`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`Plaintiff,
`
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`
`
`Civil Action No. 1:22-cv-01331-MSN-JFA
`
`
`
`JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER
`
`Plaintiff Geoscope Technologies Pte Ltd. and Defendant Google LLC (together, the
`
`“Parties”), by their respective counsel, move for entry of the attached Stipulated Protective Order.
`
`In support thereof, the Parties state as follows:
`
`1.
`
`The Parties anticipate that discovery in this action will encompass confidential and
`
`private information, the public disclosure of which would be injurious. Therefore, the Parties have
`
`stipulated to the terms of a proposed protective order.
`
`2.
`
`Both Parties consent to and join in the relief sought by this motion.
`
`
`
`WHEREFORE, the Parties jointly move for entry of the proposed Stipulated Protective
`
`Order that is submitted herewith.
`
`
`
`The Parties do not seek oral argument on this procedural motion.
`
`Dated: March 28, 2023.
`
`
`
`
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 53 Filed 03/28/23 Page 2 of 2 PageID# 589
`
`Jointly Submitted,
`
`SPOTTS FAIN, P.C.
`
`
`
`/s/ Christopher W. Bascom
`Christopher W. Bascom (VSB No. 87302)
`John M. Erbach (VSB No. 76695)
`SPOTTS FAIN, P.C.
`Renaissance Centre
`411 East Franklin Street, Suite 600
`Richmond, Virginia 23219
`Tel: (302) 984-6300
`Fax: (804) 697-2144
`jerbach@spottsfain.com
`cbascom@spottsfain.com
`
`Timothy K. Gilman (pro hac vice)
`Saunak K. Desai (pro hac vice)
`Gregory Springsted (pro hac vice)
`Alexandra Judy Cho (pro hac vice)
`STROOCK & STROOCK & LAVAN LLP
`180 Maiden Lane
`New York, NY 10038
`Tel: (212) 806-5400
`Fax: (212) 806-6006
`tgilman@stroock.com
`sdesai@stroock.com
`gspringsted@stroock.com
`ajcho@stroock.com
`
`Counsel for Plaintiff Geoscope Technologies
`Pte. Ltd.
`
`
`
`
`KAUFMAN & CANOLES, P.C.
`
`
`
`
`
`/s/
`Stephen E. Noona (VSB No. 25367)
`KAUFMAN & CANOLES, P.C.
`150 W. Main Street, Suite 2100
`Norfolk, VA 23510-1665
`Telephone: (757) 624-3239
`Facsimile: (888) 360-9092
`senoona@kaufcan.com
`
`Edward J. Bennett (VSB No. 40118)
`Benjamin N. Hazelwood (VSB No.96058)
`Adam D. Harber (pro hac vice)
`Andrew V. Trask (pro hac vice)
`Michael Xun Liu (pro hac vice)
`Adam Pan (pro hac vice)
`WILLIAMS & CONNOLLY LLP
`680 Maine Avenue SW
`Washington, DC 20024
`Telephone: (202) 434-5000
`Facsimile: (202) 434-5029
`ebennett@wc.com
`bhazelwood@wc.com
`aharber@wc.com
`atrask@wc.com
`mliu@wc.com
`apan@wc.com
`
`Counsel for Defendant Google LLC
`
`
`2
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`
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