`
`UNITED STATES DISTRICT COURT
`EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`
`
`
`
`Civil Action No. 1:22-cv-01373-MSN-JFA
`
`GEOSCOPE TECHNOLOGIES PTE. LTD.,
`Plaintiff,
`
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`
`
`CONSENT MOTION TO EXTEND THE SCHEDULE FOR FILING
`APPLICATIONS FOR AWARDS OF COSTS AND FEES
`
`Defendant, Apple Inc. (“Apple”), 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 Apple (Dkt. Nos. 107 & 110).
`
`2.
`
`Under the rules of court, Apple, as the prevailing party, may apply for an award of
`
`taxable costs. Fed. R. Civ. P. 54(d)(1). The bill of costs application is due “within fourteen (14)
`
`days from the entry of judgment, unless such time is extended by order of the Court.” E.D. Va.
`
`Civ. R. 54(D)(1).
`
`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).
`
`4.
`
`The parties have met and conferred to discuss the schedule for these filings. The
`
`parties agree that extending the due dates for filing applications for awards of fees and costs is
`
`warranted to conserve party and judicial resources.
`
`
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`1
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`
`
`Case 1:22-cv-01373-MSN-JFA Document 113 Filed 09/27/23 Page 2 of 3 PageID# 2043
`
`
`
`5.
`
`Therefore, Apple requests that the schedule for these filings be extended until 30
`
`days after the deadline to file a notice of appeal has passed, or 30 days after the mandate from the
`
`Federal Circuit has issued in any appeal, whichever date is later.
`
`6.
`
`Geoscope consents to the scheduling relief Apple seeks in this motion.
`
`The parties waive a hearing on this procedural motion.
`
`WHEREFORE, Apple, with the consent of Geoscope, requests that this Court enter an
`
`order extending the schedule for Apple’s applications for awards of fees and costs. A proposed
`
`Respectfully submitted,
`
`/s/ Craig C. Reilly
`Craig C. Reilly (VSB # 20942)
`209 Madison Street, Suite 501
`Alexandria, Virginia 22314
`T: (703) 549-5354
`F: (703) 549-5355
`E: craig.reilly@ccreillylaw.com
`Counsel for Defendant Apple Inc.
`
`order is submitted herewith.
`
`Dated: September 27, 2023
`
`
`Of Counsel for Defendant Apple Inc.:
`
`Brian M. Buroker (VSB No. 39,581)
`bburoker@gibsondunn.com
`Wendy W. Cai (pro hac vice)
`wcai@gibsondunn.com
`David Brzozowski (pro hac vice)
`dbrzozowski@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, DC 20036-5306
`Tel: (202) 955-8295
`Fax: (202) 831-6106
`
`Brian A. Rosenthal (pro hac vice)
`brosenthal@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`200 Park Avenue
`New York, New York 10166
`Tel: (212) 351-4000
`Fax: (212) 716-0839
`
`
`
`
`
`
`
`
`
`2
`
`
`
`Case 1:22-cv-01373-MSN-JFA Document 113 Filed 09/27/23 Page 3 of 3 PageID# 2044
`
`Jaysen S. Chung (pro hac vice)
`jschung@gibsondunn.com
`Andrew W. Robb (pro hac vice)
`arobb@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`1881 Page Mill Road Palo Alto, CA 94304-
`1211
`Tel: (650) 849-5300
`Fax: (650) 849-5067
`
`Nathaniel R. Scharn (pro hac vice)
`nscharn@gibsondunn.com
`Gibson, Dunn & Crutcher LLP
`3161 Michelson Drive
`Irvine, CA 92612-4412
`Tel: (949) 451-3800
`Fax: (949) 451-4220
`
`
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`3
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