JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF REMAINING CLAIM CONSTRUCTION DEADLINES

EDWARD M. CHEN, District Judge.

Pursuant to Local Rule 6-2 and Local Rule 7-12, Plaintiff GeoTag, Inc. ("GeoTag") and Defendant Zoosk, Inc. ("Zoosk") (collectively, the "Parties"), stipulate as recited below and jointly request that the Court amend the current Claim Construction Scheduling Order [Dkt. No. 133] as set forth below.

WHEREAS, the Court, by Order dated April 2, 2013 [Dkt. No. 133], issued a scheduling order setting forth the case schedule through claim construction;

WHEREAS, the Court, modified that schedule by orders dated July 24, 2013 [Dkt. No. 146], August 15, 2013 [Dkt. No. 152] and October 2, 2013 [Dkt. No. 164];

WHEREAS, the October 2, 2013 modification reset GeoTag's opening claim construction briefing to December 23, 2013, Zoosk's responsive claim construction briefing to January 6, 2014, and the Markman hearing to February 10, 2014;

WHEREAS, GeoTag's trial in the case titled GeoTag, Inc. v. Frontier Communc's Corp. et al., Case No. 2:10-cv-00265-JRG (E.D. Tex. filed July 23, 2010) (Gilstrap, J.) has been reset from December 2, 2013 to March 10, 2014;

WHEREAS, GeoTag is set to begin trial in the case titled Microsoft Corp. et al. v. GeoTag, Inc., Case No. 11-cv-00175-RGA (D. Del. filed March 1, 2011) (Andrews, J.) on April 21, 2014;

WHEREAS, new counsel of record for GeoTag entered appearances on November 13, 2013 [Dkt. Nos. 167 and 168] and on December 10, 2103 [Dkt. No. 169];

WHEREAS, the Parties agree to the below extension of all remaining claim construction deadlines to allow new counsel for GeoTag the necessary time to come up to speed to this action, as well as, to allow the Court the benefit of the rulings from GeoTag's trial in the Eastern District of Texas;

THE PARTIES HEREBY STIPULATE and jointly request that, in view of the foregoing, the case schedule shall be modified as set forth below: