STIPULATION FOR ADDITIONAL TIME TO COMPLETE SETTLEMENT AND FILE REQUEST FOR DISMISSAL WITH PREJUDICE; [PROPOSED] ORDER

AS MODIFIED

VINCE CHHABRIA, District Judge.

This status report regarding the settlement of this matter and dismissal is entered into by Plaintiffs, DEMERTRIOS DOTIS and VICKI DOTIS ("Plaintiffs"), on the one hand, and Defendants STATELESS, CHRIS JAMES; GERARD ROBERTS, d/b/a KIDKANEVIL; JUSTIN PERCIVAL; ROD BUCHANAN-DUNLOP; DAVID LEVIN; JOSHUA PAUL DAVIS d/b/a DJ SHADOW, NINJA TUNE, INC, SQUARE ENIX, INC., MICROSOFT CORPORATION, AMAZON.COM, INC., BEST BUY CO., INC., SONY INTERACTIVE ENTERTAINMENT LLC, GAMESTOP INC., TARGET CORPORATION, VALVE CORPORATION, WAL-MART STORES, INC., FERAL INTERACTIVE LIMITED and APPLE INC. (individually and collectively, the "Defendants"), by and through counsel below:

1. On December 7, 2017, following the settlement conference herein, the Court entered a docket order stating that: "[The] Parties agreed to settlement term sheet, subject to long-form agreement anticipated within 7 days, and dismissal to follow within 30 days after. Magistrate Judge Cousins retains jurisdiction to enforce term sheet." Based on this docket order the Court is expecting a notice of dismissal on or before January 16, 2017;

2. The parties have been diligently working to complete the confidential written settlement agreement (which has several complex moving parts) in accord with the term sheet agreed to at the settlement conference, and the revised draft of the agreement is currently being reviewed by Plaintiffs' counsel;

3. The parties will not complete the written settlement in time such that the case will be dismissed within the Court's expected time frame. The parties, in good faith, believe that the paperwork and settlement will likely require an additional two weeks to finalize (including getting signatures from the many parties) which will call for the dismissal of the case with prejudice.

4. In light of the foregoing, the parties have stipulated and agreed to, and jointly request an additional two weeks, to and including January 30, 2018 in which to complete the settlement and file their anticipated request for dismissal with prejudice.

[PROPOSED] ORDER

Pursuant to the stipulation, it is so ordered.

The hearing re Dkt. No. 98, Motion for Partial Summary Judgment, set for February 1, 2018, is vacated. The Court sets an in-person Further Case Management Conference for February 6, 2018 at 1:30 p.m. A joint updated Case Management Statement is due January 30, 2018.