JOINT MOTION FOR EXTENSION OF TIME TO FILE PROTECTIVE ORDER

Plaintiff e.Digital Corporation and Defendants Avid Technology, Inc., Nikon Inc., Olympus America, Inc., Samsung Electronics America, Inc. and Sanyo North America Corporation hereby move for an extension of time until December 22, 2008 to file a proposed Protective Order. In support of this Joint Motion, the parties state as follows:

1. During the October 28, 2008 Scheduling Conference, the Court ordered the parties to submit an agreed Protective Order or competing versions within 30 days.

2. On November 7, 2008, the Court entered a Discovery Order (Dkt. # 101) ordering the parties to submit a Protective Order within 30 days.

3. The parties have been negotiating, and continue to negotiate, the terms of a Protective Order. In an effort to reach accord on a Protective Order, and to limit the burden on the Court of having to rule on competing versions, the parties request additional time to continue their negotiations.

WHEREFORE, the parties respectfully request that the Court grant their Joint Motion for Extension of Time to File Protective Order until December 22, 2008 and enter the proposed order attached hereto.
Respectfully and jointly submitted this 26th day of November 2008.