STIPULATION REGARDING BRIEFING AND HEARING SCHEDULE FOR DEFENDANTS' MOTION FOR PRELIMINARY INJUNCTION, AND [PROPOSED] ORDER THEREON AS MODIFIED

JEFFREY S. WHITE, District Judge.

IT IS HEREBY STIPULATED by and between Plaintiff and Counterclaim Defendant Lotes Co., Ltd. ("Plaintiff") and Defendants and Counterclaimants Hon Hai Precision Industry Co. Ltd. and Foxconn Electronics, Inc. ("Defendants"), by and through their respective counsel, as follows:

WHEREAS, Defendants filed their Motion for Preliminary Injunction ("Motion") with this Court on June 26, 2013;

WHEREAS, on June 27, 2013, Defendants noticed the hearing on the Motion for October 11, 2013, at 9:00 a.m.;

WHEREAS, Plaintiff and Defendants agree that the dates currently set for filing and service of the opposition and reply papers for the Motion should be continued, while the date of the hearing should remain unchanged;

WHEREAS, the parties do not currently contemplate taking any discovery, and will not seek an extension of the hearing date so long as no intervening, subsequent events alter the current situation in a manner that might prejudice the parties; and

WHEREAS, good cause exists to continue the opposition and reply dates because the Motion raises complex issues as to infringement and validity of the asserted patent, as well as to the question of whether irreparable harm would arise in the absence of an injunction. Plaintiff states that it needs the additional time to gather the evidence necessary to oppose the Motion and to prepare the briefs and declarations in opposition to the Motion. Plaintiff further states that it is located in Taiwan and that many of its employees do not speak English, which slows down the back-and-forth communications about motion strategy and evidence with its California-based counsel.

NOW, THEREFORE, by and between each other, the parties stipulate that the deadline to file and serve opposition papers to the Motion shall be extended to and including August 30, 2013 and that the deadline to file and serve reply papers in support of the Motion shall be extended to and including September 13, 2013.

IT IS SO STIPULATED.