JOINT STIPULATION AND [PROPOSED] ORDER REGARDING AUTHENTICITY OF DOCUMENTS

EDWARD M. CHEN, District Judge.

WHEREAS, Aylus Networks, Inc. ("Aylus") commenced the above-captioned action (the "Litigation") against Apple Inc. ("Apple," and together with Aylus, "the Parties," and individually each a "Party") on October 9, 2013;

WHEREAS, the Parties subsequently have produced thousands of pages of documents in connection with discovery in the Litigation; and

WHEREAS, the Parties have determined that it is in their mutual interest to avoid the significant and unnecessary burden and expense associated with the document-by-document authentication of documents, and that stipulating to the authenticity of certain documents will promote the orderly and efficient progress of the Litigation.

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

1. Absent affirmative evidence that a document or thing is not what it purports to be, the Parties agree that documents produced by either Apple or Aylus in the Litigation will be presumed authentic for purposes of Rule 901 of the Federal Rules of Evidence.

2. The Parties agree that, absent affirmative evidence to the contrary, documents produced from the records of either Party are presumptively business records for purposes of Rule 902(11).

3. Nothing in this stipulation shall be construed as an agreement that any documents or things that are subject to this stipulation are admissible into evidence by any Party, except as expressly addressed herein. The Parties hereby expressly reserve the right to object to the admissibility of any document or thing under any grounds permitted by law and not expressly addressed herein.