`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`Plaintiff,
`
`Case No. 1:22-CV-01331-MSN-JFA
`
`v.
`GOOGLE LLC,
`Defendant.
`
`JURY TRIAL DEMANDED
`
`GOOGLE LLC’S MOTION TO USE ELECTRONIC DEVICES AT MOTION FOR
`JUDGMENT ON THE PLEADINGS HEARING AND MEMORANDUM IN SUPPORT
`
`Google LLC (“Google”), by counsel, pursuant to the Court's Personal Electronic
`
`Device Policy, respectfully moves the Court for leave to (i) bring laptop computers into the
`
`Courthouse and (ii) use the Court's Electronic Evidence Presentation System during the August
`
`11, 2023 Hearing on the Defendants’ Motion for Judgment on the Pleadings (“Motion for
`
`Judgment on the Pleadings”). In support of this Motion, Google states as follows:
`
`1.
`
`This Court has scheduled a Hearing for August 11, 2023 at 10:00 a.m. At that time,
`
`the Court will entertain argument in this and a related case, 1:22cv01373, on the Motion for
`
`Judgment on the Pleadings.
`
`2.
`
`Google proposes to use the Electronic Evidence System and present PowerPoint
`
`slides as part of the argument to aid the Court's understanding of its position.
`
`3.
`
`To do so, under this Court's Personal Electronic Device Policy, counsel requires the
`
`Court's authorization to bring the necessary laptops, flash drive, and associated charging cords and
`
`cables into the courthouse.
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 110 Filed 08/03/23 Page 2 of 4 PageID# 2076
`
`4.
`
`To ensure reliability, counsel requests authorization to bring two (2) laptops
`
`into the courthouse, one primary laptop and one as a backup in case of technical issues. In
`
`support of this motion, Google submits the required electronic device form as a Proposed Order
`
`attached as Exhibit 1.
`
`WHEREFORE, Google respectfully moves the Court to enter the attached electronic
`
`device authorization as an order of the Court granting Google permission to bring laptop
`
`computers, a flash drive, and associated cords and cables into the courthouse and to use the
`
`Court's Electronic Evidence Presentation System at the August 11, 2023 Hearing.
`
`Google waives a hearing on this procedural motion.
`
`August 3, 2023
`
`Respectfully submitted,
`
` /s/ Stephen E. Noona
`Stephen E. Noona (VSB No. 25367)
`Clark J. Belote (VSB No. 87310)
`KAUFMAN & CANOLES, P.C.
`150 W. Main Street, Suite 2100
`Norfolk, VA 23510-1665
`Telephone: (757) 624-3000
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`cjbelote@kaufcan.com
`
`Edward J. Bennett (VSB No. 40118)
`Adam D. Harber (pro hac vice)
`Andrew Trask (pro hac vice)
`Benjamin N. Hazelwood (VSB No.96058)
`Michael Xun Liu (pro hac vice)
`Adam Pan (pro hac vice)
`WILLIAMS & CONNOLLY
`680 Maine Avenue SW
`Washington, DC 20024
`Telephone: (202) 434-5000
`ebennett@wc.com
`aharber@wc.com
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 110 Filed 08/03/23 Page 3 of 4 PageID# 2077
`
`atrask@wc.com
`bhazelwood@wc.com
`mliu@wc.com
`apan@wc.com
`
`Counsel for Google LLC
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 110 Filed 08/03/23 Page 4 of 4 PageID# 2078
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on August 3, 2023, I will electronically file the foregoing with the
`
`Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
`
`all counsel of record, including::
`
`John M. Erbach (VSB No. 76695)
`Christopher W. Bascom (VSB No. 87302)
`SPOTTS FAIN, P.C.
`411 East Franklin Street, Suite 600
`Richmond, VA 23219
`Telephone: (804) 697-2044
`Facsimile: (804) 697-2144
`jerbach@spottsfain.com
`cbascom@spottsfain.com
`
`Timothy K. Gilman (pro hac vice)
`Saunak K. Desai (pro hac vice)
`Gregory R. Springsted (pro hac vice)
`STROOCK & STROOCK & LAVAN LLP
`180 Maiden Lane
`New York, NY 10038
`Telephone: (212) 806-5400
`Facsimile: (212) 806-6006
`tgilman@stroock.cm
`sdesai@stroock.com
`gspringsted@stroock.com
`
`Counsel for Geoscope Technologies Pte. Ltd.
`
`21687666.v2
`
` /s/ Stephen E. Noona
`Stephen E. Noona (VSB No. 25367)
`Clark J. Belote (VSB No. 87310)
`KAUFMAN & CANOLES, P.C.
`150 West Main Street, Suite 2100
`Norfolk, VA 23510
`Telephone: (757) 624-3000
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`cjbelote@kaufcan.com
`
`Counsel for Google LLC
`
`
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