`5812
`M O R R I S , N I C H O L S , A R S H T & T U N N E L L L L P
`1201 NORTH MARKET STREET
`P.O. BOX 1347
`WILMINGTON, DELAWARE 19899-1347
`
`302 658 9200
`302 658 3989 FAX
`
`December 16, 2024
`
`CAMERON P. CLARK
`(302) 351-9187
`(302) 425-3012 FAX
`cclark@morrisnichols.com
`
`The Honorable Jennifer L. Hall
`United States District Court
` for the District of Delaware
`844 North King Street
`Wilmington, DE 19801
`
`VIA ELECTRONIC FILING
`
`Re: Orca Security Ltd. v. Wiz, Inc., C.A. No. 23-0758 (JLH)
`
`Dear Judge Hall:
`
`Plaintiff and Counterclaim D efendant Orca Security Ltd. (“Orca”) and Defendant and
`Counterclaim Plaintiff Wiz, Inc. (“Wiz”) (collectively, the “Parties”) jointly submit this letter in
`accordance with Paragraph 12 of the Scheduling Order (D.I. 33, amended by D.I. 90) entered in
`the above-captioned action, which requires the Parties to meet and confer regarding an amended
`Joint Claim Construction Chart.
`
`On December 13, 2024 at 12:00 PM EST, the Parties engaged in a meet and confer via
`Zoom. The following individuals participated in the meet and confer:
`
`On behalf of Orca Security Ltd.: Doug Lumish (Lead Counsel), Blake Davis (Lead
`Counsel), Lucas Lonergan, and Nicole Bruner of Latham & Watkins LLP, and Cameron Clark of
`Morris, Nichols, Arsht & Tunnel LLP.
`
`On behalf of Wiz, Inc.: Jordan Jaffe (Lead Counsel) and Alex Miller of Wilson Sonsini
`Goodrich & Rosati, P.C., and Kelly Farnan and Fred Cottrell of Richards, Layton & Finger, P.A.
`
`The meet and confer lasted approximately forty-five minutes. The Parties did not reach
`agreement as to any disputed term and no disputes were narrowed. The Parties also discussed
`procedure for the December 23, 2024 Claim Construction Hearing and agreed to the following
`proposal subject to the Court’s approval:
`
`1) The Parties will address the eight (8) disputed terms of Orca’s Asserted Patents
`first, and then address the four (4) disputed terms of Wiz’s Asserted Patents.
`
`
`
`2) The Parties will address the terms in the order that they appear in the Parties’
`briefing, Dkt. 202 for Orca’s Asserted Patents and Dkt. 200 for Wiz’s Asserted
`Patents, with one exception. The term “analyz[e/ing] the (at least one)
`snapshot” appears last in Dkt. 202 for Orca’s Asserted Patents, but the Parties
`have agreed that term should be argued as the third term. The Parties’
`agreement regarding the order that the terms will be addressed is set forth in the
`Parties’ Amended Joint Claim Construction Chart, filed concurrently herewith.
`3) The party that will present opening arguments for each term is set forth in the
`Parties’ Amended Joint Claim Construction Chart, wherein the Parties alternate
`presenting opening arguments except that a party arguing that a term is
`indefinite will present the opening argument as to that term.
`
`Counsel are available at the Court’s convenience should Your Honor have any questions.
`
`
`Respectfully,
`
`/s/ Cameron P. Clark
`
`Cameron P. Clark (#6647)
`
`
`Clerk of Court (via hand delivery)
`All Counsel of Record (via electronic mail)
`
`Case 1:23-cv-00758-JLH-SRF Document 221 Filed 12/16/24 Page 2 of 2 PageID #:
`5813
`
`The Honorable Jennifer L. Hall
`December 16, 2024
`Page 2
`
`
`
`cc:
`
`
`
`
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