EDWARD M. CHEN, District Judge.
Plaintiff ADOBE SYSTEMS INCORPORATED ("Plaintiff"), by and through its counsel of record, and Defendants METROTECH SOLUTIONS USA INC.; 9199-6546 QUEBEC INC., d/b/a METROTECH SOLUTIONS INC., METROTECH SOLUTIONS and METROTECH; FACTORY (collectively "Defendants"), by and through their counsel of record, hereby stipulate and agree as follows:
On August 20, 2015, the Court entered a PERMANENT INJUNCTION AGAINST DEFENDANTS AND DIMISSAL WITH PREJUDICE (D.E. 31) ("Injunction").
On June 1, 2017, Plaintiff filed its MOTION FOR CONTEMPT AND SANCTIONS AGAINST THE ENJOINED PARTIES (D.E. 33) ("Motion"), asserting that Defendants violated the Injunction by dealing in Adobe products, specifically through their illegal distribution of unbundled (and in one instance, previously activated) Adobe software products.
Defendants' response to the Motion is currently due June 15, 2017. Plaintiff's reply to the Motion is currently due June 22, 2017.
On June 9, 2017, Plaintiff was contacted by counsel for Defendants requesting an extension of time to respond to the Motion due to professional commitments and to afford the Parties an opportunity to resolve this matter amicably and without further intervention of the Court.
Thereafter, the Parties conferred on a mutually agreeable hearing date and briefing schedule. The Parties also agreed to a specific deadline for the production of documents in an effort to resolve this Motion prior to the hearing.
Accordingly, Plaintiff and Defendants hereby stipulate and respectfully request the Court continue the hearing on the Motion to August 3, 2017, or a date thereafter acceptable to the Court.
Additionally, Plaintiff and Defendants hereby stipulate and respectfully request that Defendants' response to the Motion be due on or before July 13, 2017, upon the express condition that Defendants' produce documents demonstrating the purchase and sale of any Adobe products from the date of the Injunction, August 20, 2015, to the present by no later than June 21, 2017. In the event that Defendants have not produced complete purchase and sales documents by close of business on June 21, 2017, Defendants' response to the Motion shall be due June 26, 2017.
Plaintiff and Defendants hereby stipulate and respectfully request that Plaintiff's reply shall be due 7 calendar days after the filing of Defendants' response.
Pursuant to Stipulation, the hearing on Plaintiff's MOTION FOR CONTEMPT AND SANCTIONS AGAINST THE ENJOINED PARTIES ("Motion") is reset from July 6, 2017, to
Defendants' response to the Motion is due July 13, 2017, provided that Defendants produce to Plaintiff, by no later than June 21, 2017, all purchase and sales documents relating to Adobe products. Should Defendants fail to produce full and complete documents by June 21, 2017, Defendants' response to the Motion shall be due June 26, 2017.
Plaintiff's reply to the Motion is due 7 calendar days after the filing of Defendants' response.