JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING APRIL 15, 2016 CASE MANAGEMENT CONFERENCE

SUSAN ILLSTON, District Judge.

Pursuant to Civil Local Rule 7-12, Defendants Fitbit Inc., James Park, and William R. Zerella ("Defendants") and Plaintiff Brian H. Robb ("Plaintiff" and collectively, with Defendants, the "Parties"), by and through their undersigned counsel of record, submit the following stipulation and proposed order:

WHEREAS, Defendants waived service of the Summons and Complaint in this action on April 5, 2016;

WHEREAS, as a federal securities class action governed by the provisions of the Private Securities Litigation Reform Act of 1995, 15 U.S.C. §78u-4, et seq. ("PSLRA"), this Action is subject to a mandatory stay of all discovery and other proceedings pending determination of any motion to dismiss;

WHEREAS, competing motions for appointment as Lead Plaintiff and approval of Lead Counsel for the putative Class in this action pursuant to the PSLRA were filed on March 11, 2016 and are currently pending before the Court;

WHEREAS, the Court has scheduled a Case Management Conference ("CMC") in this Action for April 15, 2016 at 2:30 p.m. (Dkt. No. 5);

WHEREAS, the Parties believe it would save judicial and Party resources if the Case Management Conference ("CMC") is deferred until after this Court has appointed a Lead Plaintiff and approved Lead Plaintiff's selection of Lead Counsel for the Class and after an Amended Complaint, if any, has been filed by Lead Plaintiff;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between the undersigned Parties that:

ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED:

1. The April 15, 2016 CMC shall be rescheduled to June 10, 2016, at 2:30 p.m.