STIPULATION AND ORDER REQUESTING MODIFICATION OF LOCAL RULE 79-5 DEADLINE RELATING TO ADMINISTRATIVE MOTIONS TO SEAL ACCOMPANYING THE PARTIES' OPPOSITIONS TO DISPOSITIVE AND DAUBERT MOTIONS

HAYWOOD S. GILLIAM, JR., District Judge.

Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiffs Koninklijke Philips N.V. and U.S. Philips Corp. ("Philips") and Defendants ASUSTek Computer, Inc. and ASUS Computer International ("ASUS"), HTC Corporation and HTC America, Inc. ("HTC"), and Microsoft Corporation and Microsoft Mobile, Inc. ("Microsoft") (collectively, "the Stipulating Parties"), through counsel, hereby respectfully file this Stipulation and [Proposed] Order to extend the current September 30, 2019 deadline to October 4, 2019 for each of the Stipulating Parties, as well as certain non-parties who have produced confidential materials and information pursuant to the Protective Order governing confidentiality in this action, to file and serve any declaration required by Local Rule 79-5 with respect to the parties' recently-filed oppositions to the Daubert Motions and Motions for Summary Judgment filed in this action.

WHEREAS, pursuant to this Court's Scheduling Orders for this action (see, e.g., Docket Nos. 573, 631), on September 26, 2019, the Stipulating Parties filed their respective oppositions to various previously-filed Daubert Motions, Motions for Summary Judgment, and Motions to Strike ("Oppositions"); and

WHEREAS, those Oppositions and certain exhibits thereto contain information that has been designated "Confidential," "Highly Confidential — Outside Counsel Only," and/or "Highly Confidential — Source Code" under the Protective Order that governs confidentiality in this action (Docket No. 132), including information that has been produced and designated by entities that are not parties to nor otherwise regularly participating in this action; and

WHEREAS, in view of those designations, the Stipulating Parties have filed along with their Oppositions various Administrative Motions to Seal pursuant to Local Rule 79-5 (including Dkt. Nos. 794, 795, 798, 800, 802, 803, 806, 808, 809, 811, 814, 817, 819, 821, 823, 828, 829, and 836); and

WHEREAS, under Civil Local Rule 79-5(e), the current deadline to file and serve any declaration in support of such sealing is Monday, September 30, 2019; and

WHEREAS, given the volume of materials associated with those Administrative Motions to Seal and the fact that some of the information has been produced and designated by entities that are not parties to this action, the Stipulating Parties believe in good faith that good cause exists under Civil Local Rule 6-2 to extend the deadline for sealing declarations to be filed.

NOW, THEREFORE, the Stipulating Parties, through counsel, hereby stipulate and respectfully request that the Court extend the current Monday, September 30, 2019 deadline to Friday, October 4, 2019 to file and serve any declaration required by Local Rule 79-5 with respect to information included in Oppositions recently filed in this action.

CIVIL L.R. 5-1(i) ATTESTATION

I, Chris Holland, hereby attest that I have been authorized by counsel for the parties listed above to execute this document on their behalf.

ORDER

GOOD CAUSE APPEARING AND PURSUANT TO STIPULATION, IT IS SO ORDERED.