STIPULATION AND ORDER REGARDING EXTENDING DEADLINE FOR THE PARTIES TO COMPLETE LIMITED FACT DISCOVERY

WILLIAM H. ORRICK, III, District Judge.

Plaintiff Fujifilm Corporation and Defendant Motorola Mobility LLC (collectively, the "parties"), by and through their undersigned counsel, hereby stipulate as follows:

WHEREAS, in the Court's Order Regarding Scheduling (Docket #82), the Court approved the parties' agreed-on deadline of July 18, 2014 as the close of fact discovery;

WHEREAS, in the Stipulation and Court Order Regarding Ongoing Review of Source Code and Extending Deadline for the Parties to Complete Limited Fact Discovery (Docket #131), the Court approved the parties stipulation to a short extension until August 8, 2014 to complete limited fact discovery, and approved the parties stipulation to permit access to the source code produced by certain third parties for review and printing until at least January 16, 2015;

WHEREAS, the parties have endeavored to complete all fact discovery by the extended deadline of August 8, 2014, but believe that it is reasonably necessary that additional time should be afforded to accommodate the schedules of and minimize the burdens on third parties who were subpoenaed for documents and/or testimony before August 8, 2014, including representations from Nvidia Corporation that its designated witness is not available for deposition until the week of August 25-29, 2014.

WHEREAS, to accommodate and coordinate with the schedules of third parties whose depositions have been noticed by one or both of the parties for documents and/or testimony, and to afford the parties additional time to attempt to reach agreements on the admissibility of third-party declaration testimony, which could potentially obviate the need for certain third parties to sit for depositions or produce source code, the parties jointly request a short three-week extension of the August 8, 2014 deadline to meet and confer in this regard and complete the taking of discovery from these third parties, including the following contemplated discovery: a deposition of and possible declaration from Nvidia Corporation, a declaration from or possible deposition of OmniVision Technologies, Inc., a declaration from Qualcomm Incorporated, a declaration from Texas Instruments Inc., a declaration from Hewlett-Packard Company, a deposition of Jani Kaikko, and a deposition of Microsoft Corporation.

WHEREAS, there has been one prior request for a short extension to the initial July 18, 2014 fact discovery deadline, and a further limited extension of this deadline for the limited purpose of conducting third-party discovery will not affect any other Court-set deadlines.

NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys of record that the August 8, 2014 deadline for the taking of fact discovery is (1) extended by two weeks, until August 22, 2014, to complete the taking of discovery from third parties OmniVision, Qualcomm Incorporated, Texas Instruments Inc., and Hewlett-Packard Company, and (2) extended by three weeks, until August 29, 2014 to compete the taking of discovery from third parties Nvidia Corporation, Microsoft Corporation, and Jani Kaikko.

IT IS SO ORDERED.