`
`Case 1:19-cv-01410-MN Document 49 Filed 08/13/20 Page 2 of 3 PageID #: 1042
`
`counsel would need to travel from as far away as California; and, given concerns related to
`
`interstate travel, the parties believe a remote proceeding is prudent under the circumstances.
`
`The parties propose, subject to the Court’s approval, to conduct the August 20, 2020
`
`Omnibus Hearing via Zoom videoconference using the credentials provided below
`
`https://fenwick.zoom.us/j/95719394157?pwd=QXY0Z21wSmN1RHQwblM2Z3lDUGZ
`GQT09
`
`Meeting ID: 920 4915 2565
`Password: 040177
`
`The proceeding would also be accessible via telephone with the following dial-in credentials:
`
`US Toll-free Telephone: (888) 788-0099
`Meeting ID: 920 4915 2565
`Password: 040177
`
`If this format is acceptable, Counsel will open the conference 15 minutes prior to the hearing.
`
`We are available at the Court’s convenience to discuss this matter further and appreciate
`
`Your Honor’s consideration of this request.
`
`Dated: August 14, 2020
`
`STAMOULIS & WEINBLATT LLC
`
`DLA PIPER LLP (US)
`
`/s/ Stamatios Stamoulois
`Stamatios Stamoulois (DE Bar No. 4606)
`Richard C. Weinblatt (DE Bar No. 5080)
`Two Fox Point Centre
`6 Denny Road, Suite 307
`Wilmington, DE 19809
`Tel: (302) 999-1540
`Stamoulis@swdelaw.com
`Weinblatt@swdelaw.com
`
`Attorneys for Plaintiffs Aqua Connect, Inc.
`and Strategic Technology Partners, LLC
`
`
`/s/ Brian A. Biggs
`Denise S. Kraft (DE Bar No. 2778)
`Brian A. Biggs (DE Bar No. 5591)
`Erin E. Larson (DE Bar No. 6616)
`1201 North Market Street, Suite 2100
`Wilmington, DE 19801
`Telephone: (302) 468-5700
`Facsimile: (302 394-2341
`denise.kraft@us.dlapiper.com
`brian.biggs@us.dlapiper.com
`erin.larson@us.dlapiper.com
`
`Attorneys for Defendants TeamViewer US,
`LLC and TeamViewer GmbH
`
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`EAST\175863180.1
`
`
`
`Case 1:19-cv-01410-MN Document 49 Filed 08/13/20 Page 3 of 3 PageID #: 1043
`
`WILSON SONSINI GOODRICH &
`ROSATI
`
`ASHBY & GEDDES
`
`/s/ Ian R. Liston
`Ian R. Liston (DE Bar I.D. 5507)
`222 Delaware Avenue
`Suite 800
`Wilmington, DE 19801
`Telephone: (302) 304-7600
`Facsimile: (866) 974-7329
`Iliston@wsgr.com
`
`Attorneys for Plaintiff VB Assets, LLC
`
`
`/s/ Andrew C. Mayo
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`
`Counsel for Defendants Amazon.com,
`Inc., Amazon.com LLC, Amazon Web
`Services, Inc., A2Z Development
`Center, Inc. d/b/a Lab126, AMZN
`Mobile LLC, AMZN Mobile 2 LLC,
`Amazon.com Services, Inc. f/k/a
`Amazon Fulfillment Services, Inc.,
`and Amazon Digital Services LLC
`
`{01596052;v1 }
`EAST\175863180.1
`
`
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