STIPULATION AND [PROPOSED] ORDER TO PERMIT FILING OF SECOND AMENDED COMPLAINT

BETH LABSON FREEMAN, District Judge.

WHEREAS Plaintiff MITAC DIGITAL CORPORATION has provided to Defendant HON HAI PRECISION INDUSTRY, CO., LTD. a proposed Second Amended Complaint a copy of which sans lengthy exhibits is attached hereto as Exhibit 1.

WHEREAS HON HAI PRECISION INDUSTRY, CO., LTD has reviewed said proposed Second Amended Complaint.

WHEREAS the parties have agreed in principal to vacate the existing trial date of March 2, 2015, subject to Court order, and to a rescheduling by approximately 90 to 120 days of all attending dates currently set, for reasons including the necessity of taking numerous depositions in Taiwan, including non-party depositions, as well as other depositions outside of California and the complexities and delays involved in such, particularly as to non-party depositions in Taiwan, as well as the desire of HON HAI PRECISION INDUSTRY, CO., LTD to conduct discovery related to additional facts and claims set forth in the proposed Second Amended Complaint. The parties have agreed to the filing of said proposed Second Amended Complaint, with Defendant to have thirty days to respond thereto: which agreement is not conditioned upon the Court vacating the existing trial date and or rescheduling other dates.

IT IS SO STIPULATED.

The above having been considered, and good cause shown:

IT IS HEREBY ORDERED THAT: Plaintiff may file its proposed Second Amended Complaint and that Defendant shall have thirty days to respond thereto.