STIPULATION AND [ PROPOSED ]ORDER REGARDING HP AND SONY DISCOVERY

RICHARD G. SEEBORG, District Judge.

WHEREAS, Plaintiff HP Inc., formerly known as Hewlett-Packard Company ("HP"), and Defendants Sony Corporation, Sony Electronics Inc., Sony Optiarc Inc. (formerly known as Sony NEC Optiarc Inc.), and Sony Optiarc America Inc. (formerly known as Sony NEC Optiarc America Inc.) (collectively, "Sony") wish to explore mediation and the potential settlement of HP's claims against Sony in this case;

WHEREAS, HP and Sony wish to pursue mediation, and HP prefers to do so in Houston, Texas, using a private mediator;

WHEREAS, HP and Sony wish to avoid potentially unnecessary costs by deferring the remaining discovery between them pending mediation; and

WHEREAS, pursuant to the Scheduling Order entered on April 22, 2016 (Dkt. No. 1866), fact discovery is scheduled to close on December 9, 2016, prior to the first available date the mediator has available;

NOW THEREFORE, IT IS HEREBY STIPULATED by and between the undersigned counsel for HP and Sony as follows:

1. HP and Sony shall pursue mediation with Daryl Bristow in Houston, Texas on January 4, 2017.

2. Pending such mediation, HP and Sony shall defer all remaining written and deposition discovery between them, subject to the agreement that if (and only if) HP and Sony do not agree to settle, such discovery — which consists solely of (1) the deposition of Masafumi Amino, (2) responses to pending written discovery issued to HP by Sony, and (3) responses to pending written discovery issued to Sony by HP — shall recommence as follows:

a. The deposition of Masafumi Amino shall take place on January 30-31, 2017, in San Francisco, California; and

b. HP and Sony shall serve their responses to the remaining discovery served on the other on January 31, 2017.

IT IS SO STIPULATED.

FILER ATTESTATION

Pursuant to Rule 5-1(i)(3) of the Local Rules of Practice in Civil Proceedings Before the United States District Court for the Northern District of California, I, Beatrice B. Nguyen, hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.