STIPULATION AND ORDER TO CONTINUE CASE DEADLINES

WILLIAM H. ORRICK, District Judge.

Plaintiff and cross-defendants whiteCryption Corporation ("whiteCryption") and Intertrust Technologies Corporation ("Intertrust") and defendant and counterclaimant Arxan Technologies, Inc. ("Arxan") stipulate and agree as follows:

1. On February 18, 2015, whiteCryption initiated the above-captioned action against Arxan.

2. Arxan answered and counterclaimed against whiteCryption and Intertrust on April 10, 2015.

3. Between May and June 2015, the parties engaged in motion practice regarding the counterclaims, and on June 18, 2015, the Court granted Intertrust's motion to dismiss with leave to amend.

4. On June 17, 2015, the Court issued a Civil Pretrial Order setting the deadlines in this action. ECF No. 35. The Court later ordered the parties to a settlement conference with a magistrate judge and modified the case schedule to accommodate a first phase of document discovery prior to the settlement conference. See ECF. Nos. 42-45.

5. On January 5, 2016, the parties' participated in a settlement conference with a magistrate judge, which did not result in settlement. ECF No. 46.

6. On February 17, 2016, whiteCryption filed its first amended complaint and Arxan filed its first amended counterclaims. ECF Nos. 51-52.

7. On March 22, 2016, whiteCryption and Intertrust moved to dismiss the first amended counterclaims (ECF No. 66), and on June 15, 2016 the Court granted in part and denied in part the motion without leave to amend (ECF No. 89).

8. The parties have engaged in extensive discovery, collectively producing hundreds of thousands of documents and approximately 20 depositions will be taken, two of which are scheduled to take place after the close of fact discovery.1 Based on the document productions and scheduling issues, the first deposition did not occur until June 16, 2016.

9. Due to the large volume of documents produced in this case and the number and the schedule of depositions, the parties both require additional time to prepare and produce meaningful expert reports without seeking leave for supplementing them. Moving the expert disclosure deadline triggers a need to reschedule the deadlines that follow expert disclosures. Further, all parties anticipate filing motions for summary judgment or summary adjudication, which the parties believe is good cause to extend the briefing and hearing schedule for such motions.

10. The parties previously requested one extension of the deadlines in the Civil Pretrial Order on December 18, 2015, which was granted on December 21, 2015. ECF No. 45

11. The parties realize that changing a case schedule is highly dependent upon the Court's schedule, including the Court's availability to hear dispositive motions, conduct pretrial conferences, and conduct trials. The parties welcome a telephonic case management conference to discuss alternatives to the schedule they are proposing.

Therefore, the parties stipulate and agree, subject to the Court's approval, that deadlines for expert discovery and the deadlines that follow it be set as follows:

PURSUANT TO STIPULATION, IT IS SO ORDERED except as modified below:

Pre-trial conference: February 27, 2017 at 2:00 p.m.

Trial: April 3, 2017 at 8:30 a.m.