JOINT STIPULATION AND [PROPOSED] ORDER TO STAY PROCEEDINGS

RICHARD SEEBORG, District Judge.

WHEREAS, on June 15, 2017, Via Licensing Corporation ("Via") filed a Complaint for Breach of Contract Seeking Damages and Specific Performance (the "Complaint") against Haier America Trading, LLC ("HAT") in the above-entitled action;

WHEREAS, on November 20, 2018, the parties signed a confidential settlement term sheet (the "Settlement Term Sheet") and agreed to work together to prepare a formal settlement agreement consistent with the terms set forth in the Settlement Term Sheet;

WHEREAS, among other terms the Settlement Term Sheet requires HAT and related entities to perform certain obligations on or before December 31, 2018, (collectively, the "Haier 2018 Obligations");

WHEREAS, the Settlement Term Sheet contemplates that within three business days of performance of the last of the Haier 2018 Obligations, the parties shall file a stipulation of dismissal without prejudice which shall request that the Court retain jurisdiction to enforce the terms of the Settlement Term Sheet or, if superseded by a formal settlement agreement, the terms of the formal settlement agreement;

WHEREAS, this case is scheduled for a trial commencing on December 10, 2018, and there are numerous interim deadlines in connection with this action;

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between Via and HAT, by and through their respective counsel, that:

1. In light of the agreements reached in the Settlement Term Sheet, all proceedings in the above-captioned action shall be stayed until January 31, 2019, and all currently-set deadlines vacated, to allow the parties time to prepare a formal settlement agreement, and to allow time for the performance of the Haier 2018 Obligations;

2. If for some reason, the parties do not file a stipulated dismissal by January 7, the parties request that the Court set a case management conference at the next earliest available date in January 2019 to discuss the case and set new deadlines as necessary.

In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests that concurrence in the filing of this document has been obtained from the other signatories above.

[PROPOSED] ORDER

PURSUANT TO THIS STIPULATION, AND FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.