JOINT STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE STIPULATED PROTECTIVE ORDER

HAYWOOD S. GILLIAM, JR., District Judge.

Pursuant to Civil L. R. 6-1, 6-2, and 7-12, Plaintiff Zomm LLC ("Zomm") and Defendant Apple Inc. ("Apple") hereby stipulate and request, by and through their undersigned counsel and subject to the Court's approval, to extend the deadline to file a Stipulated Protective Order to February 11, 2019.

WHEREAS, pursuant to the Court's January 25, 2019 Order (Dkt. 61), the Parties are required to file a Stipulated Protective Order by February 1, 2019;

WHEREAS, the Parties have met and conferred and have significantly narrowed the areas of disagreement regarding the terms of the Stipulated Protective Order;

WHEREAS, the Parties are continuing to negotiate in good faith and believe that they could make further progress towards reaching agreement on additional terms of the Stipulated Protective Order with further time to continue their meet and confer discussions;

WHEREAS, the Parties agree to extend the deadline to file the Stipulated Protective Order in the hope that they can reach agreement on the Stipulated Protective Order; and

WHEREAS, the Parties have requested two prior modifications of time to extend the deadline to file a Stipulated Protective Order (Dkt. 55, 60); and

WHEREAS, the Parties requested an additional week to file an ESI Stipulation (Dkt. 55), which the Parties filed on January 18, 2019 (Dkt. 58) and has now been ordered by the Court (Dkt. 59); and

WHEREAS, the parties also requested a modification of time related to the briefing schedule for Apple's Motion to Dismiss Plaintiff's Non-Patent Causes of Action and Stay Plaintiff's Patent Cause of Action (Dkt. 45) to account for the holidays (Dkt. 51), which was granted by the Court on December 17, 2018 (Dkt. 53); and

WHEREAS, the modification requested herein will not affect any other scheduled dates or events in this action.

It is hereby STIPULATED AND AGREED, by and between the Parties, subject to the approval of the Court, as follows:

The Parties will file a Stipulated Protective Order, including an identification of any outstanding disputes regarding its terms, no later than February 11, 2019.

Pursuant to Civil L.R. 6-2(a), this stipulation is supported by the concurrently filed Declaration of Michael J. Zinna.

IT IS SO STIPULATED.

CERTIFICATE OF SERVICE

I certify that all counsel of record is being served on February 1, 2019, with a copy of this document via the Court's CM/ECF system.

FILER'S ATTESTATION

Pursuant to Local Rule 5-1(i)(3), I hereby attest that the other signatory listed, on whose behalf the filing is submitted, concurs in the filing's content and has authorized the filing.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.