STIPULATION AND [PROPOSED] ORDER SETTING FINAL APPROVAL HEARING DATE AND BRIEFING SCHEDULE

SAUNDRA BROWN ARMSTRONG, District Judge.

Plaintiffs Moises Zepeda, Michael Spear, Ronya Osman, Brian Pattee, Casey Ching, Denae Zamora, Michael Lavagna and Gary Miller (together, "Plaintiffs") and defendants PayPal, Inc. ("PayPal") and eBay Inc. (together, "Defendants"), through their undersigned counsel of record, stipulate as follows:

WHEREAS, on November 5, 2015, this Court entered an Order Granting Plaintiffs' Motion for Preliminary Approval of Amended Class Action Settlement Agreement (ECF No. 281) and, on January 28, 2016, entered an Order Setting Final Approval Schedule (the "Scheduling Order") (ECF No. 290);

WHEREAS, a subset of Settlement Class Members were inadvertently not served with class notice, in accordance with the Scheduling Order, on or before April 10, 2016 (the "Additional Settlement Class Members");

WHEREAS, pursuant to the Scheduling Order, any responses to objections to the parties' Settlement Agreement (ECF No. 275-2) and any papers in support of final approval thereof were to be filed on or before June 13, 2016, and the Final Approval Hearing was scheduled to take place on July 13, 2016 at 1:00 PM;

WHEREAS, the Scheduling Order provides, in pertinent part, that: "[t]he Final Approval Hearing may be postponed, adjourned, or continued by order of the Court without further notice to the Settlement Class";

WHEREAS, on June 10, 2016, the Court entered an Order (ECF No. 325) vacating the Final Approval Hearing date and briefing schedule and directed the parties to submit a proposed, revised schedule for the Final Approval Hearing and related dates and deadlines;

IT IS HEREBY STIPULATED, by and between Plaintiffs and Defendants, through their respective counsel of record, as follows:

1. The deadline for PayPal to provide summary Email Notice to Additional Settlement Class Members, pursuant to paragraph 3 of the Scheduling Order, shall be extended until August 15, 2016.

2. The deadline for the Settlement Administrator to provide Supplemental summary Postcard Notice to Additional Settlement Class Members, pursuant to paragraph 6 of the Scheduling Order, shall be extended until September 14, 2016.

3. The deadline for Claim Forms to be submitted by Additional Settlement Class Members, pursuant to paragraph 7 of the Scheduling Order, shall be extended until October 14, 2016.

4. The deadline for Additional Settlement Class Members to exclude themselves from the Claims Class by mailing a request for exclusion, pursuant to paragraph 8 of the Scheduling Order, shall be extended until October 14, 2016.

5. The deadline for Defendants to exercise their right to terminate the Settlement Agreement, pursuant to paragraph 9 of the Scheduling Order, shall be extended until November 3, 2016.

6. The deadline for Additional Settlement Class Members to object to the fairness, reasonableness, or adequacy of the Settlement, the request for an award of fees and costs to Class Counsel or the awards to the Settlement Class representatives, pursuant to paragraph 10 of the Scheduling Order, is extended until October 14, 2016.

7. Any responses to objections to the Settlement Agreement and any papers in support of the Settlement shall be filed with the Court at least thirty (30) days before the Final Approval Hearing.

8. No later than seven (7) days before the Final Approval Hearing, Defendants or the Settlement Administrator shall file with the Court a declaration verifying that notice has been provided to the Settlement Class as set forth in the Scheduling Order and/or this Order.

9. The Final Approval Hearing shall be held before the Honorable Saundra B. Armstrong, Courtroom 1, Oakland Courthouse, 1301 Clay Street, Oakland, California 94612, on December 14, 2016 at 1:00 PM. The Final Approval Hearing may be postponed, adjourned, or continued by order of the Court without further notice to the Settlement Class.

[PROPOSED] ORDER

PURSUANT TO THE STIPULATION, IT IS SO ORDERED.