`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`
`
`
`v.
`
`
`GOOGLE LLC,
`
`
`Plaintiff,
`
`Defendant,
`
`Case No. 1:22-cv-01331-MSN-JFA
`
`
`
`
`
`CONSENT MOTION TO EXTEND THE SCHEDULE FOR FILING
`APPLICATIONS FOR AWARDS OF COSTS AND FEES
`
`Defendant, Google LLC (“Google”), with the consent of Geoscope Technologies Pte. Ltd.
`
`(“Geoscope”), moves the Court to enter an order extending the schedule for filing applications for
`
`an award of taxable costs and an award of reasonable attorneys’ fees on the following grounds:
`
`1.
`
`This is an action for patent infringement. The Court has now entered orders
`
`dismissing all the claims asserted against Google (Dkt. Nos. 118, 119, & 121).
`
`2.
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`Under the rules of court, Google, as the prevailing party, may apply for an award
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`of taxable costs. Fed. R. Civ. P. 54(d)(1). The bill of costs application is due “within fourteen (14)
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`days from the entry of judgment, unless such time is extended by order of the Court.” E.D. Va.
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`Civ. R. 54(D)(1).
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`3.
`
`Under the Patent Act, reasonable attorneys’ fees may be awarded to the prevailing
`
`party in an “exceptional” case. 35 U.S.C. § 285. An application for an award of reasonable
`
`attorneys’ fees is due “no later than 14 days after the entry of judgment,” “[u]nless … a court order
`
`provides otherwise.” Fed. R. Civ. P. 54(d)(2)(B)(i).
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`
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`
`
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`Case 1:22-cv-01331-MSN-JFA Document 124 Filed 09/28/23 Page 2 of 4 PageID# 2220
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`4.
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`The parties have met and conferred to discuss the schedule for these filings. The
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`parties agree that extending the due dates for filing applications for awards of fees and costs is
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`warranted to conserve party and judicial resources.
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`5.
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`Therefore, Google requests that the schedule for these filings be extended until 30
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`days after the deadline to file a notice of appeal has passed, or 30 days after the mandate from the
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`Federal Circuit has issued in any appeal, whichever date is later.
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`6.
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`Geoscope consents to the scheduling relief Google seeks in this motion.
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`The parties waive a hearing on this procedural motion.
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`WHEREFORE, Google, with the consent of Geoscope, requests that this Court enter an
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`order extending the schedule for Google’s applications for awards of fees and costs. A proposed
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`order is submitted herewith.
`
`
`September 28, 2023
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`
`
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`
`
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`
`
`2
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`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
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 124 Filed 09/28/23 Page 3 of 4 PageID# 2221
`
`ebennett@wc.com
`aharber@wc.com
`atrask@wc.com
`bhazelwood@wc.com
`mliu@wc.com
`apan@wc.com
`
`Counsel for Google LLC
`
`
`
`
`
`3
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`
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`Case 1:22-cv-01331-MSN-JFA Document 124 Filed 09/28/23 Page 4 of 4 PageID# 2222
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`CERTIFICATE OF SERVICE
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`I hereby certify that on September 28, 2023, I will electronically file the foregoing with the
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`Clerk of Court using the CM/ECF system, which will send a notification of such filing (NEF) to
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`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.
`
`
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`
`
`21862522.v2
`21862522.v3
`
`4
`
`
`
` /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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