STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINTS AND CONTINUING CASE MANAGEMENT CONFERENCE

VINCE CHHABRIA, District Judge.

WHEREAS, the above-captioned actions Ansfield v. Infoblox, Inc., et al., Case No. 3:14-cv-02500-VC (filed May 30, 2014), Beqaj v. Infoblox, Inc., et al., Case No. 3:14-cv-02564-VC, (filed June 4, 2014), and Achey, et al. v. Infoblox, Inc., et al., Case No. 3:14-cv-02644-VC (filed June 9, 2014), collectively referred to as the "Actions," are proposed class actions alleging violations of the Securities Exchange Act of 1934 against Infoblox, Inc., Robert D. Thomas and Remo E. Canessa (collectively, "Defendants");

WHEREAS, the Actions have been determined to be "related cases" within the meaning of Civil Local Rule 3-12(a);

WHEREAS, the Actions are subject to the requirements of the Private Securities Litigation Reform Act of 1995 (the "Reform Act"), which sets forth specialized procedures for the administration of securities class actions;

WHEREAS, the Reform Act provides for, among other things, the appointment of a lead plaintiff to act on behalf of the alleged class, pursuant to 15 U.S.C. § 78u-4(3)(B);

WHEREAS, the parties expect that motions for appointment of a lead plaintiff and lead counsel will be filed by July 29, 2014, and expect that motion(s) to consolidate the Actions will be filed at or about the same time;

WHEREAS, Defendants intend to file motions to dismiss the claims asserted against them;

WHEREAS, because the special procedures specified in the Reform Act contemplate appointment of lead plaintiff and lead counsel, and because the lead plaintiff and lead counsel appointed by the Court should have the opportunity to file an amended complaint, requiring Defendants to respond to the initial complaints in the above-referenced Actions would serve no purpose and would result in the needless expenditure of private and judicial resources;

WHEREAS, the Court has scheduled an Initial Case Management Conference in each of the Actions for September 16, 2014, and set certain deadlines in connection therewith;

WHEREAS, pursuant to the Reform Act, all discovery and other proceedings, including initial disclosures, are subject to a mandatory stay unless and until a motion to dismiss has been denied (15 U.S.C. § 78u-4(b)(3)(B));

WHEREAS, in light of the Reform Act's mandatory stay of proceedings, the parties believe that a case management conference at this point would serve no purpose and would result in the needless expenditure of private and judicial resources, and that the initial case management conference in this action should be continued to a date after the Court has had an opportunity to decide defendants' anticipated motion to dismiss;

IT IS ACCORDINGLY STIPULATED, by and between the parties, that:

1. The time for Defendants to answer, move or otherwise respond to the complaints in each of the Actions is extended until after appointment of lead plaintiff(s) and lead counsel pursuant to the Reform Act;

2. Within forty-five (45) days from the date that the Court appoints lead plaintiff(s) and lead counsel pursuant to 15 U.S.C. § 78u-4(3)(B), such lead plaintiff(s) shall file an amended consolidated complaint ("Amended Complaint");

3. Within forty-five (45) days from the date that an Amended Complaint is filed by the Court-appointed lead plaintiff(s), Defendants shall file a motion to dismiss, answer, or other response to such Amended Complaint;

4. Defendants shall have no obligation to file any motion to dismiss, answer or other responsive pleading to any complaint in any of the Actions until an Amended Complaint is filed by the Court-appointed lead plaintiff(s); and

5. The case management conferences presently scheduled in each of the Actions for September 16, 2014, along with any associated deadlines under the Federal Rules of Civil Procedure and Local Rules (including ADR deadlines), shall be vacated, and reset to a date after the Court rules on Defendants' anticipated motion to dismiss the Amended Complaint.

Pursuant to Civil L.R. 5-1(i)(3), all signatories concur in filing this stipulation.

[PROPOSEDS] ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:

1. The time for Defendants to answer, move or otherwise respond to the complaints in each of the Actions is extended until after appointment of lead plaintiff and lead counsel pursuant to the Reform Act;

2. Within forty-five (45) days from the date that the Court appoints a lead plaintiff(s) and lead counsel pursuant to 15 U.S.C. § 78u-4(3)(B), such lead plaintiff(s) shall file an amended consolidated complaint ("Amended Complaint");

3. Within forty-five (45) days from the date that an Amended Complaint is filed by the Court-appointed lead plaintiff(s), Defendants shall file a motion to dismiss, answer, or other response to such Amended Complaint;

4. Defendants shall have no obligation to file any motion to dismiss, answer or other responsive pleading to any complaint in the Actions until an Amended Complaint is filed by the Court-appointed lead plaintiff(s); and

5. The case management conferences presently scheduled in each of the Actions for September 16, 2014, along with any associated deadlines under the Federal Rules of Civil Procedure and Local Rules (including ADR deadlines), are hereby vacated, and will be reset after the Court rules on Defendants' anticipated motion to dismiss the Amended Complaint.