JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING ON DEFENDANTS' FORUM NON CONVENIENS MOTION, MODIFYING BRIEFING SCHEDULE, AND CONTINUING INITIAL CASE MANAGEMENT CONFERENCE

MAXINE M. CHESNEY, District Judge.

WHEREAS, on August 27, 2013, Plaintiff King.com Ltd. ("King") filed a Complaint for copyright infringement against Defendant 6waves LLC ("6waves");

WHEREAS, King served 6waves with that Complaint on September 4, 2013;

WHEREAS, on September 23, 2013, King and 6waves stipulated to extend 6waves's deadline to respond to that Complaint until October 25, 2013 (Dkt. 13);

WHEREAS, on October 1, 2013, this Court set the initial case management conference in this case for December 6, 2013 (Dkt.19);

WHEREAS, on October 31, 2013, King filed a First Amended Complaint for copyright infringement adding 6waves' parent corporation Six Waves Inc. ("SWI") as a defendant;

WHEREAS, on November 1, 2013, SWI and 6waves (collectively, "Defendants") filed a motion to dismiss on grounds of forum non conveniens, noticed for hearing on December 6, 2013 and supported by, inter alia, a 46-page declaration from Jacques deLisle and a 23-page declaration from Meph Jia Gui regarding the laws and legal systems of the People's Republic of China;

WHEREAS, under this Court's local rules, King's response to that motion would normally be due on November 15, 2013;

WHEREAS, lead counsel for King, Jennifer Kelly, has jury duty from November 4 until November 8, 2013, and a long-planned vacation scheduled to begin on November 13, 2013;

WHEREAS, Defendants' lead counsel, Sonali Maitra, is scheduled to be out of the office for a vacation scheduled to begin on December 13, 2013, and Defendants' counsel's staff is largely unavailable the week of Christmas until New Years;

WHEREAS, the parties believe that it would be the most efficient use of judicial resources to schedule the initial case management conference in this case after the date set for the hearing on Defendants' motion;

NOW THEREFORE, the parties hereby stipulate and respectfully request that:

1. The hearing on Defendants' motion to dismiss on the grounds of forum non conveniens be continued until January 17, 2014;

2. The deadline for King to file its opposition to that motion be extended until December 6, 2013;

3. The deadline for Defendants to file their reply to that opposition be extended until January 3, 2014;

4. The initial case management conference in this case be continued until January 31, 2014; and

5. The deadlines triggered by the initial case management conference are adjusted as follows: the deadline to meet and confer under Federal Rule of Civil Procedure 26(f) is set for January 17, 2014 and the deadline to submit a joint case management statement is set for January 24, 2014.

[PROPOSED] ORDER

Pursuant to the above stipulation, and good cause appearing, IT IS HEREBY ORDERED that:

1. The hearing on Defendants' motion to dismiss on the grounds of forum non conveniens is continued until January 17, 2014;

2. The deadline for King to file its opposition to that motion is extended until December 6, 2013;

3. The deadline for Defendants to file their reply to that opposition is extended until January 3, 2014;

4. The initial case management conference in this case is re-set for February 21, 2014 at 10:30 a.m.; and

5. Deadlines triggered by the initial case management conference are adjusted as follows: the deadline to meet and confer under Federal Rule of Civil Procedure 26(f) is set for February 7, 2014 and the deadline to submit a joint case management statement is set for February 14, 2014.