`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`
`
`
`
`
`GOOGLE LLC,
`
`
`
`
`Plaintiff,
`
`
`
`Defendant.
`
`v.
`
`
`
`
`
`Civil Action No. 1:22-cv-01331-MSN-JFA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`PLAINTIFF GEOSCOPE TECHNOLOGIES PTE. LTD.’S UNOPPOSED
`MOTION FOR LEAVE TO AMEND ITS CLAIM ELECTION
`
`Pursuant to the Joint Discovery Plan (Dkt. No. 50), Plaintiff Geoscope Technologies Pte.
`
`Ltd. (“Geoscope”) respectfully requests leave to amend its election of asserted claims to include
`
`claim 13 and related dependent claims 15-17 and 20 from U.S. Patent No. 8,320,264 (“the ’264
`
`Patent”). The reasons for this motion and the precise relief sought are fully explained in the
`
`Memorandum in Support of Plaintiff Geoscope Technologies Pte. Ltd.’s Unopposed Motion for
`
`Leave to Amend its Claim Election filed contemporaneously herewith. A Proposed Order granting
`
`the Motion is filed herewith. Defendant Google LLC has indicated that it does not oppose this
`
`
`
`motion.
`
`
`
`
`
`
`
`
`
`
`
`
`Case 1:22-cv-01331-MSN-JFA Document 66 Filed 05/19/23 Page 2 of 2 PageID# 752
`
`
`
`Dated: May 19, 2023
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`/s/ John M. Erbach
`John M. Erbach (VSB No. 76695)
`Chris Bascom (VSB No. 87302)
`SPOTTS FAIN, P.C.
`Renaissance Centre
`411 East Franklin Street, Suite 600
`Richmond, Virginia 23219
`Tel: (804) 697-2044
`Fax: (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)
`Alexandra J. Cho (pro hac vice)
`SCHULTE ROTH & ZABEL LLP
`919 Third Avenue
`New York, NY 10022
`Tel: (212) 756-2000
`Fax: (212) 593-5955
`tim.gilman@srz.com
`saunak.desai@srz.com
`gregory.springsted@srz.com
`alexandra.cho@srz.com
`
`Attorneys for Plaintiff Geoscope Technologies
`Pte. Ltd.
`
`2
`
`
`
`
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