Synopsys, Inc. v. Risk Based Security, Inc.
| Synopsys, Inc. |
| Risk Based Security, Inc. |
| Craig T. Merritt |
| 3:2021cv00252 |
| April 14, 2021 |
| US District Court for the Eastern District of Virginia |
| John A Gibney |
| Copyright |
| 28 U.S.C. § 1331 Fed. Question: Declaratory Judgment |
| Plaintiff |
Docket Report
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This docket was last retrieved on October 7, 2022. A more recent docket listing may be available from PACER.
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Filing 438
ORDER that Synopsys's Rule 54 fee motion, (ECF No. #427 ), presents a contested issue that it did not previously address with the Court-whether it is indeed entitled to attorneys' fees pursuant to either the Reseller Agreement or the Defend Trade Secrets Act and Virginia Uniform Trade Secrets Act. Because Synopsys's asserted right to fees will require additional briefing and resources, the Court will defer ruling on Synopsys's motion for attorneys' fees and costs. After due consideration, the Court DENIES Synopsys's motion for attorneys' fees and costs, (ECF No. #427 ), without prejudice and with leave to renew within twenty-one (21) days of the Fourth Circuit's mandate to this Court. Accordingly, the Court dismisses RBS's motion to stay this Court's consideration of Synopsys's motion for attorney's fees, (ECF No. #430 ), as MOOT. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 10/7/2022. (sbea)
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Filing 437
Reply Brief In Support of Emergency Motion to Stay Consideration of Fees and Costs filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 436
RESPONSE in Opposition re #430 Emergency MOTION to Stay Consideration of Fees and Costs filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1)(Connally, Nathaniel)
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Filing 435
ORDER that Court GRANTS the Defendant's Motion to Extend Deadline for RBS to File a Reply Brief in Support of Its Motion to Stay Consideration of Fees and Costs #434 . (Id.) RBS shall file its answer by September 9, 2022. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 8/29/2022. (adun, )
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Filing 434
Consent MOTION for Extension of Deadline for RBS to file a Reply Brief In Support of its Motion to Stay Consideration of Fees and Costs by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 433
ORDER. The Court DIRECTS the Clerk to reseal the transcript of proceedings held on November 18, 2021 #130 and the transcript of proceedings held on March 1, 2022 #396 . See Order for details. Signed by District Judge John A. Gibney, Jr. on 8/25/2022. (jsmi, )
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Filing 432
ORDER - Upon due consideration, the Court SUSPENDS RBS's deadline to respond to Synopsys's motion for attorney's fees pending this Court's resolution of RBS's motion to stay. The Court shall issue such further responsive deadlines as may be appropriate when it rules on the motion to stay. SEE ORDER FOR DETAILS. Signed by District Judge John A. Gibney, Jr on 8/19/2022. (jpow, )
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Filing 431
Memorandum in Support re #430 Emergency MOTION to Stay Consideration of Fees and Costs filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 430
Emergency MOTION to Stay Consideration of Fees and Costs by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 429
BILL OF COSTS by Synopsys, Inc.. (Attachments: #1 Decl. of Patrick T. Michael, #2 Exhibit 1 to the Decl. of Patrick T. Michael, #3 Exhibit 2 to the Decl. of Patrick T. Michael, #4 Exhibit 3 to the Decl. of Patrick T. Michael, #5 Exhibit 4 to the Decl. of Patrick T. Michael, #6 Exhibit 5 to the Decl. of Patrick T. Michael)(Cury, Lauren)
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Filing 428
Memorandum in Support re #427 MOTION for Attorney Fees and Costs filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1 (Decl. of Patrick T. Michael), #2 Exhibit A to the Decl. of Patrick T. Michael, #3 Exhibit B to the Decl. of Patrick T. Michael, #4 Exhibit C to the Decl. of Patrick T. Michael, #5 Exhibit D to the Decl. of Patrick T. Michael, #6 Exhibit 2 (Decl. of N. Thomas Connally), #7 Exhibit 3 (Decl. of Charles B. Molster, III), #8 Exhibit 4 (Decl. of Shanee Y. W. Nelson))(Connally, Nathaniel)
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Filing 427
MOTION for Attorney Fees and Costs by Synopsys, Inc.. (Connally, Nathaniel)
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Filing 426
ORDER of USCA as to #420 Notice of Appeal filed by Risk Based Security, Inc. Upon consideration of submissions relative to Appellants emergency motion to stay unsealing order pending appeal, the court grants the motion and stays enforcement of the district courts July 28, 2022, order and August 2, 2022, order directing the parties to publicly file confidential documents containing RBSs trade secrets pending appeal. (22-1812) (smej, )
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Filing 425
ORDER of USCA as to #420 Notice of Appeal filed by Risk Based Security, Inc. On August 2, 2022, Defendant-Appellant Risk Based Security, Inc., filed an emergency motion seeking to stay a district court order requiring the unsealing of certain materials by August 4, 2022.The court grants an administrative stay of the district courts unsealing order to allow consideration of the motion for stay pending appeal and the response thereto. The district courts order is, accordingly, stayed pending further order of this court. (22-1812) (smej, )
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USCA Case Number 22-1812, Case Manager M. Beall, for #420 Notice of Appeal filed by Risk Based Security, Inc.. (smej, )
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Filing 424
ORDER that the Court has previously considered all the arguments RBS raises in its brief supporting its motion to stay and found them wanting. The Court, therefore, finds that these arguments do not give RBS a high likelihood of success on appeal. The Court thus DENIES RBS's motion to stay its Order directing the parties to file documents that comply with the Court's July 28, 2022 Order on or before August 4, 2022, (ECF No. #421 ). See Order for details. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 8/2/2022. (sbea)
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Filing 423
Transmission of Notice of Appeal to US Court of Appeals re #420 Notice of Appeal (All case opening forms, plus the transcript guidelines, may be obtained from the Fourth Circuit's website at www.ca4.uscourts.gov) (smej, )
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Assembled INITIAL Electronic Record Transmitted to 4CCA re #420 Notice of Appeal (smej, )
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Filing 422
Memorandum in Support re #421 MOTION to Stay Pending Appeal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 421
MOTION to Stay Pending Appeal by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 420
NOTICE OF APPEAL re: #419 Rule 58 Judgment by Risk Based Security, Inc. Filing fee $ 505, receipt number AVAEDC-8499636 (Lonas, Carl). Modified on 8/1/2022. (sbea)
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Filing 419
RULE 58 JUDGMENT - For the reasons stated in the accompanying Opinion, the Court enters judgment in this case as follows: As to Count II, the Court enters judgment for the plaintiff, Synopsys, Inc. ("Synopsys"), and declares that Synopsys has not misappropriated the defendant Risk Based Security, Inc.'s ("RBS") claimed trade secrets under the Defend Trade Secrets Act or the Virginia Uniform Trade Secrets Act. As to Count IV, the Court enters judgment for Synopsys and declares that Synopsys has not tortiously interfered with any of RBS's existing contracts or business expectancies under Virginia law. Signed by District Judge John A. Gibney, Jr on 7/28/2022. (jpow, )
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Filing 418
OPINION. SEE OPINION FOR DETAILS. Signed by District Judge John A. Gibney, Jr on 7/28/2022. (jpow, )
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Filing 417
MEMORANDUM ORDER - The Court thus DENIES the motions to seal in ECF Nos. #209 , #215 , #222 , #230 , #318 , #324 , #331 , #334 , #362 , #369 , and #377 , EXCEPT that the proprietary data structure (see, e.g., ECF No. #209 , Ex. A 1281), any personal contact information, information about the RBS executive's past employment, and information about the respective ownership interests in RBS SHALL remain sealed. The Court thus DENIES the motions to seal in ECF Nos. #100 , #194 , #199 , #244 , #253 , #262 , #282 , #293 , #299 , #306 , and #384 , EXCEPT that any personal contact information, the Stock Purchase Agreement for the acquisition of RBS, (ECF No. #255 -2), the disclosure schedule for that agreement, (ECF No. #304 -4), the proprietary data structure, (see, e.g., ECF No. #311 -1, at 111 ), and the source code in ECF No. #104 -8 SHALL remain sealed. The Court UNSEALS the financial information previously sealed in ECF No. #172 , (see also ECF No. #36 ), and DENIES RBS's motion to seal trade secret information disclosed during the November 18, 2021 hearing, (ECF No. #410 ). The Court also DENIES RBS's motion to seal any portion of the March 1, 2022 hearing transcript, (id), and DENIES as MOOT Synopsys's February 10, 2022, and RBS's February 23, 2022 motions to seal. (ECF Nos. #271 , #356 .) The Clerk SHALL unseal ECF Nos. #130 and #396 . (Cf ECF No. #414 .) The Court DIRECTS the parties to refile documents that comply with this Order within seven days of the date of this Order. The parties may redact only information which this Order allows to be sealed. SEE ORDER FOR DETAILS. Signed by District Judge John A. Gibney, Jr on 7/28/2022. (jpow, )
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Filing 416
STATUS REPORT Regarding Previously File Motions to Seal by Risk Based Security, Inc. (Attachments: #1 Exhibit 1 - Redacted, #2 Exhibit 2 - Redacted, #3 Exhibit 3 - Redacted, #4 Exhibit 4 - Redacted, #5 Exhibit 5 - Redacted, #6 Exhibit 6 - Redacted, #7 Exhibit 7 - Redacted, #8 Exhibit 8 - Redacted, #9 Exhibit 9 - Redacted, #10 Exhibit 10 - Redacted, #11 Exhibit 11 - Redacted, #12 Exhibit 12 - Redacted, #13 Exhibit 13 - Redacted, #14 Exhibit 14 - Redacted, #15 Exhibit 15 - Redacted, #16 Exhibit 16 - Redacted, #17 Exhibit 17 - Redacted, #18 Exhibit 18 - Redacted, #19 Exhibit 19 - Redacted, #20 Exhibit 20 - Redacted, #21 Exhibit 21 - Redacted, #22 Exhibit 22 - Redacted, #23 Exhibit 23 - Redacted, #24 Exhibit 24 - Redacted, #25 Exhibit 25 - Redacted, #26 Exhibit 26 - Redacted, #27 Exhibit 27 - Redacted, #28 Exhibit 28 - Redacted, #29 Exhibit 29 - Redacted, #30 Exhibit 30 - Redacted, #31 Exhibit 31 - Redacted)(Lonas, Carl). Modified on 6/16/2022. (sbea)
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Filing 415
STATUS REPORT Regarding Outstanding Motions to Seal by Synopsys, Inc. (Attachments: #1 Exhibit 1 - Redacted, #2 Exhibit 2, #3 Exhibit 3 - Redacted, #4 Exhibit 4 - Redacted, #5 Exhibit 5 - Redacted, #6 Exhibit 6 - Redacted, #7 Exhibit 7 - Redacted, #8 Exhibit 8 - Redacted, #9 Exhibit 9 - Redacted, #10 Exhibit 10 - Redacted, #11 Exhibit 11 - Redacted, #12 Exhibit 12 - Redacted, #13 Exhibit 13 - Redacted, #14 Exhibit 14 - Redacted, #15 Exhibit 15 - Redacted, #16 Exhibit 16 - Redacted, #17 Exhibit 17 - Redacted, #18 Exhibit 18 - Redacted, #19 Exhibit 19 - Redacted, #20 Exhibit 20 - Redacted, #21 Exhibit 21 - Redacted, #22 Exhibit 22 - Redacted, #23 Exhibit 23 - Redacted, #24 Exhibit 24 - Redacted, #25 Exhibit 25 - Redacted, #26 Exhibit 26 - Redacted, #27 Exhibit 27, #28 Exhibit 28 - Redacted, #29 Exhibit 29 - Redacted, #30 Exhibit 30 - Redacted, #31 Exhibit 31, #32 Exhibit 32 - Redacted, #33 Exhibit 33 - Redacted)(Pickens, Christopher). Modified on 6/16/2022. (sbea)
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Filing 414
ORDER that upon due consideration, the Court DIRECTS the Clerk to file the unredacted transcripts, (ECF Nos. #130 and #396 ), under seal pending its disposition of RBS's motion. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 5/25/2022. (sbea)
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Filing 413
Sealed Document. (Attachments: #1 Exhibit 3)(Lonas, Carl)
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Filing 412
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 411
Memorandum in Support re #410 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 410
MOTION to Seal by Risk Based Security, Inc. (Attachments: #1 Proposed Order, #2 Exhibit 2 - Redacted, #3 Exhibit 3 - Redacted)(Lonas, Carl). Modified docket text on 5/24/2022. (sbea)
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Filing 409
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 408
MEMORANDUM ORDER that Synopsys has not provided substantially different evidence, identified a change in law, or established that the Court committed a clear error that would cause a manifest injustice, the Court will deny Synopsys's motion to reconsider the sealing order. In light of that ruling and in accordance with the principles outlined below, the Court will direct the parties to file status reports on the remaining sealing motions. The Court ORDERS the parties to file status reports on or before June 15, 2022, indicating which of the remaining motions to seal or which parts of the remaining motions to sealstill require adjudication and which have become moot on the basis of the Court's denial of Synopsys's motion for reconsideration. Accordingly, for any sealing motions or portions of sealing motions (1) not rendered moot and (2) for which the parties previously sought to seal entire documents, the Court ORDERS the parties to file proposed redactions for such documents. Though RBS filed its request in accordance with the Redaction Policy of this Court, the Court finds that the information RBS seeks to redact does not constitute material subject to Rule 5.2 privacy protections, (ECF No. 406, at 1). To the extent RBS still seeks to redact portions of this transcript, the Court ORDERS RBS to refile its March 23 redaction request as a motion to seal. The Court further ORDERS RBS to do the same for its December 13, 2021 transcript redaction request, (ECF No. #140 ). See Order for details. Its so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 5/13/2022. (sbea)
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Filing 407
Redaction of #396 Transcript (halasz, gil).
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Filing 406
Transcript Redaction Request re: #396 Transcript by attorney Carl Dewayne Lonas. (Lonas, Carl)
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Filing 405
ORDER upon due consideration, the Court GRANTS Synopsys's #401 motion under Federal Rule of Civil Procedure 58. After the Court issues its written opinion, (cf. ECF No. #394 ), the Court will set out the declaratory judgment in a separate document. Rule 54(d) motions shall be filed no later than fourteen days after the Court issues the document setting out the declaratory judgment. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 3/22/2022. (sbea)
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Filing 404
NOTICE by Synopsys, Inc. of Compliance With the Court's March 17, 2022 Order #400 (Pickens, Christopher)
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Filing 403
Waiver of Hearing Regarding Motion Under Rule 58(d) by Synopsys, Inc. (Pickens, Christopher)
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Filing 402
Memorandum in Support re #401 MOTION Under Rule 58(d) filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 401
MOTION Under Rule 58(d) by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 400
ORDER. The Court has received three bills from Craig T. Merritt of Merritt Law, PLLC, for services rendered in his capacity as Special Master for discovery for each bill, the Court directed the parties to pay their respective portions. (ECF Nos. #174 , #241 and #399 ). The Court now ORDERS the parties to pay any outstanding balance from any of these bills within seven days of the date of this Order. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 3/17/2022. (sbea)
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Filing 399
ORDER that the Court will allocate payment among the parties. Upon due consideration, the Court ORDERS the plaintiff to pay $10,590.00 of the February bill and the defendant to pay $10,590.00 of the February bill. The parties shall pay their bills in accordance with any agreements they may have regarding the payment of costs and fees in this case. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 3/10/2022. (sbea)
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Filing 398
FINAL ORDER re stipulation of dismissal without prejudice pursuant to Federal Rule of Civil Procedure 41 (a)( 1 )(A)(ii) as to the remaining claim in this case, Count I #397 . The Court acknowledges this voluntary dismissal. The case will remain open for the limited purposes of (1) issuing an opinion to accompany the Court's Order on the parties' motions to exclude and motions for summary judgment, #394 ; (2) ruling on the pending motion for reconsideration of the Court's sealing order, (ECF No. #177 ); and (3) ruling on the parties' myriad sealing motions, (ECF Nos. #100 , #194 , #199 , #209 , #215 , #222 , #230 , #244 , #253 , #262 , #271 , #282 , #293 , #299 , #306 , #318 , #324 , #331 , #334 , #356 , #362 , #369 , #377 , #384 ). Finally, the Court DENIES AS MOOT the parties' motions in limine. (ECF Nos. #297 , #309 .) SEE ORDER FOR DETAILS. Signed by District Judge John A. Gibney, Jr. on 3/9/22. (adun, )
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Filing 397
STIPULATION of Dismissal of Count I by Synopsys, Inc.. (Connally, Nathaniel)
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Filing 396
TRANSCRIPT of proceedings held on 03/01/2022, before Judge Hon. John A. Gibney, Jr., Court Reporter Gil Halasz, Telephone number 804 916-2248. NOTICE RE REDACTION OF TRANSCRIPTS:The parties have thirty(30) calendar days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.vaed.uscourts.gov Transcript may be viewed at the court public terminal or purchased through the court reporter before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER Redaction Request due 4/4/2022. Redacted Transcript Deadline set for 5/5/2022. Release of Transcript Restriction set for 6/3/2022.(halasz, gil)
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Minute Entry for proceedings held before Magistrate Judge Elizabeth W. Hanes:Settlement Conference held on 3/4/2022. (mful)
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Filing 395
ORDER that having considered the matter and deeming it otherwise proper and just to do so, and on the basis of the reasoning in the report, the Court ACCEPTS and ADOPTS the report, as amended, (ECF No. #354 ), as the OPINION of the Court, (ECF No. #290 ). The Court GRANTS IN PART and DENIES IN PART Risk Based Security, Inc.'s ("RBS") motion to compel, (ECF No. #247 ), and GRANTS IN PART and DENIES IN PART Synopsys's motion to compel, (ECF No. #250 ). The Court will address any outstanding evidentiary issues at the final pretrial conference scheduled for March 14, 2022, at 9:00 a.m. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 3/4/2022. (sbea)
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Filing 394
ORDER that the Court held a hearing on the parties' motions to exclude and motions for summary judgment on Tuesday, March 1, 2022. Upon due consideration and for the reasons stated from the bench, the Court ORDERS as follows: The Court GRANTS IN PART and DENIES IN PART Synopsys's motion to exclude RBS's experts, (ECF No. #206 ). The Court GRANTS IN PART and DENIES IN PART RBS's motion to exclude Eric Cole, (ECF No. #233 ). The Court GRANTS IN PART and DENIES IN PART Synopsys's motion for summary judgment, (ECF No. #218 . The Court GRANTS IN PART and DENIES IN PART RBS's motion for partial summary judgment, (ECF No. #219 ). The Court will issue an opinion on these rulings. The Court also CONTINUES the final pretrial conference previously scheduled for March 2, 2022. The Court RESCHEDULES the final pretrial conference for Monday, March 14, 2022, at 9:00 a.m., immediately before the trial. The Court has also reviewed the parties' motions in limine, (ECF Nos. #297 and #309 ), and finds that the Court's rulings on the parties' motions to exclude and for summary judgment render many of the parties' arguments moot. The Court ORDERS each party to submit a notice on or before Wednesday, March 9, 2022, identifying which portions of its motion in limine the Court should address at the March 14, 2022 final pretrial conference, and which portions have become moot. The Court also ORDERS the parties to submit updated exhibit lists, witness lists, and discovery designations that comply with the rulings herein on or before Wednesday, March 9, 2022. Each party shall refile its objections on or before Thursday, March 10, 2022, removing any objections to exhibits, witnesses, or discovery designations the other party no longer seeks to introduce. Each party shall bring five courtesy copies of the updated exhibit lists, witness lists, discovery designations, and accompanying binders to the Court by Monday, March 14, 2022, at 8:00 a.m. If the parties agree to present any voluminous exhibits or designations electronically, then they need not bring physical copies to the Court. The parties must contact the Court on or before Thursday, March 10, 2022, if they plan to present any exhibits or designations exclusively electronically. The parties shall provide the Court a courtesy copy of any electronic exhibits or designations on a USB drive by Monday, March 14, 2022, at 8:00 a.m. See Order for details. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 3/2/2022. (sbea)
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Second Settlement Conference set for 3/4/2022 at 9:00 AM via ZOOM before Magistrate Judge Elizabeth W. Hanes. (mful)
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Filing 393
Minute Entry for proceedings held before District Judge John A. Gibney, Jr.:Motion Hearing held on 3/1/2022 re #218 MOTION for Summary Judgment filed by Synopsys, Inc., #233 MOTION to Exclude filed by Risk Based Security, Inc., #219 MOTION for Partial Summary Judgment filed by Risk Based Security, Inc., #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh filed by Synopsys, Inc.; the motions to exclude testimony of Shostack and Cole are granted in part and denied in part, as to Kursh it is granted; the Court grants Synopsys SJ motion in part; the final pretrial conference is cancelled and counsel directed to schedule settlement conference with magistrate judge (Court Reporter G. Halasz, OCR.)(wtuc)
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Notice of Correction re: #392 Exhibit List; filing attorney selected the wrong filing event. The correct event is "Opposition" and link it to the ECF No. docket entry. No further action is required at this time. (sbea)
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Filing 392
RBS Objections to Synopsys' Supplemental Exhibit List by Risk Based Security, Inc... (Attachments: #1 Exhibit A)(Lonas, Carl)
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Filing 391
Third Supplemental Exhibit List by Risk Based Security, Inc... (Lonas, Carl)
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Filing 390
Discovery Designation by Risk Based Security, Inc..(Lonas, Carl)
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Filing 389
RESPONSE in Opposition re #309 MOTION in Limine filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 388
Sealed Response/Reply/Opposition re #303 Sealed Memorandum in Support. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit G, #4 Exhibit H, #5 Exhibit I)(Lonas, Carl)
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Filing 387
Opposition to Plaintiff's Motion in Limine (Redacted) re: #303 Sealed Memorandum in Support filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J)(Lonas, Carl). Modified docket text on 2/28/2022. (sbea)
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Filing 386
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 385
Memorandum in Support re #384 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 384
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 383
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 382
ORDER that the #381 Motion is GRANTED. It is ORDERED that the deadline for the parties to submit pre trial briefs is extended from March 4, 2022 until March 9, 2022. The remaining deadlines set forth in the Court's Third Amended Scheduling Order, ECF No. 159 are unchanged. It is ORDERED that the parties shall file their pretrial briefs by March 9, 2022. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/25/2022. (sbea )
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Notice of Correction re: #381 MOTION Joint Motion Re Deadline to Submit Pretrial Briefs; Joint Motion should include signature blocks for attorneys for both parties. (sbea)
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Filing 381
MOTION Joint Motion Re Deadline to Submit Pretrial Briefs by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 380
Waiver of Hearing re: #377 Motion to Seal Synopsys Reply Brief in Support of Motion for Summary Judgment and Exhibits 2-5 Thereto #374 by Synopsys, Inc. (Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 379
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re: #377 MOTION to Seal Synopsys Reply Brief in Support of Motion for Summary Judgment and Exhibits 2-5 Thereto #374 (Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 378
Memorandum in Support re: #377 MOTION to Seal Synopsys Reply Brief in Support of Motion for Summary Judgment and Exhibits 2-5 Thereto #374 filed by Synopsys, Inc. (Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 377
MOTION to Seal Synopsys Reply Brief in Support of Motion for Summary Judgment and Exhibits 2-5 Thereto #374 by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 376
Sealed Attachment/Exhibit(s) re #375 Sealed Response/Reply/Opposition. (Attachments: #1 Exhibit 2, #2 Exhibit 3, #3 Exhibit 4, #4 Exhibit 5)(Pickens, Christopher)
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Filing 375
Sealed Reply in Support re #218 MOTION for Summary Judgment . (Pickens, Christopher)
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Filing 374
REPLY to Response to Motion (Redacted) re: #218 MOTION for Summary Judgment filed by Synopsys, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2 (Public Redacted Version), #3 Exhibit 3 (Filed Under Seal), #4 Exhibit 4 (Filed Under Seal), #5 Exhibit 5 (Public Redacted Version)(Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 373
Waiver of Hearing on Motion to Seal Synopsys Reply Brief in Support of Its Motion to Exclude Expert Opinions of Adam Shostack and Steven Kursh and Exhibits A-C Thereto #369 by Synopsys, Inc. (Pickens, Christopher)
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Filing 372
Sealed Attachment/Exhibit(s) re #371 Sealed Response/Reply/Opposition. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Pickens, Christopher)
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Filing 371
Sealed Reply in Support re #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh. (Pickens, Christopher)
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Filing 370
Memorandum in Support re: #369 MOTION to Seal Synopsys Reply Brief in Support of Motion to Exclude Expert Opinions of Adam Shostack and Steven Kursh and Exhibits A-C Thereto #367 REPLY to Response to Motion (Redacted) filed by Synopsys, Inc. (Pickens, Christopher). Modified on 2/25/2022. (sbea)
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Filing 369
MOTION to Seal Synopsys Reply Brief in Support of Motion to Exclude Expert Opinions of Adam Shostack and Steven Kursh and Exhibits A-C Thereto #367 by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified docket text on 2/25/2022. (sbea)
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Filing 368
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. (Pickens, Christopher)
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Filing 367
REPLY to Response to Motion (Redacted) re: #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh filed by Synopsys, Inc. (Attachments: #1 Exhibit A (Filed Under Seal), #2 Exhibit B (Filed Under Seal), #3 Exhibit C (Filed Under Seal))(Pickens, Christopher). Modified docket text on 2/25/2022. (sbea)
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Filing 366
Sealed Response/Reply/Opposition. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)(Lonas, Carl)
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Filing 365
Reply to Motion (Redacted) re: #219 MOTION for Partial Summary Judgment filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E - Redacted, #6 Exhibit F)(Lonas, Carl). Modified docket text on 2/24/2022. (sbea)
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Filing 364
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 363
Memorandum in Support re #362 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 362
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 361
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 360
Sealed Response/Reply/Opposition re #233 MOTION to Exclude . (Attachments: #1 Exhibit C)(Lonas, Carl)
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Filing 359
Reply to Motion (Redacted) re: #233 MOTION to Exclude Expert Opinion of Dr, Eric Cole filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Lonas, Carl). Modified docket text on 2/24/2022. (sbea)
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Filing 358
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 357
Memorandum in Support re #356 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 356
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 355
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 354
ORDER REGARDING USE OF EXHIBITS PREVIOUSLY DESIGNATED AS AEO MATERIALS. See for details. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/23/2022. (sbea)
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Filing 353
Amended Objections to Plaintiff Synopsys, Inc.'s Discovery Designations to Be Introduced at Trial by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/23/2022. (sbea)
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Set Hearing: Final Pretrial Conference set for 3/2/2022 at 09:00 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (wtuc)
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Filing 352
Supplemental Exhibit List by Synopsys, Inc... (Attachments: #1 Exhibit A)(Pickens, Christopher)
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Filing 351
Objection to Risk Based Security Inc.'s Designated and Rebuttal Testimony re: #237 Discovery Designation, #315 Discovery Designation filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/23/2022. (sbea)
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Filing 350
Objection to #238 Witness List of Risk Based Security, Inc. filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 349
Objections to Defendant Risk Based Security, Inc.'s Second Supplemental Trial Exhibit List filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/23/2022. (sbea)
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Filing 348
Objections to Plaintiff Synopsys, Inc's Discovery Designations to Be Introduced At Trial by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/23/2022. (sbea)
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Filing 347
RBS Objections to Synopsys' Witness List by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 346
RBS Objections to Synopsys' Exhibit List by Risk Based Security, Inc. (Attachments: #1 Exhibit A - Redacted)(Lonas, Carl). Modified docket text on 2/23/2022. (sbea)
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Filing 345
NOTICE by Synopsys, Inc. of Withdrawal of Objection to Third Report and Recommendation of Special Master #344 (Pickens, Christopher)
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Minute Entry for proceedings held before Magistrate Judge Elizabeth W. Hanes:Settlement Conference held on 2/22/2022. (mful)
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Filing 344
Opposition re: #290 Third Report and Recommendations of Special Master by Craig T. Merritt filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/22/2022. (sbea)
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Filing 343
Joint MOTION to Clarify Provision of Special Master's Third Report and Recommendation #290 Regarding the Use of Exhibits Previously Designated as AEO Materials by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Connally, Nathaniel)
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Filing 342
STIPULATION Joint Factual Stipulations by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 341
Sealed Response/Reply/Opposition re #340 Opposition,,. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit J, #10 Exhibit K, #11 Exhibit L, #12 Exhibit M, #13 Exhibit N, #14 Exhibit O, #15 Exhibit P, #16 Exhibit Q, #17 Exhibit T, #18 Exhibit U, #19 Exhibit V)(Lonas, Carl)
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Filing 340
Opposition to #218 MOTION for Summary Judgment filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V)(Lonas, Carl)
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Filing 339
Unredacted Doument re #338 Memorandum in Opposition by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Pollock, Stewart)
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Filing 338
Memorandum in Opposition (Redacted) re: #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Pollock, Stewart). Modified docket text on 2/18/2022. (sbea)
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Filing 337
Waiver of Hearing On Motion to Seal re: #334 MOTION to Seal by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/18/2022. (sbea)
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Filing 336
Memorandum in Support re #334 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 335
Waiver of Hearing on Motion to Seal re: #331 MOTION to Seal>, #332 Memorandum in Support by Risk Based Security, Inc. (Pollock, Stewart). Modified docket text on 2/18/2022. (sbea)
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Filing 334
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 333
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 332
Memorandum in Support re #331 MOTION to Seal Motion to File Under Seal filed by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 331
MOTION to Seal Motion to File Under Seal by Risk Based Security, Inc.. (Attachments: #1 Exhibit 1)(Pollock, Stewart)
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Filing 330
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. (Pollock, Stewart)
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Filing 329
Sealed Attachment/Exhibit(s) re #328 Sealed Response in Opposition re #219 MOTION for Partial Summary Judgment. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 7, #6 Exhibit 8, #7 Exhibit 9, #8 Exhibit 11, #9 Exhibit 12, #10 Exhibit 13, #11 Exhibit 14)(Pickens, Christopher)
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Filing 328
Sealed Response in Opposition re #219 MOTION for Partial Summary Judgment. (Pickens, Christopher)
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Filing 327
Waiver of Hearing on #324 MOTION to Seal Synopsys' Response in Opposition to Risk Based Security's Motion for Partial Summary Judgment and Certain Exhibits Thereto #323 by Synopsys, Inc. (Pickens, Christopher)
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Filing 326
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #324 MOTION to Seal Synopsys' Response in Opposition to Risk Based Security's Motion for Partial Summary Judgment and Certain Exhibits Thereto #323 (Pickens, Christopher)
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Filing 325
Memorandum in Support re #324 MOTION to Seal Synopsys' Response in Opposition to Risk Based Security's Motion for Partial Summary Judgment and Certain Exhibits Thereto #323 filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 324
MOTION to Seal Synopsys' Response in Opposition to Risk Based Security's Motion for Partial Summary Judgment and Certain Exhibits Thereto #323 by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 323
RESPONSE in Opposition (Redacted) re: #219 MOTION for Partial Summary Judgment filed by Synopsys, Inc. (Attachments: #1 Exhibit 1 (Public-Redacted Version), #2 Exhibit 2 (Filed Under Seal), #3 Exhibit 3 (Filed Under Seal), #4 Exhibit 4 (Filed Under Seal), #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7 (Public-Redacted Version), #8 Exhibit 8 (Filed Under Seal), #9 Exhibit 9 (Filed Under Seal), #10 Exhibit 10, #11 Exhibit 11 (Filed Under Seal), #12 Exhibit 12 (Filed Under Seal), #13 Exhibit 13 (Filed Under Seal), #14 Exhibit 14 (Filed Under Seal), #15 Exhibit 15, #16 Exhibit 16, #17 Exhibit 17)(Pickens, Christopher). Modified docket text on 2/18/2022. (sbea)
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Filing 322
Waiver of Hearing on Motion to Seal Opposition to Defendant Risk Based Security Inc.'s Motion to Exclude Expert Opinion of Dr. Eric B. Cole, Ph.D. and Exhibits B and C Thereto #318 by Synopsys, Inc. (Pickens, Christopher)
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Filing 321
Sealed Attachment/Exhibit(s) re #320 Sealed Opposition re #233 MOTION to Exclude Expert Opinion of Dr. Eric B. Cole, PH.D. (Attachments: #1 Exhibit B, #2 Exhibit C)(Pickens, Christopher)
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Filing 320
Sealed Opposition re #233 MOTION to Exclude Expert Opinion of Dr. Eric B. Cole, PH.D. (Pickens, Christopher)
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Filing 319
Memorandum in Support re #318 MOTION to Seal OPPOSITION TO DEFENDANT RISK BASED SECURITY, INC.S MOTION TO EXCLUDE EXPERT OPINION OF DR. ERIC B. COLE, PH.D AND EXHIBITS B AND C THERETO #316 filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 318
MOTION to Seal OPPOSITION TO DEFENDANT RISK BASED SECURITY, INC.S MOTION TO EXCLUDE EXPERT OPINION OF DR. ERIC B. COLE, PH.D AND EXHIBITS B AND C THERETO #316 by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 317
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. (Pickens, Christopher)
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Filing 316
Memorandum in Opposition re: #233 MOTION to Exclude (Public Redacted Version) filed by Synopsys, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B (Filed Under Seal), #3 Exhibit C (Public Redacted Version))(Pickens, Christopher). Modified docket text on 2/18/2022. (sbea)
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Filing 315
Rebuttal to Plaintiff Synopsys, Inc.'s Discovery Designations to Be Introduced At Trial by Risk Based Security, Inc. (Lonas, Carl). Modified to correct docket text on 2/18/2022. (sbea)
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Filing 314
Rebuttal Witness List by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 313
Rebuttal Exhibit List by Risk Based Security, Inc... (Lonas, Carl)
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Filing 312
ORDER that this matter comes before the Court on the parties' motions in limine. (ECF Nos. #297 and #309 ). Upon due consideration, the Court DIRECTS each party to file any response to the other party's motion on or before Friday, February 25, 2022. Neither party shall file a reply brief without first obtaining the Court's leave. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/16/2022. (sbea)
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Filing 311
Sealed Memorandum in Support re #309 MOTION in Limine . (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit D, #4 Exhibit E, #5 Exhibit H, #6 Exhibit I, #7 Exhibit J, #8 Exhibit O, #9 Exhibit S, #10 Exhibit T, #11 Exhibit U)(Lonas, Carl)
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Filing 310
Memorandum in Support (Redacted) re: #309 OMNIBUS MOTION in Limine filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W)(Lonas, Carl). Modified docket text on 2/16/2022. (sbea)
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Filing 309
OMNIBUS MOTION in Limine by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/16/2022. (sbea)
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Filing 308
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 307
Memorandum in Support re #306 MOTION to Seal Motion in Limine filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 306
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 305
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. Motion in Limine (Lonas, Carl)
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Filing 304
Sealed Attachment/Exhibit(s) re #303 Sealed Memorandum in Support. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 7)(Pickens, Christopher)
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Filing 303
Sealed Memorandum in Support re #297 MOTION in Limine. (Pickens, Christopher)
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Filing 302
Waiver of Hearing on Synopsys' Motion to Seal Synopsys' Memorandum in Support of Its Motion in Limine and Exhibits 1-3 and 7 Thereto #299 by Synopsys, Inc. (Pickens, Christopher)
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Filing 301
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #299 MOTION to Seal Synopsys' Memorandum in Support of Its Motion in Limine and Exhibits 1-3 and 7 Thereto (Pickens, Christopher)
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Filing 300
Memorandum in Support re #299 MOTION to Seal Synopsys' Memorandum in Support of Its Motion in Limine and Exhibits 1-3 and 7 Thereto filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 299
MOTION to Seal Synopsys' Memorandum in Support of Its Motion in Limine and Exhibits 1-3 and 7 Thereto by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 298
Memorandum in Support (Redacted Public Version) re: #297 MOTION in Limine filed by Synopsys, Inc. (Attachments: #1 Exhibit 1 (Filed Under Seal), #2 Exhibit 2 (Filed Under Seal), #3 Exhibit 3 (Public Redacted Version), #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 EXHIBIT 7 (Filed Under Seal), #8 Exhibit 8)(Pickens, Christopher). Modified docket text on 2/16/2022. (sbea)
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Filing 297
MOTION in Limine by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 296
Waiver of Hearing on Motion to Seal Synopsys' Exhibit List #293 by Synopsys, Inc. (Cury, Lauren)
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Filing 295
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #293 MOTION to Seal Synopsys' Exhibit List ECF No. #288 (Cury, Lauren)
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Filing 294
Memorandum in Support re #293 MOTION to Seal Synopsys' Exhibit List ECF No. #288 filed by Synopsys, Inc.. (Cury, Lauren)
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Filing 293
MOTION to Seal Synopsys' Exhibit List ECF No. #288 by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Cury, Lauren)
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Filing 292
PUBLIC-REDACTED Exhibit List by Synopsys, Inc... (Cury, Lauren)
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Filing 291
ORDER that the time to file objections has expired and neither party has objected to the report, (See ECF No. #242 ). Having considered the matter and deeming it otherwise proper and just to do so, the Court ACCEPTS and ADOPTS the report as the OPINION of the Court, (ECF No. #240 ). It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/15/2022. (sbea)
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Filing 290
NOTICE by Craig T. Merritt Third Report and Recommendations of Special Master (Merritt, Craig)
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Filing 289
Reply to #187 NOTICE of RBS' Reply ISO Objections to 1st Report of Special Master filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Lonas, Carl)
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Settlement Conference set for 2/22/2022 at 9:30 AM via video conference before Magistrate Judge Elizabeth W. Hanes. (mful)
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Filing 288
Exhibit List by Synopsys, Inc. (Attachments: #1 Exhibit A)(Pickens, Christopher). Modified docket text on 2/15/2022. (sbea)
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Filing 287
RESPONSE in Support re #250 MOTION to Compel PRODUCTION OF DOCUMENTS filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1)(Pickens, Christopher)
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Filing 286
Sealed Response/Reply/Opposition re #247 MOTION to Compel . (Attachments: #1 Exhibit B, #2 Exhibit E, #3 Exhibit F, #4 Exhibit G)(Lonas, Carl)
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Filing 285
REPLY to Response to Motion (Redacted) re: #247 MOTION to Compel filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G)(Lonas, Carl). Modified docket text on 2/15/2022. (sbea)
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Filing 284
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 283
Memorandum in Support re #282 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 282
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 281
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 280
Witness List by Synopsys, Inc.. (Pickens, Christopher)
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Filing 279
Discovery Designation by Synopsys, Inc..(Pickens, Christopher)
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Filing 278
ORDER REGARDING PROCEDURES FOR SETTLEMENT CONFERENCE. The Court has scheduled this case for a settlement conference on February 22, 2022 at 9:30 A.M., to be held by videoconference. In addition to counsel, each party must have a representative present on the videoconference with the full authority to settle this action. If an individual is a named party, that individual must be personally present on the videoconference. If a business entity (or entities) is/are involved, each entity must have a representative with full authority to settle the case on behalf of that entity present on the videoconference. See Order for details and deadlines. It is so ORDERED. Signed by Magistrate Judge Elizabeth W. Hanes on 2/11/2022. (sbea, )
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Filing 277
Second Supplemental Exhibit List by Risk Based Security, Inc... (Lonas, Carl)
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Filing 276
ORDER that this case be REASSIGNED to United States Magistrate Judge Elizabeth W. Hanes for settlement purposes. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/11/2022. (sbea)
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Case Referred to Magistrate Judge Elizabeth W. Hanes. Magistrate Judge Mark R. Colombell no longer assigned to the case. (sbea)
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Filing 275
Waiver of Hearing on Motion to Seal Synopsys Brief in Opposition to Motion Compel and Exhibit 4 Thereto #271 by Synopsys, Inc. (Pickens, Christopher)
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Filing 274
Sealed Attachment/Exhibit 4 re #273 Memorandum in Opposition re #247 MOTION to Compel. (Attachments: #1 Exhibit 4)(Pickens, Christopher)
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Filing 273
Sealed Memorandum in Opposition re #247 MOTION to Compel. (Pickens, Christopher)
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Filing 272
Brief in Support re: #271 MOTION to Seal Synopsys' Brief In Opposition To Motion To Compel And Exhibit 4 Thereto #269 filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 271
MOTION to Seal Synopsys' Brief In Opposition To Motion To Compel And Exhibit 4 Thereto #269 by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 270
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. (Pickens, Christopher)
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Filing 269
Memorandum in Opposition re: #247 MOTION to Compel (Public Redacted Version) filed by Synopsys, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4 (Filed Under Seal), #5 Exhibit 5)(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 268
Supplemental Exhibit List by Risk Based Security, Inc... (Lonas, Carl)
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Filing 267
Opposition re: #250 MOTION to Compel Production of Documents filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B)(Lonas, Carl). Modified docket text on 2/11/2022. (sbea)
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Filing 266
Waiver of Hearing on Motion to Seal Synopsys Response to RBS Objection to the Special Masters First Report and Recommendation and Exhibits B, C, and E thereto #262 by Synopsys, Inc. (Pickens, Christopher)
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Filing 265
Sealed Attachment/Exhibit(s) re #264 Sealed Response re #192 Reply to Special Master's First Report and Recommendation. (Attachments: #1 Exhibit B, #2 Exhibit C, #3 Exhibit E)(Pickens, Christopher)
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Filing 264
Sealed Response re #192 Reply to Special Master's First Report and Recommendation. (Pickens, Christopher)
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Filing 263
Memorandum in Support re: #262 MOTION to Seal Synopsys Response To RBS Objection To Special Masters First Report And Recommendation And Exhibits B, C, And E Thereto #260 Response filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 262
MOTION to Seal Synopsys Response To RBS Objection To Special Masters First Report And Recommendation And Exhibits B, C, And E Thereto #260 by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 261
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. (Pickens, Christopher)
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Filing 260
Response (Public Redacted Version) re: #192 Reply to Special Master's First Report and Recommendation filed by Synopsys, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B (Filed Under Seal), #3 Exhibit C (Filed Under Seal), #4 Exhibit D, #5 Exhibit E (Filed Under Seal))(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 259
Brief in Support to #215 MOTION to Seal , #230 MOTION to Seal filed by Synopsys, Inc.. (Pickens, Christopher)
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Reset Hearing: Bench Trial set for 3/14/2022 at 09:00 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (CHANGED TO BENCH TRIAL) (wtuc)
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Filing 258
ORDERS each party to file any response to the opposing party's motion on or before Thursday, February 10, 2022, and to file any reply on or before Friday, February 11, 2022. After the issuance of the Special Master's Report and Recommendation (the report) on the motions, the parties may file any objections to the report within four days of the date the report is issued. Each party shall file any response to the other party's objections, if any, within four days of the date the objections are filed. The objecting party shall file any reply within two days of the date the response is filed. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 2/8/2022. (sbea)
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Filing 257
Brief in Support re: #253 MOTION to Seal Brief In Support Of Synopsys Motion To Compel Production Of Documents And Exhibits 4-10 Thereto filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 256
Waiver of Hearing on Motion to Seal Synopsys' Brief in Support of Motion to Compel Production of Documents and Exhibits 4-10 #253 by Synopsys, Inc. (Pickens, Christopher)
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Filing 255
Sealed Attachment/Exhibit(s) re: #254 Sealed Memorandum in Support. (Attachments: #1 Exhibit 4 (Filed Under Seal), #2 Exhibit 5 (Filed Under Seal), #3 Exhibit 6 (Filed Under Seal), #4 Exhibit 7 (Filed Under Seal), #5 Exhibit 8 (Filed Under Seal), #6 Exhibit 9 (Filed Under Seal), #7 Exhibit 10 (Filed Under Seal))(Pickens, Christopher). Modified docket text on 2/8/2022. (sbea)
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Filing 254
Sealed Memorandum in Support re: #250 MOTION to Compel Production Of Documents (Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 253
MOTION to Seal Brief In Support Of Synopsys Motion To Compel Production Of Documents And Exhibits 4-10 Thereto by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 252
NOTICE Of Motion To Seal Brief In Support Of Synopsys' Motion To Compel Production Of Documents And Exhibits 4-10 Thereto Filing Sealing Motion LCvR5(C) by Synopsys, Inc. (Pickens, Christopher). Modified docket on 2/8/2022. (sbea)
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Filing 251
Brief in Support (Public Redacted Version) re: #250 MOTION to Compel Production of Documents filed by Synopsys, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4 (Public Redacted Version), #5 Exhibit 5 (Filed Under Seal), #6 Exhibit 6 (Public Redacted Version), #7 Exhibit 7 (Filed Under Seal), #8 Exhibit 8 (Filed Under Seal), #9 Exhibit 9 (Filed Under Seal))(Pickens, Christopher). Modified docket text on 2/8/2022. (sbea)
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Filing 250
MOTION to Compel Production of Documents by Synopsys, Inc. (Attachment: #1 Proposed Order)(Pickens, Christopher). Modified docket text on 2/11/2022. (sbea)
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Filing 249
Sealed Attachment/Exhibit(s) re #248 Memorandum in Support,. (Attachments: #1 Exhibit B, #2 Exhibit H)(Lonas, Carl)
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Filing 248
Memorandum in Support re #247 MOTION to Compel filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I)(Lonas, Carl)
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Filing 247
MOTION to Compel by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 246
Waiver of Hearing by Risk Based Security, Inc. (Lonas, Carl)
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Filing 245
Memorandum in Support re #244 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 244
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 243
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 242
ORDER under Federal Rule of Civil Procedure 53(f)(2), either party may file objections to the Special Master's report no later than 21 days after a copy of the report is served "unless the court sets a different time." Upon due consideration, the Court DIRECTS the parties to file any objections to the report on or before Friday, February 11, 2022. Each party shall file any response to the other party's objections, if any, on or before Friday, February 18, 2022. The objecting party shall file any reply on or before Wednesday, February 23, 2022. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/7/2022. (sbea)
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Filing 241
ORDER that the plaintiff to pay $17,640.00 of the January bill and the defendant to pay $ 17,640.00 of the January bill. The parties shall pay their bills in accordance with any agreements they may have regarding the payment of costs and fees in this case. The Court also ORDERS each party to promptly pay any outstanding balance from the Special Master's December bill, as ordered on January 14, 2022, if it has not yet done so. (ECF No. #174 ). It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/7/2022. (sbea)
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Filing 240
Second Report and Recommendations of Special Master by Craig T. Merritt (Attachments: #1 Exhibit 1 - Eric B. Cole Deposition Transcript Excerpt, #2 Exhibit 2 - Adam Shostack Deposition Transcript Excerpt)(Merritt, Craig). Modified docket text on 2/8/2022. (sbea)
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Filing 239
Exhibit List by Risk Based Security, Inc... (Lonas, Carl)
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Filing 238
Witness List by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 237
Discovery Designation by Risk Based Security, Inc..(Lonas, Carl)
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Filing 236
Sealed Memorandum in Support re: #233 MOTION to Exclude Expert Opinion Of Eric P. Cole, Ph.D. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z, #27 Exhibit AA, #28 Exhibit BB, #29 Exhibit DD, #30 Exhibit EE, #31 Exhibit FF, #32 Exhibit GG)(Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Set as to #219 MOTION for Partial Summary Judgment , #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh, #218 MOTION for Summary Judgment , #233 MOTION to Exclude : Motion Hearing set for 3/1/2022 at 09:30 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (wtuc)
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Filing 235
Memorandum in Support of Motion To Exclude Expert Opinion Of Eric B. Cole, Ph.D. re #233 MOTION to Exclude Expert Opinion Of Eric P. Cole, Ph.D. filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z, #27 Errata AA, #28 Exhibit BB, #29 Exhibit DD, #30 Exhibit CC, #31 Exhibit EE, #32 Exhibit FF, #33 Exhibit GG)(Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Filing 234
Sealed Attachment/Exhibit(s) re #227 Sealed Memorandum in Support. (Attachments: #1 Exhibit 1 (FIILED UNDER SEAL), #2 Exhibit 2 (FIILED UNDER SEAL), #3 Exhibit 4 (FIILED UNDER SEAL), #4 Exhibit 5 (FIILED UNDER SEAL), #5 Exhibit 6 (FIILED UNDER SEAL), #6 Exhibit 8 (FIILED UNDER SEAL), #7 Exhibit 9 (FIILED UNDER SEAL), #8 Exhibit 10 (FIILED UNDER SEAL), #9 Exhibit 12 (FIILED UNDER SEAL), #10 Exhibit 15 (FIILED UNDER SEAL), #11 Exhibit 18 (FIILED UNDER SEAL), #12 Exhibit 19 (FIILED UNDER SEAL), #13 Exhibit 23 (FIILED UNDER SEAL), #14 Exhibit 24 (FIILED UNDER SEAL), #15 Exhibit 25 (FIILED UNDER SEAL), #16 Exhibit 26 (FIILED UNDER SEAL), #17 Exhibit 27 (FIILED UNDER SEAL), #18 Exhibit 28 (FIILED UNDER SEAL), #19 Exhibit 29 (FIILED UNDER SEAL), #20 Exhibit 30 (FIILED UNDER SEAL), #21 Exhibit 31 (FIILED UNDER SEAL), #22 Exhibit 33 (FIILED UNDER SEAL), #23 Exhibit 36 (FIILED UNDER SEAL), #24 Exhibit 38 (FIILED UNDER SEAL), #25 Exhibit 39 (FIILED UNDER SEAL), #26 Exhibit 40 (FIILED UNDER SEAL), #27 Exhibit 41 (FIILED UNDER SEAL), #28 Exhibit 42 (FIILED UNDER SEAL), #29 Exhibit 43 (FIILED UNDER SEAL))(Pickens, Christopher)
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Filing 233
MOTION to Exclude Expert Opinion Of Eric P. Cole, Ph.D. by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Filing 232
Waiver Of Waiver Of Hearing On Motion To Seal re: #230 MOTION to Seal by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Filing 231
Memorandum in Support re #230 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 230
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 229
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 228
Sealed Memorandum in Support re #219 MOTION for Partial Summary Judgment . (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z, #27 Exhibit AA, #28 Exhibit BB)(Lonas, Carl)
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Filing 227
Sealed Memorandum in Support re #218 MOTION for Summary Judgment . (Pickens, Christopher)
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Filing 226
Waiver of Hearing of Motion to Seal Brief in Support of Synopsys' Motion for Summary Judgment and Certain Exhibits #222 by Synopsys, Inc. (Pickens, Christopher)
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Filing 225
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #222 MOTION to Seal Brief in Support of Synopsys' Motion for Summary Judgment and Certian Exhibits Thereto (Pickens, Christopher)
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Filing 224
Memorandum in Support re #222 MOTION to Seal Brief in Support of Synopsys' Motion for Summary Judgment and Certian Exhibits Thereto filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 223
Memorandum in Support (Redacted) re: #219 MOTION for Partial Summary Judgment filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z, #27 Exhibit AA, #28 Exhibit BB, #29 Exhibit CC)(Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Filing 222
MOTION to Seal Brief in Support of Synopsys' Motion for Summary Judgment and Certian Exhibits Thereto by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 221
Brief in Support to #218 MOTION for Summary Judgment (PUBLIC-REDCATED VERSION) filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1 (FIILED UNDER SEAL), #2 Exhibit 2 (FIILED UNDER SEAL), #3 Exhibit 3, #4 Exhibit 4 (PUBLIC REDACTED VERSION), #5 Exhibit 5 (REDACTED-PUBLIC VERSION), #6 Exhibit 6 (FIILED UNDER SEAL), #7 Exhibit 7, #8 Exhibit 8 (REDACTED-PUBLIC VERSION), #9 Exhibit 9 (FIILED UNDER SEAL), #10 Exhibit 10 (FIILED UNDER SEAL), #11 Exhibit 11, #12 Exhibit 12 (FIILED UNDER SEAL), #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15 (FIILED UNDER SEAL), #16 Exhibit 16, #17 Exhibit 17, #18 Exhibit 18 (FIILED UNDER SEAL), #19 Exhibit 19 (REDACTED-PUBLIC VERSION), #20 Exhibit 20, #21 Exhibit 21, #22 Exhibit 22, #23 Exhibit 23 (FIILED UNDER SEAL), #24 Exhibit 24 (FIILED UNDER SEAL), #25 Exhibit 25 (FIILED UNDER SEAL), #26 Exhibit 26 (FIILED UNDER SEAL), #27 Exhibit 27 (FIILED UNDER SEAL), #28 Exhibit 28 (FIILED UNDER SEAL), #29 Exhibit 29 (FIILED UNDER SEAL), #30 Exhibit 30 (FIILED UNDER SEAL), #31 Exhibit 31 (FIILED UNDER SEAL), #32 Exhibit 32, #33 Exhibit 33 (FIILED UNDER SEAL), #34 Exhibit 34, #35 Exhibit 35, #36 Exhibit 36 (FIILED UNDER SEAL), #37 Exhibit 37, #38 Exhibit 38 (FIILED UNDER SEAL), #39 Exhibit 39 (FIILED UNDER SEAL), #40 Exhibit 40 (FIILED UNDER SEAL), #41 Exhibit 41 (REDACTED-PUBLIC VERSION), #42 Exhibit 42 (FIILED UNDER SEAL), #43 Exhibit 43 (FIILED UNDER SEAL))(Pickens, Christopher)
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Filing 220
(DISREGARD - See ECF #223 ) - Memorandum in Support (Redacted) re: #219 MOTION for Partial Summary Judgment filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/4/2022. (sbea) Modified on 2/4/2022 (smej, ).
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Filing 219
MOTION for Partial Summary Judgment by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 218
MOTION for Summary Judgment by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 217
Waiver of Hearing On Motion To Seal re: #215 MOTION to Seal by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/4/2022. (sbea)
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Filing 216
Memorandum in Support re #215 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 215
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 214
Notice of Under Seal Filing LCvR5 (B) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 213
Waiver of Hearing on Motion to Seal Synopsyss Memorandum in Support of its Motion to Exclude the Expert Opinions of Adam Shostack and Steven Kursh, and Exhibits A-E and I-L thereto #209 by Synopsys, Inc. (Pickens, Christopher)
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Filing 212
Sealed Attachment/Exhibit(s) re #211 Sealed Memorandum in Support. (Attachments: #1 Exhibit A (FILED UNDER SEAL), #2 Exhibit B (FILED UNDER SEAL), #3 Exhibit C (FILED UNDER SEAL), #4 Exhibit D (FILED UNDER SEAL), #5 Exhibit E (FILED UNDER SEAL), #6 Exhibit I (FILED UNDER SEAL), #7 Exhibit J (FILED UNDER SEAL), #8 Exhibit K (FILED UNDER SEAL), #9 Exhibit L (FILED UNDER SEAL))(Pickens, Christopher)
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Filing 211
Sealed Memorandum in Support re #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh. (Pickens, Christopher)
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Filing 210
Memorandum in Support re #209 MOTION to Seal Memorandum in Support of Synopsys' Motion to Exclude Expert Opinions of Adam Shostack and Steven Kursh and Exhibits A-E and I-L Thereto filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 209
MOTION to Seal Memorandum in Support of Synopsys' Motion to Exclude Expert Opinions of Adam Shostack and Steven Kursh and Exhibits A-E and I-L Thereto by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 208
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #207 Brief in Support,, (Pickens, Christopher)
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Filing 207
Brief in Support to #206 MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh (REDACTED - PUBLIC VERSION) filed by Synopsys, Inc.. (Attachments: #1 Exhibit A (FILED UNDER SEAL), #2 Exhibit B (FILED UNDER SEAL), #3 Exhibit C (FILED UNDER SEAL), #4 Exhibit D (FILED UNDER SEAL), #5 Exhibit E (FILED UNDER SEAL), #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I (FILED UNDER SEAL), #10 Exhibit J (FILED UNDER SEAL), #11 Exhibit K (FILED UNDER SEAL), #12 Exhibit L (FILED UNDER SEAL))(Pickens, Christopher)
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Filing 206
MOTION to Exclude Expert Opinions of Adam Shostack and Steven Kursh by Synopsys, Inc.. (Attachments: #1 Supplement)(Pickens, Christopher)
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Filing 205
ORDER based on the parties' motion, the agreement of counsel as reflectedtherein, the entire record herein, and for good cause shown: It is ORDERED that the Motion is GRANTED, (ECF No. #204 ); and It is ORDERED, as to the Court's Third Amended Scheduling Order (ECF No. #159 ), RBS will meet the "plaintiff" deadlines for filing witness lists and discovery designations, and Synopsys will meet the "defendant" deadline for filing its witness lists and discovery designations. The deadlines themselves remain unchanged. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/3/2022. (sbea)
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Filing 204
Joint MOTION Regarding Pretrial Deadlines by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Connally, Nathaniel)
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Filing 203
Waiver of Hearing on Motion to Seal Exhibits 2 and 3 of Hearing before Special Master Craig T. Merritt of January 18, 2022, and RBS' Supplemental Interrogatory Answers by Synopsys, Inc. (Pickens, Christopher)
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Filing 202
Sealed Attachment/Exhibit(s) re: #201 Notice of Filing Sealing Motion LCvR5(C). (Attachments: #1 Exhibit A - Redacted, #2 Exhibit B)(Pickens, Christopher). Modified docket text on 2/3/2022. (sbea)
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Filing 201
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #199 MOTION to Seal Exhibits 2 and 3 of Hearing before Special Master Craig T. Merritt on January 18, 2022, and RBS' Supplemental Interrogatory Answers (Pickens, Christopher)
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Filing 200
Memorandum in Support re #199 MOTION to Seal Exhibits 2 and 3 of Hearing before Special Master Craig T. Merritt on January 18, 2022, and RBS' Supplemental Interrogatory Answers filed by Synopsys, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B)(Pickens, Christopher)
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Filing 199
MOTION to Seal Exhibits 2 and 3 of Hearing before Special Master Craig T. Merritt on January 18, 2022, and RBS' Supplemental Interrogatory Answers by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 198
ORDER that this matter comes before the Court on the Special Master's Report and Recommendation ("report"), (ECF No. #187 ). On January 31, 2022, the defendant Risk Based Security, Inc. ("RBS") fil ed objections to the report, (ECF No. #192 ). The Court DIRECTS the plaintiff Synopsys, Inc. ("Synopsys") to file any response on or before Thursday, February 10, 2022. RBS SHALL file any reply on or before Monday, February 14, 2022. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 2/2/2022. (sbea)
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Filing 197
Waiver of Hearing On Motion To Seal re: #194 MOTION to Seal by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/3/2022. (sbea)
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Filing 196
Sealed Attachment/Exhibit(s) re: #195 Memorandum in Support. (Attachments: #1 Exhibit B - Redacted, #2 Exhibit C - Redacted)(Lonas, Carl). Modified docket text on 2/3/2022 .(sbea)
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Filing 195
Memorandum in Support re #194 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 194
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 193
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. re #186 NOTICE (Lonas, Carl)
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Notice of Correction re: #192 Reply; Clerk left a voicemail message with filing attorney on selecting the correct filing event. Attorney selected "Reply" and the correct event is "Response". Clerk has corrected the docket text and no further action is required at this time. (sbea)
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Filing 192
Response to #187 Special Master's Report and Recommendation filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 2/1/2022. (sbea)
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Filing 191
ORDER that this matter comes before the Court on the joint motion of Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Risk Based Security, Inc. ("RBS," and with Synopsys, the "Parties") regarding expert deadlines and order of presentation at trial. The Court GRANTS the motion, (ECF No. #190 ), and ORDERS that the expert discovery deadlines in the Court's Third Amended Pretrial Order, (ECF No. #159 ), are modified as set forth: Rebuttal reports from RBS' experts, Adam Shostack and Steven Kursh, due on January 28, 2022, may include new opinions based on discovery received after their initial reports, specifically identified as such; Depositions of the parties' experts will be completed by February 1, 2022; Synopsys' expert, Dr. Cole, may serve a sur-reply report that replies to the new opinions of Shostack and Kursh disclosed in their rebuttal reports, on February 2, 2022;and It is ORDERED that RBS will file its list of exhibits on February 4, 2022, that Synopsys will file its list of exhibits on February 11, 2022, and that RBS will file its list of exhibits on February 17, 2022. The remaining deadlines in the Third Amended Pretrial Order remain unchanged, (ECF No. #159 ). It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/31/2022. (sbea)
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Filing 190
JOINT MOTION Regarding Expert Discovery Deadlines and the Order of Presentation at Trial by Synopsys, Inc. (Attachments #1 Proposed Order)(Connally, Nathaniel). Modified docket text on 2/1/2022. (sbea)
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Filing 189
ORDER that this matter comes before the Court on the Special Master's Report and Recommendation, (ECF No. #187 ). Under Federal Rule of Civil Procedure 53(f)(2), the parties may file objections to the Special Master's report no later than 21 days after a copy of the report is served "unless the court sets a different time". Having considered the upcoming deadlines in the Third Amended Pretrial Order and the March 14, 2022 trial date, the Court DIRECTS the parties to file any objections on or before Monday, January 31, 2022. If the parties seek to extend any deadlines in the Third Amended Pretrial Order, they should file a motion-jointly, if possible-proposing new deadlines. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/27/2022. (sbea)
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Notice of Correction re: #186 Special Master's Temporary Sealing Order for Attachments to Report and Recommendations; per Local Rules, please be mindful when including the "Nine Element Signature Block" to include all elements including the filing attorney's bar number. No further action is required at this time. (sbea)
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Filing 188
Sealed Attachment/Exhibit(s) re #187 NOTICE. (Attachments: #1 Appendix Transcript of January 18, 2022, Special Master Hearing, #2 Appendix January 18, 2022, Hearing Exhibit 1, #3 Appendix January 18, 2022, Hearing Exhibit 2, #4 Appendix January 18, 2022, Hearing Exhibit 3, #5 Appendix January 18, 2022, Hearing Exhibit 4, #6 Appendix January 18, 2022, Hearing Exhibit 5, #7 Appendix October 18, 2021, RBS Second Supplemental Interrogatory Response, #8 Appendix January 12, 2022, RBS Third Supplemental Interrogatory Response)(Merritt, Craig)
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Filing 187
First Report and Recommendations of Special Master by Craig T. Merritt (Merritt, Craig). Modified docket text on 1/27/2022. (sbea)
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Filing 186
Special Master's Temporary Sealing Order for Attachments to Report and Recommendations by Craig T. Merritt (Merritt, Craig). Modified docket text on 1/27/2022. (sbea)
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Filing 185
ORDER granting #184 Motion for Pro hac vice Appointed Richard Li for Synopsys, Inc.. Signed by District Judge John A. Gibney, Jr on 1/20/22. (adun, )
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Filing 184
Motion to appear Pro Hac Vice by Richard Li and Certification of Local Counsel Lauren Cury Filing fee $ 75, receipt number AVAEDC-8203942. by Synopsys, Inc.. (Cury, Lauren)
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Filing 182
ORDER that the Court directed the parties to file status reports indicating which of the remaining motions to seal-or which parts of the remaining motions to seal-still required adjudication and which motions had become moot on the basis of the Court's findings in the January 11 Order. Upon due consideration of the parties' status reports, the Court DENIES the following motions to seal as MOOT: October 22, 2021 motion to seal (ECF No. #81 ); November 10, 2021 motion to seal (ECF No. #109 ); November 16, 2021 motion to seal (ECF No. #120 ); December 13, 2021 motion to seal (ECF No. #144 ); December 17, 2021 motion to seal (ECF No. #151 ); January 5, 2022 motion to seal (ECF No. #163 ). Synopsys also moves the Court to reconsider the January 11 Order and asks the Court to seal certain documents pending disposition of the motion, (ECF Nos. #177 and #178 ). The Court DIRECTS the Clerk to file ECF Nos. 175-3 through -8 under seal pending the Court's disposition of Synopsys's motion. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/20/2022. (sbea)
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Filing 181
Financial Interest Disclosure Statement (Local Rule 7.1) by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 180
Declaration of Ean Sewell re: #177 MOTION for Reconsideration; #172 Order #179 Status Report, by Synopsys, Inc. (Connally, Nathaniel). Modified docket text on 1/19/2022. (sbea)
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Filing 179
STATUS REPORT regarding Dkt. 172 by Synopsys, Inc. (Attachments: #1 Exhibit 1 - Redacted, #2 Exhibit 2 - Redacted, #3 Exhibit 3 - Redacted, #4 Exhibit 4 - Redacted, #5 Exhibit 5 - Redacted, #6 Exhibit 6 - Redacted, #7 Exhibit 7 - Redacted, #8 Exhibit 8 - Redacted, #9 Exhibit 9 - Redacted, #10 Exhibit 10 - Redacted, #11 Exhibit 11 - Redacted)(Connally, Nathaniel). Modified docket text on 1/19/2022. (sbea)
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Filing 178
Memorandum in Support re: #177 MOTION for Reconsideration re #172 Order filed by Synopsys, Inc. (Attachments: #1 Exhibit 1 - Redacted, #2 Exhibit 2 - Redacted, #3 Exhibit 3 - Redacted, #4 Exhibit 4 - Redacted, #5 Exhibit 5 - Redacted, #6 Exhibit 6 - Redacted, #7 Exhibit 7 - Redacted)(Connally, Nathaniel). Modified docket text on 1/19/2022. (sbea)
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Filing 177
MOTION for Reconsideration re: #172 Order by Synopsys, Inc. (Attachment: #1 Proposed Order)(Connally, Nathaniel). Modified docket text on 1/19/2022. (sbea)
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Filing 176
STATUS REPORT Pursuant to DKT 172 by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 175
NOTICE of Filing by Risk Based Security, Inc. re: #172 Order Filings Per Order: (Attachments: #1 Reply Memorandum Re: DKT 30, #2 Exhibit E - Redacted Re: DKT 31, #3 Exhibit F - Redacted Re: DKT 31, #4 Exhibit G - Redacted Re: DKT 31, #5 Exhibit H - Redacted Re: DKT 31, #6 Exhibit I - Redacted Re: DKT 31, #7 Exhibit J - Redacted Re: DKT 31, #8 Exhibit K - Redacted Re: DKT 31, #9 Exhibit L Re: DKT 31, #10 Exhibit M Re: DKT 31)(Lonas, Carl). Modified docket text on 1/19/2022. (sbea)
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Filing 174
ORDER that the Court received a bill from Craig T. Merritt or Merritt Law, PLLC. totaling $2,220.00 for services rendered in his capacity as Special Master for discovery (the "December bill"). Pursuant to the Order appointing Mr. Merritt, (ECF No. #135 ), the Court will allocate payment among the parties. Upon clue consideration. the Court ORDERS the plaintiff to pay $1,110.00 of the December bill and the defendant to pay $1,110.00 or the December bill. The parties shall pay their bills in accordance with any agreements they may have regarding the payment of costs and fees in this case. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/14/2022. (sbea)
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Filing 173
Special Master Scheduling Order No. 1 by Craig T. Merritt (Merritt, Craig). Modified docket text on 1/13/2022. (sbea)
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Filing 172
MEMORANDUM ORDER that the Court DENIES RBS's #33 motion to seal. The Court DIRECTS the parties to refile documents that comply with this Order within seven days of the date of this Order. The Court DIRECTS the parties to file status reports within seven days of the date of this Order indicating which of the remaining motions to seal-or which parts of the remaining motions to seal-still require adjudication and which motions have become moot on the basis of the Court's findings in this Order. For any sealing motions, or any portions of sealing motions, that still require adjudication on the merits, the parties shall set forth the reasons for sealing in their status reports. See Order for details. It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/11/2022. (sbea)
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Filing 171
ORDER for the reasons stated in the accompanying Opinion, the Court FINDS that a justiciable controversy exists. The Court's November 19, 2021 Order addresses the Court's holdings on RBS's motions to dismiss and for judgment on the pleadings, (ECF No. #128 ). It is so ORDERED. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/11/2022. (sbea)
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Filing 170
OPINION. See Opinion for details. Signed by Senior United States District Judge John A. Gibney, Jr. on 1/11/2022. (sbea)
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Filing 169
TRANSCRIPT of proceedings held on 01/06.2022, before Judge Hon. John A. Gibney, Jr., Court Reporter Gil Halasz, Telephone number 804 916-2248. NOTICE RE REDACTION OF TRANSCRIPTS:The parties have thirty(30) calendar days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.vaed.uscourts.gov Transcript may be viewed at the court public terminal or purchased through the court reporter/transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER Redaction Request due 2/8/2022. Redacted Transcript Deadline set for 3/11/2022. Release of Transcript Restriction set for 4/11/2022.(halasz, gil)
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Filing 168
Minute Entry for proceedings held before District Judge John A. Gibney, Jr.: Hearing held on 1/6/2022; arguments of counsel heard; an opinion will issue on Court's ruling (Court Reporter G. Halasz, OCR.)(wtuc)
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Filing 167
Sealed Document re #163 MOTION to Seal . (Attachments: #1 Exhibit A)(Lonas, Carl)
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Filing 166
NOTICE Of Supplemental Evidence In Support Of Memorandum As to The Absence Of Any Justiciable Controversy by Risk Based Security, Inc. re: #142 Memorandum as to the Absence of Any Justiciable Controversy. (Attachment: #1 Exhibit A)(Lonas, Carl). Modified docket text on 1/6/2022. (sbea)
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Filing 165
WAIVER of Hearing On Motion To Seal re: #163 MOTION to Seal by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 1/6/2022. (sbea)
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Filing 164
Memorandum in Support re #163 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 163
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 162
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. (Lonas, Carl)
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Filing 159
THIRD AMENDED PRETRIAL ORDER - See Order for details. Signed by District Judge John A. Gibney, Jr on 12/27/2021. (cgar)
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Filing 158
JOINT MOTION to Modify Discovery Deadlines by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 12/27/2021. (sbea)
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Filing 157
ORDER GRANTING MOTION TO WITHDRAW APPEARANCE OF COUNSEL. Chunmeng Yang previously entered an appearance, pro hac vice, as attorney forDefendant Risk Based Security, Inc. in this matter. Ms. Yang no longer represents Defendant. The Court therefore grants the motion seeking her withdrawal as counsel in this matter. SO ORDERED. Signed by District Judge John A. Gibney, Jr. on 12/22/2021. (sbea)
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Filing 156
MOTION to Withdraw as Attorney Re: Chunmeng Yang by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Set Hearing: Hearing on #142 , #143 , #149 , and #150 set for 1/6/2022 at 09:30 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (wtuc)
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Filing 155
Waiver of Hearing on Motion to Seal Exhibit L to Synopsys' Response to Risk Based Security, Inc.'s Memorandum as to the Absence of any Justiciable Controversy by Synopsys, Inc. (Connally, Nathaniel)
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Filing 154
Sealed Attachment/Exhibit(s) re #153 Notice of Filing Sealing Motion LCvR5(C),. (Attachments: #1 Exhibit L (FILED UNDER SEAL))(Connally, Nathaniel)
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Filing 153
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #151 MOTION to Seal Exhibit L to Synopsys' Response to Risk Based Security, Inc.'s Memorandum as to the Absence of any Justiciable Controversy (Connally, Nathaniel)
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Filing 152
Memorandum in Support re #151 MOTION to Seal Exhibit L to Synopsys' Response to Risk Based Security, Inc.'s Memorandum as to the Absence of any Justiciable Controversy filed by Synopsys, Inc.. (Connally, Nathaniel)
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Filing 151
MOTION to Seal Exhibit L to Synopsys' Response to Risk Based Security, Inc.'s Memorandum as to the Absence of any Justiciable Controversy by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Connally, Nathaniel)
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Filing 150
Response to #142 Memorandum as to the Absence of Any Justiciable Controversy filed by Synopsys, Inc.. (Attachments: #1 Exhibit L (FILED UNDER SEAL))(Connally, Nathaniel)
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Filing 149
Response to #143 Memorandum, as to Whether RBS' Covenant Not to Sue Moots the Instant Declaratory judgment Action filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit 3, #2 Exhibit 4, #3 Exhibit 5)(Lonas, Carl)
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Filing 148
Waiver of Hearing on Motion to Seal Exhibits C, K and portions of Exhibit I to Synopsys Statement That a Conditional and Revocable Covenant Not to Sue Does Not Moot its Declaratory Judgment Action by Synopsys, Inc. (Connally, Nathaniel)
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Filing 147
Sealed Exhibit(s) re #146 Notice of Filing Sealing Motion LCvR5(C) (Attachments: #1 Exhibit C (FILED UNDER SEAL), #2 Exhibit I (REDACTED - PORTIONS FILED UNDER SEAL), #3 Exhibit K (FILED UNDER SEAL))(Connally, Nathaniel)
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Filing 146
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #144 MOTION to Seal Exhibits C, K and portions of Exhibit I to Synopsys Statement That a Conditional and Revocable Covenant Not to Sue Does Not Moot its Declaratory Judgment Action (Connally, Nathaniel)
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Filing 145
Memorandum in Support re #144 MOTION to Seal Exhibits C, K and portions of Exhibit I to Synopsys Statement That a Conditional and Revocable Covenant Not to Sue Does Not Moot its Declaratory Judgment Action filed by Synopsys, Inc.. (Connally, Nathaniel)
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Filing 144
MOTION to Seal Exhibits C, K and portions of Exhibit I to Synopsys Statement That a Conditional and Revocable Covenant Not to Sue Does Not Moot its Declaratory Judgment Action by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Connally, Nathaniel)
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Filing 143
Memorandum That a Conditional and Revocable Covenant Not to Sue Does Not Moot Synopsys' Declaratory Judgment Action to #139 Order, filed by Synopsys, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C (FILED UNDER SEAL), #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I (REDACTED), #10 Exhibit J, #11 Exhibit K (FILED UNDER SEAL))(Connally, Nathaniel)
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Filing 142
Memorandum as to the Absence of Any Justiciable Controversy to #139 Order, filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Lonas, Carl)
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Filing 141
ORDER that on December 1, 2021, the Court appointed Craig T. Merritt of Merritt Law, PLLC, as Special Master and directed him to file a proposed schedule of rates for any lawyers, legal assistants, and support staff on his team and for any expert consultants. The Court further directed the parties to file any objections within seven days of the Special Master's filing, (ECF No. #135 ). On December 3, 2021, the Special Master filed his proposed fee schedule. Neither party has objected. Upon due consideration, the Court APPROVES the proposed rate schedule as reasonable. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 12/13/2021. (sbea)
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Filing 140
Transcript Redaction Request re: #130 Transcript by attorney Carl Dewayne Lonas (Lonas, Carl). Modified docket text on 12/13/2021. (sbea)
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Filing 139
ORDER. The COURT ORDERS each party to state its position as to whether a justiciable controversy exists in light of RBS's filings #132 , on or before Monday, December 13, 2021. Each party shall file any response on or before Friday, December 17, 2021. SEE ORDER FOR DETAILS. Signed by District Judge John A. Gibney, Jr. on 12/7/2021. (adun, )
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Filing 138
Letter to Judge Gibney from Plaintiff Synopsys. (Connally, Nathaniel)
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Filing 137
Letter to Judge Gibney. (Lonas, Carl)
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Filing 136
NOTICE by Craig T. Merritt re #135 Order,, Proposed Fee Schedule of Special Master (Merritt, Craig)
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Filing 135
ORDER that this matter comes before the Court on the parties' joint notice regarding the appointment of a Special Master and request that the Court appoint Craig T. Merritt of Merritt Law, PLLC, as Special Master for discovery, (ECF No. #131 . Mr. Merritt has conducted a search for conflicts of interest and has filed the affidavit required by Federal Rule of Civil Procedure 53(b)(3), (ECFNo. #133 ). His affidavit does not identify any conflicts. Accordingly, pursuant to Rule 53, the Court hereby APPOINTS Mr. Merritt to serve as Special Master for the purposes of discovery in this case. See Order for complete details. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 12/1/2021. (sbea, )
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Filing 134
NOTICE of Appearance by Lauren Beth Cury on behalf of Synopsys, Inc. (Cury, Lauren)
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Filing 133
AFFIDAVIT regarding 28 U.S.C. 455 compliance by Craig T. Merritt. (Merritt, Craig)
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Filing 132
NOTICE OF FILING by Risk Based Security, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Pollock, Stewart). Modified docket text on 11/29/2021. (sbea)
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Filing 131
NOTICE by Synopsys, Inc. (Joint Notice) regarding Special Master Pursuant to the Court's November 19, 2021 #128 Order (Pickens, Christopher)
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Filing 130
TRANSCRIPT of proceedings held on 11/18/2021, before Judge Hon. John A. Gibney, Jr., Court Reporter Gil Halasz, Telephone number 804 916-2248. NOTICE RE REDACTION OF TRANSCRIPTS:The parties have thirty(30) calendar days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.vaed.uscourts.gov Transcript may be viewed at the court public terminal or purchased through the court reporter/transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER Redaction Request due 12/22/2021. Redacted Transcript Deadline set for 1/24/2022. Release of Transcript Restriction set for 2/21/2022.(halasz, gil)
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Filing 129
SYNOPSYS' OMNIBUS Sur-Reply to RBS' Motions for Judgment on the Pleadings and For Reconsideration filed by Synopsys, Inc. (sbea)
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Filing 128
ORDER that the Court held a hearing on the motions on Thursday, November 18, 2021. Upon due consideration and for the reasons stated from the bench, the Court ORDERS as follows: 1) The Court GRANTS RBS's motion to dismiss Count III, (ECF No. #48 ). The Court will issue an accompanying opinion. 2) The Court GRANTS RBS's motion for reconsideration of the Court's Order on the motion to stay and DENIES the motion to stay, (ECF No. #68 ). 3) The Court DENIES RBS's motion for judgment on the pleadings, (ECF No. #71 ). The Court will issue an accompanying opinion. 4) The Court GRANTS Synopsys's motion for clarification of the amended pretrial order, (ECF No. #76 ), and FINDS that RBS has the burden of proof on all remaining claims. 5) The Court DENIES Synopsys's motion to compel, (ECF No. #78 ), and Synopsys's motion for a protective order, (ECF No. #79 ). The Court GRANTS Synopsys leave to refile the motion to compel. The Court ORDERS the parties to proceed with discovery and to begin depositions. The Court ORDERS that Synopsys will take the first deposition, and DIRECTS the parties to alternate depositions thereafter. 6) The Court GRANTS Synopsys's November 2, 2021 motion for leave to file a sur-reply to RBS's motions for reconsideration and judgment on the pleadings, (ECF No. #94 ), and DIRECTS the Clerk to docket Synopsys's sur-reply, (ECF No. 94-1). 7) The Court may appoint one of the following attorneys to serve as special master for discovery. The Court DIRECTS each party to file a notice on or before Tuesday, November 23, 2021, indicating its objection or consent to the appointment of a special master. If the parties reach a consensus on these issues, they may file a joint notice on or before Tuesday, November 23, 2021. RBS filed a motion for sanctions and to modify the scheduling order. (ECF No. #116 ). Because the Court finds that the appointment of a special master, the Court's ruling on Synopsys's motion for a protective order, the Court's order for the parties to proceed with discovery, and the extension or pretrial deadlines sufficiently addresses RBS's motion, the Court DENIES the motion as MOOT. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 11/19/2021. (sbea)
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Filing 127
SECOND AMENDED PRETRIAL ORDER (see order for new deadlines). Signed by District Judge John A. Gibney, Jr. on 11/18/21. (wtuc)
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Filing 126
Minute Entry for proceedings held before District Judge John A. Gibney, Jr.:Motion Hearing held on 11/18/2021 re #48 MOTION to Dismiss for Failure to State a Claim filed by Risk Based Security, Inc., #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2 filed by Synopsys, Inc., #79 MOTION for Protective Order filed by Synopsys, Inc., #76 MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings filed by Synopsys, Inc., #71 MOTION for Judgment on the Pleadings filed by Risk Based Security, Inc., #68 MOTION for Reconsideration re #47 Order on Motion to Stay, filed by Risk Based Security, Inc; findings made from bench, motions ruled on; an order to enter (Court Reporter G. Halasz, OCR.)(wtuc) (Main Document 126 replaced on 11/19/2021) (wtuc, ).
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Filing 123
Sealed Attachment/Exhibit(s) re #118 Affidavit in Support of Motion,. (Attachments: #1 Exhibit 4, #2 Exhibit 5)(Lonas, Carl)
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Filing 122
Sealed Memorandum in Support re #117 Memorandum in Support. (Lonas, Carl)
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Filing 121
Memorandum in Support re #120 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 120
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 119
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. re #118 Affidavit in Support of Motion, #117 Memorandum in Support (Lonas, Carl)
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Filing 118
AFFIDAVIT in Support re: #116 MOTION for Sanctions and to Modify Scheduling Order filed by Risk Based Security, Inc. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4 - Redacted, #5 Exhibit 5 - Redacted, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9)(Lonas, Carl). Modified docket text on 11/18/2021. (sbea)
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Filing 117
Memorandum in Support (Redacted) re: #116 MOTION for Sanctions and to Modify Scheduling Order filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 11/18/2021. (sbea)
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Filing 116
MOTION for Sanctions and to Modify Scheduling Order by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 115
RESPONSE to Motion re #100 MOTION to Seal filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1 (Declaration of Shanee Y.W. Nelson), #2 Proposed Order)(Pickens, Christopher)
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Filing 114
REPLY to Response to Motion re #76 MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 113
Waiver of Hearing on Motion to Seal Portions of Synopsys' Reply Brief in Support of Its Motion to Compel and Motion for Protective Order by Synopsys, Inc. (Pickens, Christopher)
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Filing 112
Sealed Reply Brief in Support of Synopsys' Motion to Compel and Motion for Protective Order (Pickens, Christopher)
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Filing 111
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #108 Reply to Response to Motion, (Pickens, Christopher)
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Filing 110
Memorandum in Support re #109 MOTION to Seal Portions of Synopsys' Reply Brief in Support of its Motion to Compel and Motion for Protective Order filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 109
MOTION to Seal Portions of Synopsys' Reply Brief in Support of its Motion to Compel and Motion for Protective Order by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 108
REPLY to Response to Motion (REDACTED - PUBLIC VERSION) re: #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2, #79 MOTION for Protective Order filed by Synopsys, Inc. (Pickens, Christopher). Modified docket text on 11/12/2021. (sbea)
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Filing 107
REPLY to Response to Motion re #94 MOTION for Leave to File Sur-Reply to Motions for Reconsideration and Judgment on the Pleadings filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 106
Memorandum in Opposition re #76 MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings filed by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 105
RESPONSE in Opposition re #94 MOTION for Leave to File Sur-Reply to Motions for Reconsideration and Judgment on the Pleadings filed by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 104
Sealed Attachment/Exhibit(s) re #98 Affidavit in Opposition to Motion,,. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit U, #21 Exhibit V)(Pollock, Stewart)
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Filing 103
Sealed Response/Reply/Opposition re #97 Memorandum in Opposition,. (Pollock, Stewart)
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Filing 102
Waiver of Hearing re: #100 MOTION to Seal by Risk Based Security, Inc. (Pollock, Stewart). Modified docket text on 11/5/2021. (sbea)
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Filing 101
Memorandum in Support re #100 MOTION to Seal filed by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 100
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Pollock, Stewart)
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Filing 99
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. re #98 Affidavit in Opposition to Motion,, #97 Memorandum in Opposition, (Pollock, Stewart)
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Filing 98
AFFIDAVIT in Opposition re #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2, #79 MOTION for Protective Order filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H, #9 Exhibit I, #10 Exhibit J, #11 Errata K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R, #19 Exhibit S, #20 Exhibit T, #21 Exhibit U, #22 Exhibit V, #23 Exhibit W, #24 Exhibit X, #25 Exhibit Y, #26 Exhibit Z)(Pollock, Stewart)
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Filing 97
Memorandum in Opposition (Redacted) re: #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2, #79 MOTION for Protective Order filed by Risk Based Security, Inc. (Pollock, Stewart). Modified docket text on 11/5/2021. (sbea)
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Filing 96
ORDER This matter comes before the Court on Synopsys, Inc.'s ("Synopsys") motion for leave to file a sur-reply to Risk Based Security, Inc.'s ("RBS") motions for reconsideration of the Court's Order on the motion to stay and for judgment on the pleadings. (ECF No. #94 .) The Court DIRECTS RBS to file its response to the motion, if any, on or before Friday, November 5, 2021.Synopsys shall tile its reply, if any, on or before Monday, November 8. It is so ORDERED. Signed by District Judge John A. Gibney, Jr on 11/3/2021. (asho, )
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Filing 95
Brief in Support to #94 MOTION for Leave to File Sur-Reply to Motions for Reconsideration and Judgment on the Pleadings filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 94
MOTION for Leave to File Sur-Reply to Motions for Reconsideration and Judgment on the Pleadings by Synopsys, Inc.. (Attachments: #1 Exhibit 1)(Pickens, Christopher)
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Filing 93
Letter of Rogatory prepared and issued for filing attorney to serve on defendants located in Canada. (sbea)
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Filing 92
ORDER that the #73 motion issuance of letters rogatory. In accordance with this Order, the Court has executed the attached letter of request. The Court DIRECTS the Clerk to execute, certify, and imprint the Court's seal on the letter. The Court further DIRECTS the Clerk to docket a copy of the letter and to make the original available to the plaintiff for filing with the Vancouver Civil Court in Vancouver, British Columbia, Canada. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 10/28/2021. (Attachment: #1 Letter of Request). (sbea)
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Notice of Correction re: #90 Affidavit in Support of Motion; the Affidavit in Support does not contain the 9-element signature block. Please contact the Clerk's Office and this document can be switched out upon receipt and the NEF will be regenerated. (sbea)
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Filing 91
REPLY to Response to Motion re: #68 MOTION for Reconsideration, re: #47 Memorandum Order filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 10/27/2021. (sbea)
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Filing 90
AFFIDAVIT in Support re: #71 MOTION for Judgment on the Pleadings filed by Risk Based Security, Inc. (Attachments: #1 Exhibit A, #2 Exhibit B)(Lonas, Carl). Clerk replaced main document on 10/27/2021). NEF was regenerated. Modified docket text on 10/27/2021. (sbea)
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Filing 89
REPLY to Response to Motion re #71 MOTION for Judgment on the Pleadings filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 88
ORDER that this matter comes before the Court on 1) Risk Based Security, Inc.'s ("RBS") motion to dismiss, (ECF No. #48 ); 2) RBS's motion fo r reconsideration of the Court's Order on the motion to stay, (ECF No. #68 ); 3) RBS's motion for judgment on the pleadings, (ECF No. [71); Synopsys, Inc.'s ("Synopsys") motion for clarification of the amended pretrial order, (ECF No. #76 ); Synopsys' motion to compel, (ECF No. #78 ); and Synopsys' motion for a protective order, (ECF No. #79 ). The Court SCHEDULES a hearing on the motions for Thursday, November 18, 2021, at 9:30 a.m. Because of the pending motion for clarification of the amended pretrial order, the Court AMENDS paragraph 4 of the amended pretrial order, (ECF No. 40 para 4), as follows: Expert Witnesses. The parties will disclose the information required under Rule 26(a)(2) on the following schedule: Party with the burden of proof on an issue by December 2, 2021; opposing party by December 20, 2021; rebuttal expert(s) by January 3, 2022. Motions, by either party, challenging the designation of experts shall be filed by at least January 13, 2022. The remaining deadlines in the amended pretrial order remain the same. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 10/26/2021. (sbea)
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Set as to #79 MOTION for Protective Order, #68 MOTION for Reconsideration re #47 Order on Motion to Stay, #48 MOTION to Dismiss for Failure to State a Claim, #76 MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings, #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2, #71 MOTION for Judgment on the Pleadings: Motion Hearing set for 11/18/2021 at 09:30 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (wtuc)
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Filing 87
Letter RECEIVED regarding payment for ECF No. #73 Motion for Issuance of Letter Rogatory. (Attachment: #1 Receipt). (sbea)
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Filing 86
Notice of Filing Sealing Motion LCvR5(C) by Synopsys, Inc. re #80 Brief in Support,, and Exhibits 3-8 Thereto (Pickens, Christopher)
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Filing 85
Waiver of Hearing on Motion to Seal Portions of Synopsys' Brief in Support of Motion to Compel and Motion for Protective Order and Exhibits 3-8 Thereto by Synopsys, Inc. (Pickens, Christopher)
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Filing 84
Sealed Attachment/Exhibit(s). (Attachments: #1 Exhibit 3 (FILED UNDER SEAL), #2 Exhibit 4 (FILED UNDER SEAL), #3 Exhibit 5 (FILED UNDER SEAL), #4 Exhibit 6 (FILED UNDER SEAL), #5 Exhibit 7 (FILED UNDER SEAL), #6 Exhibit 8 (FILED UNDER SEAL))(Pickens, Christopher)
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Filing 83
Sealed Memorandum in Support of Motion to Compel and Motion for Protective Order (Pickens, Christopher)
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Filing 82
Memorandum in Support re #81 MOTION to Seal Portions of Synopsys' Brief in Support of its Motion to Compel and Motion for Protective Order and Exhibits Nos. 3-8 Thereto filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 81
MOTION to Seal Portions of Synopsys' Brief in Support of its Motion to Compel and Motion for Protective Order and Exhibits Nos. 3-8 Thereto by Synopsys, Inc.. (Attachments: #1 Proposed Order)(Pickens, Christopher)
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Filing 80
Brief in Support to #78 MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2, #79 MOTION for Protective Order (REDACTED - PUBLIC VERSION) filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3 (FILED UNDER SEAL), #4 Exhibit 4 (FILED UNDER SEAL), #5 Exhibit 5 (FILED UNDER SEAL), #6 Exhibit 6 (FILED UNDER SEAL), #7 Exhibit 7 (FILED UNDER SEAL), #8 Exhibit 8 (FILED UNDER SEAL), #9 Exhibit 9, #10 Exhibit 10)(Pickens, Christopher)
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Filing 79
MOTION for Protective Order by Synopsys, Inc.. (Pickens, Christopher)
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Filing 78
MOTION to Compel Defendant Risk Based Security, Inc. to Supplement its Answers to Interrogatories No. 1-2 by Synopsys, Inc.. (Pickens, Christopher)
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Filing 77
Brief in Support to #76 MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings filed by Synopsys, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2)(Pickens, Christopher)
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Filing 76
MOTION for Clarification of Amended Scheduling Order re #40 Pretrial Order, Set Hearings by Synopsys, Inc.. (Pickens, Christopher)
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Filing 75
Opposition to #71 MOTION for Judgment on the Pleadings filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 74
Opposition to #68 MOTION for Reconsideration re: #47 Memorandum Order filed by Synopsys, Inc. (Attachments: #1 Exhibit A)(Pickens, Christopher). Modified docket text on 10/21/2021. (sbea)
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Filing 73
MOTION for Issuance of Letters Rogatory by Risk Based Security, Inc.. (Attachments: #1 Exhibit Letter Rogatory)(Lonas, Carl)
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Filing 72
Memorandum in Support re #71 MOTION for Judgment on the Pleadings filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 71
MOTION for Judgment on the Pleadings by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 70
AFFIDAVIT in Support re #68 MOTION for Reconsideration re #47 Order on Motion to Stay, filed by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E)(Lonas, Carl)
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Filing 69
Memorandum in Support re #68 MOTION for Reconsideration re #47 Order on Motion to Stay, filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 68
MOTION for Reconsideration re #47 Order on Motion to Stay, by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 67
NOTICE by Synopsys, Inc. of Change of Firm Name and Address (Pickens, Christopher)
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Minute Entry for proceedings held before Magistrate Judge Mark R. Colombell: Settlement Conference held on 9/29/2021. (jsau, )
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Filing 59
ORDER granting #56 Motion for Kevin Walpole Kirsch to appear Pro hac vice for Risk Based Security, Inc.. Signed by District Judge John A. Gibney, Jr. on 9/20/2021. (smej, )
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Filing 58
ORDER granting #55 Motion for Chunmeng Yang to appear Pro hac vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 9/20/2021. (smej, )
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Filing 57
ORDER granting #54 Motion for Andrew Evan Samuels to appear Pro hac vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 9/20/2021. (smej, )
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Filing 56
Motion to appear Pro Hac Vice by Kevin Walpole Kirsch and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-8004702. by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 55
Motion to appear Pro Hac Vice by Chunmeng Yang and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-8004693. by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 54
Motion to appear Pro Hac Vice by Andrew Evan Samuels and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-8004671. by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 53
REPLY BRIEF in Support re: #48 MOTION to Dismiss for Failure to State a Claim filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 8/26/2021. (sbea,)
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Notice of Correction re: #53 Response in Support of Motion; filing attorney selected the wrong filing event. The correct event is "REPLY". Clerk modified docket text. No further action is required. (sbea,)
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Filing 52
Opposition to #48 MOTION to Dismiss for Failure to State a Claim filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 51
Rule 26(f) Joint Proposed Discovery Plan by Synopsys, Inc..(Pickens, Christopher)
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Filing 50
ANSWER to Complaint by Risk Based Security, Inc..(Lonas, Carl)
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Filing 49
Memorandum in Support re #48 MOTION to Dismiss for Failure to State a Claim filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 48
MOTION to Dismiss for Failure to State a Claim by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 47
MEMORANDUM ORDER for reasons outlined above, the Court does not find granting a stay in this case warranted. The Court DENIES RBS's #8 Motion to Stay. It is so ORDERED. See Memorandum Order for complete details. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 8/6/2021. (sbea,)
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Filing 46
REGARDING PROCEDURES FOR SETTLEMENT CONFERENCE. The Court has scheduled this case for a settlement conference on September 29, 2021 at 9:30 A.M. At that time, the parties shall report to the chambers of Magistrate Judge Mark R. Colombell. In addition to counsel, each party must have a representative physically present with the full authority to settle this action. If an individual is a named party, that individual must be personally present at the settlement conference. If a business entity (or entities) is/are involved, each entity must have a representative with full authority to settle the case on behalf of that entity physically present. See Order for complete details and deadlines. It is so ORDERED. Signed by Magistrate Judge Mark R. Colombell on 8/6/2021. (sbea,)
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Set Hearing: Settlement Conference set for 9/29/2021 at 09:30 AM in Richmond Judges Chamber before Magistrate Judge Mark R. Colombell. (jsau, )
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Filing 45
ORDER granting #44 Motion for Christopher Alexander Wiech to appear as Pro Hac Vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 8/5/2021. (sbea,)
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Filing 44
Motion to appear Pro Hac Vice by Christopher Alexander Wiech and Certification of Local Counsel Stewart Ryan Pollock Filing fee $ 75, receipt number AVAEDC-7922566. by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 43
ORDER that this matter comes before the Court on Defendant Risk Based Security, Inc.'s #41 Motion to Extend Deadline. The Court GRANTS the motion. RBS shall file its answer by August 9, 2021. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 7/30/2021. (sbea,)
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Filing 42
TRANSCRIPT of proceedings held on 07/20/2021, before Judge Hon. John A. Gibney, Jr., Court Reporter Gil Halasz, Telephone number 804 916-2248. NOTICE RE REDACTION OF TRANSCRIPTS:The parties have thirty(30) calendar days to file with the Court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript will be made remotely electronically available to the public without redaction after 90 calendar days. The policy is located on our website at www.vaed.uscourts.gov Transcript may be viewed at the court public terminal or purchased through the court reporter/transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER Redaction Request due 8/30/2021. Redacted Transcript Deadline set for 9/29/2021. Release of Transcript Restriction set for 10/28/2021.(halasz, gil)
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Filing 41
MOTION for Extension of Time to File Answer by Risk Based Security, Inc.. (Pollock, Stewart)
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Filing 40
AMENDED PRETRIAL ORDER: Jury Trial set for 3/14/2022 at 09:00 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. Signed by District Judge John A. Gibney, Jr. on 7/21/21. (wtuc)
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Filing 39
PRETRIAL ORDER: Jury Trial set for 3/18/2022 at 09:00 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. Signed by District Judge John A. Gibney, Jr. on 7/20/21. (wtuc)
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Filing 38
Order that the settlement conference and proceedings are referred to United States Magistrate Judge Mark R. Colombell. Counsel shall be responsible for contacting the Chambers of Magistrate Judge Colombell within five (5) days of the date of this Order to schedule the conference, which should occur at such time as Magistrate Judge Colombell shall approve. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 7/20/2021. (sbea,)
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Filing 37
Minute Entry for proceedings held before District Judge John A. Gibney, Jr.:Motion Hearing held on 7/20/2021 re #8 MOTION to Stay filed by Risk Based Security, Inc., Initial Pretrial Conference held on 7/20/2021; the motion to stay is denied; Jury Trial is scheduled for March, 18, 2021. (Court Reporter G. Halasz, OCR.)(wtuc) (Main Document 37 replaced on 7/21/2021 to correct trial date notation) (wtuc).
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Filing 36
Sealed Attachment/Exhibit(s) re #31 Affidavit in Support of Motion,. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit)(Lonas, Carl)
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Filing 35
Sealed Response/Reply/Opposition re #30 Response in Support of Motion. (Lonas, Carl)
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Filing 34
Memorandum in Support re #33 MOTION to Seal filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 33
MOTION to Seal by Risk Based Security, Inc.. (Attachments: #1 Proposed Order)(Lonas, Carl)
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Filing 32
Notice of Filing Sealing Motion LCvR5(C) by Risk Based Security, Inc. re #31 Affidavit in Support of Motion, #30 Response in Support of Motion (Lonas, Carl)
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Filing 31
REPLY DECLARATION of C. Dewayne Lonas In Further Support of Defendant Risk Based Security, Inc.s Motion to Stay re: #8 MOTION to Stay This Action filed by Risk Based Security, Inc. (Attachments: #1 Exhibit E, #2 Exhibit F, #3 Exhibit G, #4 Exhibit H, #5 Exhibit I, #6 Exhibit J, #7 Exhibit K, #8 Exhibit L - Redacted, #9 Exhibit M - Redacted, #10 Exhibit N)(Lonas, Carl). Modified docket text on 6/15/2021. (sbea,)
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Filing 30
REPLY MEMORANDUM of Law In Further Support of Defendant Risk Based Security, Inc.s Motion to Stay This Action (Redacted) re: #8 MOTION to Stay This Action filed by Risk Based Security, Inc. (Lonas, Carl). Modified docket text on 6/15/2021. (sbea,)
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Filing 29
STIPULATED PROTECTIVE ORDER. See Order for details. IT IS SO ORDERED. Signed by District Judge John A. Gibney, Jr. on 6/10/2021. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C). (sbea,)
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Filing 28
Joint MOTION for Protective Order by Risk Based Security, Inc.. (Attachments: #1 Exhibit 1)(Lonas, Carl)
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Filing 27
ORDER GRANTING CONSENT MOTION FOR EXTENSION OF TIME. Upon consideration of Defendant Risk Based Security, Inc.'s Consent Motion for Extension of Time to File a Reply Brief in Support of Its Motion to Stay, this Court finds that the Consent Motion should be GRANTED. Defendant Risk Based Security, Inc.'s deadline to file its reply brief is extended through and including June 14, 2021. SO ORDERED this 2nd day of June, 2021. Signed by District Judge John A. Gibney, Jr. on 6/2/2021. (sbea,)
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Filing 26
NOTICE of Appearance by Stewart Pollock on behalf of Risk Based Security, Inc. (Pollock, Stewart)
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Filing 25
Declaration re #24 Opposition to Motion to Stay by Synopsys, Inc.. (Attachments: #1 Exhibit A - Tracking Order, #2 Exhibit B - Hearing Transcript)(Pickens, Christopher)
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Filing 24
Opposition to #8 MOTION to Stay This Action filed by Synopsys, Inc.. (Pickens, Christopher)
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Filing 23
Consent MOTION for Extension of Time to File Response/Reply as to #8 MOTION to Stay This Action by Risk Based Security, Inc.. (Attachments: #1 Proposed Order Exhibit 1)(Lonas, Carl)
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Filing 22
ORDER granting #17 Motion for Krista Sue Schwartz to appear as Pro Hac Vice for Synopsys, Inc. Signed by District Judge John A. Gibney, Jr. on 5/25/2021. (sbea,)
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Filing 21
ORDER granting #16 Motion for Patrick Thomas Michael, III to appear as Pro Hac Vice for Synopsys, Inc. Signed by District Judge John A. Gibney, Jr. on 5/25/2021. (sbea,)
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Filing 20
ORDER granting #15 Motion for Lisa Bollinger Gehman to appear as Pro Hac Vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 5/24/2021. (sbea,)
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Filing 19
ORDER granting #14 Motion for Chad Anthony Rutkowski to appear as Pro Hac Vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 5/24/2021. (sbea,)
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Filing 18
ORDER granting #13 Motion for Michael Steven Gordon to appear as Pro Hac Vice for Risk Based Security, Inc. Signed by District Judge John A. Gibney, Jr. on 5/24/2021. (sbea,)
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Filing 17
Motion to appear Pro Hac Vice by Krista Schwartz and Certification of Local Counsel Christopher Pickens Filing fee $ 75, receipt number AVAEDC-7807140. by Synopsys, Inc.. (Pickens, Christopher)
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Filing 16
Motion to appear Pro Hac Vice by Patrick Michael and Certification of Local Counsel Christopher Pickens Filing fee $ 75, receipt number AVAEDC-7807108. by Synopsys, Inc.. (Pickens, Christopher)
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Filing 15
Motion to appear Pro Hac Vice by Lisa Bollinger Gehman and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-7805646. by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 14
Motion to appear Pro Hac Vice by Chad Rutkowski and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-7805624. by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 13
Motion to appear Pro Hac Vice by Michael Gordon and Certification of Local Counsel C. Dewayne Lonas Filing fee $ 75, receipt number AVAEDC-7805587. by Risk Based Security, Inc.. (Lonas, Carl)
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Set as to #8 MOTION to Stay This Action: Motion Hearing set for 7/20/2021 at 10:00 AM in Richmond Courtroom 6000 before District Judge John A. Gibney, Jr. (wtuc)
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Filing 12
Financial Interest Disclosure Statement (Local Rule 7.1) by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 11
Declaration re #9 Memorandum in Support, #8 MOTION to Stay This Action of Chad A. Rutkowski by Risk Based Security, Inc.. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6)(Lonas, Carl)
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Filing 10
Declaration re #9 Memorandum in Support, #8 MOTION to Stay This Action of C. Dewayne Lonas by Risk Based Security, Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)(Lonas, Carl)
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Filing 9
Memorandum in Support re #8 MOTION to Stay This Action filed by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 8
MOTION to Stay This Action by Risk Based Security, Inc.. (Lonas, Carl)
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Filing 7
Certificate of Compliance by Synopsys, Inc. as to Risk Based Security, Inc. (sbea,)
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Filing 6
Summons Returned Unexecuted by Synopsys, Inc. as to Risk Based Security, Inc.. (Pickens, Christopher)
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Filing 5
SUMMONS Returned Executed by Synopsys, Inc. Risk Based Security, Inc. served on 4/27/2021, answer due 5/18/2021 (Pickens, Christopher)
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Filing 4
Summons Issued as to Risk Based Security, Inc. **NOTICE TO ATTORNEY: Please remove the headers and print two duplexed copies of the electronically issued summons for the Defendant. Please serve one copy of the summons and a copy of the Complaint upon the Defendant. Please ensure that your process server returns the service copy (executed or unexecuted) to your attention and electronically file it using the filing events, Summons Returned Executed or Summons Returned Unexecuted. (sbea,)
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Initial Case Assignment to District Judge John A. Gibney, Jr. (sbea,)
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Filing 3
Corporate Disclosure Statement by Synopsys, Inc.. (Pickens, Christopher)
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Filing 2
Proposed Summons re #1 Complaint by Synopsys, Inc.. (Pickens, Christopher)
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Filing 1
Complaint (Filing Fee: $402, Receipt Number: 0422-7725545), filed by Synopsys, Inc. (Attachments: #1 Exhibit 1 - Letter, #2 Civil Cover Sheet)(Pickens, Christopher). Clerk replaced Complaint to include Civil Action Number on 4/15/2021. Modified docket text on 4/15/2021. (sbea,)
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