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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ORCA SECURITY LTD.,
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`v.
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`WIZ, INC.,
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`Plaintiff,
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`Defendant.
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`
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`C.A. No. 23-758 (JLH)
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`JOINT MOTION FOR TELECONFERENCE TO RESOLVE DISCOVERY DISPUTES
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`Pursuant to Section 8(g) of the Scheduling Order (D.I. 33, D.I. 90) and
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`Section 3(a)(iii) of the Stipulation and Order Regarding Discovery of Electronically Stored
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`Information (D.I. 71), Plaintiff Orca Security Ltd. and Defendant Wiz, Inc. respectfully move this
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`Court to schedule a teleconference to address the following disputes about electronic discovery.
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`Plaintiff Orca Security Ltd.’s Issue(s) For Teleconference:
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`1.
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`Defendant’s objections to Orca’s proposed ESI search term: (((cloud w/5 (native
`OR security)) OR platform) w/15 (invest* OR profit* OR fund* OR venture OR
`market* OR demand OR compet* OR financ* OR revenue* OR sale* OR
`purchase* OR acqui* OR merg* OR cost* OR startup OR project* OR forecast*
`OR seed OR “series a” OR “series b” OR margin* OR milestone* OR price* OR
`pricing OR calculat* OR discount*))
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`The following attorneys, including at least one Delaware Counsel and at least one
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`Lead Counsel per party, participated in one or more verbal meet-and-confers by telephone on the
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`following dates: July 2, 5, 12, 15, and 17, 2024.
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`Delaware Counsel:
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`Orca: Rodger Smith (Morris, Nichols, Arsht & Tunnell);
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`Wiz: Christine Haynes, Fred Cottrell, Kelly Farnan,
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`and
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`Gabriela Monasterio (Richards, Layton & Finger)
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`Case 1:23-cv-00758-JLH Document 108 Filed 07/19/24 Page 2 of 2 PageID #: 2184
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`Lead Counsel:
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`Orca: Blake Davis, Chris Henry, Krissy McKenna, Ryan Banks,
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`Lucas Lonergan, Nicole Bruner, and Peter Hoffman (Latham & Watkins);
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`Wiz: Caty Lacey, Lisa Zang, Praatika Prasad, and Callie Davidson
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`(Wilson Sonsini)
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`The parties are available for a teleconference on September 11, 2024 at 3:00 pm
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`ET, i.e., the date and time the Court set for a teleconference to resolve other discovery
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`disputes (D.I. 95), or will otherwise make themselves available at the Court’s convenience.
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`
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`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
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`/s/ Rodger D. Smith II
`___________________________________
`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`Cameron P. Clark (#6647)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`rsmith@morrisnichols.com
`cclark@morrisnichols.com
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`Attorneys for Plaintiff
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`July 19, 2024
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`RICHARD, LAYTON & FINGER, P.A.
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`/s/ Christine D. Haynes
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`Frederick L. Cottrell, III (#2555)
`Kelly E. Farnan (#4395)
`Christine D. Haynes (#4697)
`One Rodney Square
`920 North King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`farnan@rlf.com
`haynes@rlf.com
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`Attorneys for Defendant
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