Case 1:22-cv-01331-MSN-JFA Document 88 Filed 06/21/23 Page 1 of 4 PageID# 1653
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`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
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`
`
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`GEOSCOPE TECHNOLOGIES PTE. LTD.,
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`
`
`v.
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`
`GOOGLE LLC,
`
`
`Plaintiff,
`
`Defendant,
`
`Case No. 1:22-cv-01331-MSN-JFA
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`
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`
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`CONSENT MOTION FOR SCHEDULING
`CERTAIN PRETRIAL EVENTS AND BRIEFING
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`Defendant, Google LLC (“Google”), with the consent of Geoscope Technologies Pte. Ltd.
`
`(“Geoscope”), moves the Court to enter an order setting a schedule for certain pretrial events that
`
`will be completed prior to the final pretrial conference, which will be held on August 17, 2023.
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`This is an action for patent infringement. There is pending before the Court a separate
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`patent infringement action in which Geoscope has asserted the same patents against another party.
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`Geoscope Technologies Pte Ltd. v. Apple Inc., No. 1:22-cv-1373-MSN-JFA (E.D. Va. filed Dec.
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`1, 2022) (“Apple Action”). Certain proceedings in this action and the Apple Action are coordinated
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`(see Dkt. No. 50, Joint Discovery Plan, § VI(B)).
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`EXTENSION OF EXPERT DISCLOSURE AND DEPOSITION DATES
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`1.
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`Under the current schedule, opening expert reports are due June 26, 2023, and
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`rebuttal expert reports are due July 21, 2023 (Dkt. No. 50, Joint Discovery Plan, § V(D)).
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`2.
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`The parties are diligently completing fact discovery, including analysis of
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`Defendant’s source code. To provide for more orderly preparation of Rule 26(a)(2) expert
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`disclosures, the parties seek to extend the expert disclosure dates by only one week for each
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`
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`1
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`
`
`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 FOR SCHEDULING
`CERTAIN PRETRIAL EVENTS AND BRIEFING
`
`Defendant, Google LLC (“Google”), with the consent of Geoscope Technologies Pte. Ltd.
`
`(“Geoscope”), moves the Court to enter an order setting a schedule for certain pretrial events that
`
`will be completed prior to the final pretrial conference, which will be held on August 17, 2023.
`
`This is an action for patent infringement. There is pending before the Court a separate
`
`patent infringement action in which Geoscope has asserted the same patents against another party.
`
`Geoscope Technologies Pte Ltd. v. Apple Inc., No. 1:22-cv-1373-MSN-JFA (E.D. Va. filed Dec.
`
`1, 2022) (“Apple Action”). Certain proceedings in this action and the Apple Action are coordinated
`
`(see Dkt. No. 50, Joint Discovery Plan, § VI(B)).
`
`EXTENSION OF EXPERT DISCLOSURE AND DEPOSITION DATES
`
`1.
`
`Under the current schedule, opening expert reports are due June 26, 2023, and
`
`rebuttal expert reports are due July 21, 2023 (Dkt. No. 50, Joint Discovery Plan, § V(D)).
`
`2.
`
`The parties are diligently completing fact discovery, including analysis of
`
`Defendant’s source code. To provide for more orderly preparation of Rule 26(a)(2) expert
`
`disclosures, the parties seek to extend the expert disclosure dates by only one week for each
`
`
`
`1
`
`
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`Case 1:22-cv-01331-MSN-JFA Document 88 Filed 06/21/23 Page 2 of 4 PageID# 1654
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`
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`deadline, as follows: Opening expert disclosures would be due July 3, 2023, and rebuttal expert
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`disclosures would be due July 28, 2023. The parties also seek leave to complete expert depositions
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`by August 18, 2023, which is just one-week after the currently scheduled discovery cut-off.
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`RULE 12(C) MOTION UNDER 35 U.S.C. § 101
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`3.
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`Defendants Apple and Google plan to file a joint motion under Rule 12(c) in both
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`actions seeking judgment on the pleadings under 35 U.S.C. § 101, contesting the patent eligibility
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`of the asserted claims.
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`4.
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`To allow for a full exposition of the parties’ contentions under Section 101, the
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`parties have met and conferred and agree that an enlargement of the page limits for the briefing
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`will facilitate the orderly adjudication of this motion. The parties request that the Court allow a
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`40-page opening brief (jointly filed by Defendants), a 40-page brief in opposition, and a 25-page
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`reply brief (jointly filed by Defendants).
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`5.
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`For the Section 101 motion, the parties request the following briefing schedule:
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`Event
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`Defendants’ Joint Motion and
`Opening Brief
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`Date
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`June 27, 2023
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`Plaintiff’s Brief in Opposition
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`July 13, 2023
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`Defendants’ Joint Reply Brief
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`The parties are meeting and conferring to propose dates for a hearing on the Section
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`July 20, 2023
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`6.
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`101 motion. In addition, the parties in both actions have completed briefing on claim construction,
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`and are meeting and conferring to propose dates for a hearing on claim construction.
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`CONTINUING THE DUE DATE FOR RULE 26(A)(3) PRETRIAL DISCLOSURES
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`7.
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`Currently, the parties’ Rule 26(a)(3) disclosures are due on or before August 17,
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`2023, the date of the final pretrial conference (Dkt. No. 49, Order, third paragraph).
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`2
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`Case 1:22-cv-01331-MSN-JFA Document 88 Filed 06/21/23 Page 3 of 4 PageID# 1655
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`8.
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`Given the complex factual and technical issues in this action, the parties submit that
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`preparing their Rule 26(a)(3) pretrial disclosures—witness lists, exhibit lists, and deposition
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`designations—just three business days after the fact-discovery cut-off will be burdensome and
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`inefficient.
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`9.
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`To allow time for mature consideration when designating trial evidence, the parties
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`respectfully request that the current due date for Rule 26(a)(3) pretrial disclosures be continued,
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`and that the parties should meet and confer in advance of the final pretrial conference and then be
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`prepared to propose a schedule for their Rule 26(a)(3) disclosures, as well as any objections thereto,
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`for the Court’s consideration at the final pretrial conference.
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`OTHER DATES, TERMS, AND PROVISIONS OF ORDERS NOT CHANGED
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`10.
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`The parties do not propose to change either the fact-discovery cut-off (August 11,
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`2023) or the date of the final pretrial conference (August 17, 2023, at 1:00 p.m.).
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`11.
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`Except as changed by the attached proposed order, the parties do not propose to
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`change any other dates, terms, and provisions set in the Court’s prior orders.
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`The parties waive a hearing on this procedural motion.
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`WHEREFORE, Google, with the consent of Geoscope, and in coordination with the Apple
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`Action, requests that this Court enter an order setting a new schedule for certain events to be
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`completed between now and the pretrial conference. A proposed order is submitted herewith.
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`3
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`Case 1:22-cv-01331-MSN-JFA Document 88 Filed 06/21/23 Page 4 of 4 PageID# 1656
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`Dated: June 21, 2023
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`/s/Stephen E. Noona____________
`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)
`Adam D. Harber (pro hac vice)
`Andrew Trask (pro hac vice)
`Benjamin N. Hazelwood (VSB No. 96058)
`Michael Xun Liu (pro hac vice)
`Matthew W. Lachman (pro hac vice)
`Adam Pan (pro hac vice)
`Anna Searle (pro hac vice)
`WILLIAMS & CONNOLLY
`680 Maine Avenue SW
`Washington, DC 20024
`Telephone: (202) 434-5000
`ebennett@wc.com
`aharber@wc.com
`atrask@wc.com
`bhazelwood@wc.com
`mliu@wc.com
`mlachman@wc.com
`apan@wc.com
`asearle@wc.com
`
`Counsel for Google LLC
`
`4
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