`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`ORCA SECURITY LTD.,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`WIZ, INC.,
`
`
`
`
`Defendant.
`
`
`
`
`
`C.A. No. 23-758 (JLH)
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`JOINT MOTION FOR TELECONFERENCE TO RESOLVE DISCOVERY DISPUTES
`
`Plaintiff Orca Security Ltd. and Defendant Wiz, Inc. respectfully move this Court
`
`to schedule a teleconference to address outstanding disputes regarding the following discovery
`
`matters.
`
`Plaintiff Orca Security Ltd.’s Issues For Teleconference:
`
`1.
`
`Defendants’ deficient production of core technical documents, including the scope
`
`of source code to be produced.
`
`2.
`
`Setting interim deadlines for Defendant’s document productions and responses to
`
`Orca’s interrogatories.1
`
`Defendant Wiz, Inc.’s Issues For Teleconference:
`
`1.
`
`The timing of and conditions for Orca’s production of source code for its allegedly
`
`practicing products.
`
`2.
`
`Orca’s failure to meet and confer on its Issue 2 above.
`
`
`1
`Orca will show through the Parties’ correspondence that this issue has been the subject of
`multiple meet and confers.
`
`
`
`
`
`Case 1:23-cv-00758-JLH Document 49 Filed 04/25/24 Page 2 of 3 PageID #: 1323
`
`
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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: April 4, 2024, April 12, 2024, April 18, 2024, and April 23, 2024.
`
`Delaware Counsel:
`
` Orca: Jack Blumenfeld and Rodger Smith (Morris, Nichols, Arsht & Tunnell);
`
` Wiz: Christine Haynes and Kelly Farnan (Richards, Layton & Finger)
`
`Lead Counsel:
`
` Orca: Doug Lumish, Blake Davis, Krissy McKenna, Ryan Banks, and Lucas
`
`Lonergan (Latham & Watkins);
`
` Wiz: Jordan Jaffe, Caty Lacey, Callie Davidson, and Praatika Prasad (Wilson
`
`Sonsini)
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`The parties are available for a teleconference on the following dates: May 3, May 7,
`
`or May 8 after 1:00 pm ET.
`
`2
`
`
`
`Case 1:23-cv-00758-JLH Document 49 Filed 04/25/24 Page 3 of 3 PageID #: 1324
`
`
`
`MORRIS, NICHOLS, ARSHT &TUNNELL LLP
`
`/s/ Rodger D. Smith II
`___________________________________
`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899-1347
`(302) 658-9200
`jblumenfeld@morrisnichols.com
`rsmith@morrisnichols.com
`
`Attorneys for Plaintiff Orca Security Ltd.
`
`OF COUNSEL:
`
`Douglas E. Lumish
`Lucas Lonergan
`LATHAM & WATKINS LLP
`140 Scott Drive
`Menlo Park, CA 94025
`(650) 328-4600
`
`Blake R. Davis
`LATHAM & WATKINS LLP
`505 Montgomery Street, Suite 2000
`San Francisco, CA 94111
`(415) 391-0600
`
`Kristina D. McKenna
`LATHAM & WATKINS LLP
`200 Clarendon Street
`Boston, MA 02116
`(617) 948-6000
`
`April 25, 2024
`
`
`
`
`
`RICHARD, LAYTON & FINGER, P.A.
`
`/s/ Christine D. Haynes
`
`
`
`
`
`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
`
`Attorneys for Defendant Wiz, Inc.
`
`OF COUNSEL:
`
`Jordan R. Jaffe
`Catherine Lacy
`Callie Davidson
`Alex Miller
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`(415) 947-2000
`
`Praatika Prasad
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`1301 Avenue of the Americas, 40th Floor
`New York, NY 10019-6022
`(212) 999-5800
`
`3
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`
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