STIPULATED REQUEST FOR ORDER CONTINUING ALL PENDING DATES, INCLUDING TIME TO SUBMIT UPDATED JOINT CASE MANAGEMENT STATEMENT, UBIQUITI'S TIME TO RESPOND TO PLAINTIFFS' FIRST AMENDED COMPLAINT, TIME FOR DEFENDANT UBIQUITI NETWORKS, INC. TO SUBMIT INITIAL DISCLOSURE, AND FURTHER CASE MANAGEMENT CONFERENCE; [proposed] ORDER

EDWARD M. CHEN, District Judge.

Pursuant to Local Rules 6-1, 6-2, 7-12, Plaintiffs Tasion Communications Inc., International Power Systems, LLC, and Fundamental Holdings, Corp. (collectively, "Plaintiffs") and Defendant Ubiquiti Networks, Inc. ("Ubiquiti") ("collectively, "Requesting Parties"), by and through their undersigned counsel, submit this Stipulated Request for Order Continuing All Pending Dates, Including Time to Submit Updated Joint Case Management Statement, Ubiquiti's Time to Respond to Plaintiffs' First Amended Complaint, Time for Defendant Ubiquiti Networks, Inc. to Submit Initial Disclosure, and Further Case Management Conference.

WHEREAS, on December 11, 2013, the Requesting Parties appeared before this Court for a Further Case Management Conference (Dkt. No. 47);

WHEREAS, Defendant Streakwave Wireless, Inc. ("Streakwave") was served with summons on Thursday, December 12, 2013;

WHEREAS, the certificate of service of summons was filed with the Court today, December 18, 2013 (Dkt. No. 49);

WHEREAS, Streakwave has yet to make an appearance in this matter (See Docket Generally);

WHEREAS, the Requesting Parties have received no communications from Streakwave regarding the currently pending dates;

WHEREAS, the Requesting Parties have not been informed of who is/are Streakwave's counsel;

WHEREAS, in order to submit an Updated Joint Case Management Statement, it is necessary that Streakwave provide its input and positions on the issues presented in the Updated Joint Case Management Statement, including a proposed case schedule for handling this matter;

WHEREAS, the Requesting Parties have conferred and agreed to jointly request a three (3) week continuance of all pending dates, including the time for: (1) all parties to submit their Updated Joint Case Management Statement to January 9, 2014; (2) Ubiquiti's time to file their Response to Plaintiffs First Amended Class Action Complaint to January 16, 2014; (3) Ubiquiti to submit its Initial Disclosure to January 23, 2014; and (4) the Further Case Management Conference to January 23, 2014, at 10:30 a.m.

WHEREAS, Local Rule 6-1 permits the parties to stipulate in writing without a court order, "to enlarge or shorten the time in matters not required to be filed or lodged with the Court. . . provided the change will not alter the date of any event or any deadline already fixed by Court order." Local Rule 6-1;

WHEREAS, the Requesting Parties are not aware of any date fixed by Court order that will be altered by the Requesting Parties' stipulation, absent the Court's execution of this Proposed Order (which would modify the deadline to submit an Updated Joint Case Management Statement, for Ubiquiti to file its Initial Disclosure, and the date of the Further Case Management Conference);

WHEREAS, the requested extensions will not otherwise alter the schedule of this case; and

WHEREAS, good cause exists to grant the Requesting Parties' Stipulated Request.

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED as follows:

1. Ubiquiti's time to respond to Plaintiffs' First Amended Class Action Complaint shall be due by January 16, 2014;

NOW THEREFORE, THE REQUESTING PARTIES JOINTLY REQUEST AN ORDER STATING:

1. The last day to submit an Updated Joint Case Management Statement shall be by January 9, 2014;

2. Ubiquiti shall file its Initial Disclosure by January 23, 2014; and

2. The Further CMC shall be set for Thursday, January 23, 2014, at 10:30 a.m. or such other time convenient for the Court.

IT IS SO STIPULATED.

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED,