Defendants The Rector and Visitors of George Mason University (“Mason”) and Thomas Bluestein submit this Notice of Removal pursuant to 28 U.S.C. § 1441, et seq., requesting that this Honorable Court assume jurisdiction over this action, and set forth the following reasons:

The above-captioned matter was commenced by the filing of a Complaint in the Circuit Court of Fairfax County.

On December 11, 2023, Counsel for Plaintiff sent Defendants the Summons and Fairfax County Circuit Court waiver of service forms.

Pursuant to 28 U.S.C. § 1441 and 28 U.S.C. § 1443, this case meets the requirements of removal to federal court as it asserts claims arising out of the United States Constitution, and laws of the United States, and maintains a “civil rights” action.

This Notice of Removal is being filed with the Court within thirty (30) days after service of the Summons and Complaint on Defendants.

Paul G. Gardephe United States District Judge Dated: July 11, 2022 Network-1 Technologies, Inc. v. Google LLC, et al., Nos. 1:14-cv-2396- PGG-SN & 1:14-cv-9558-PGG-SN 12424 Wilshire Boulevard 12th Floor Los Angeles California 90025 Tel 310.826.7474 Fax 310.826.6991 www.raklaw.com Re: Dear Judge Gardephe: Pursuant to the Court’s Memorandum Order (Case No. 2396, Dkt. # 264), Plaintiff Network-1 Technologies, Inc. (“Network-1”) and Defendants Google LLC and YouTube, LLC (collectively “Google”) respectfully submit this joint letter setting forth their respective positions as to whether the stipulated supplemental discovery authorized by Judge Netburn’s May 7, 2021 Order, including any supplemental expert reports, has any impact on the parties’ pending cross-motions for summary judgment.

The Order also provided that the parties reserved the right to seek leave to serve supplemental expert reports in light of the additional discovery.

Network-1 should be permitted to present that material to the Court.1 Accordingly, Network-1 respectfully requests that the Court order Google to provide its updated sales/revenue information by not later than July 21.

While Google is correct that the parties agreed to work cooperatively to arrive at such a schedule, Network-1 has been seeking to get Google’s supplemental financial information for nearly a year without success, suggesting that assistance from the Court is now needed.

Network-1 confirmed the same to Judge Netburn at a hearing on April 22, 2021: “You had also asked about the effect on the summary judgment briefing that’s currently outstanding with the Court.