TO THE CLERK OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA:

NOTICE IS HEREBY GIVEN that the aforementioned matter known as e.Digital Corporation v. ArcSoft, Inc., dba as Closeli and as simplicam Case Number3:15-cv-00056, has been settled in principle.

Plaintiff e.Digital Corporation (“Plaintiff”) and Defendant ArcSoft, Inc., dba as Closeli and as simplicam (“Defendant”) have reached an agreement in principle for settlement of the above-captioned matter and are in the process of trying to finalize their settlement agreement. Plaintiff and Defendant are referred to collectively hereafter as the “Parties.” The Parties anticipate filing a notice of voluntary dismissal of the claims and counterclaims in this case no later than June 12, 2015.

In light of the above, the Parties further agree and stipulate that Plaintiff will and hereby does withdraw without prejudice its motion entitled, “Plaintiff And Counterdefendant e.Digital Corporation’s Notice Of Motion And Motion To Transfer Venue To The Northern District Of California.” (“Motion”) (Dkt #19 et seq.).

In light of the foregoing, the Parties further make the following joint motion seeking the following relief:

1) An order from the Court staying all deadlines in this matter up to and including June 12, 2015, by which date the parties expect to have executed a settlement agreement and it is anticipated that the Parties will file a joint motion for the dismissal of all claims and counterclaims in the case; and,

2) An order taking off calendar the following pending motion current set to be heard on June 15, 2015 at 10:30 a.m.:

• a) “Plaintiff And Counterdefendant e.Digital Corporation’s Notice Of Motion And Motion To Transfer Venue To The Northern District Of California” (Dkt #19 et seq.).

This limited stay of deadlines is for good cause and so that justice may be served. The Parties do not submit this request to the Court for purposes of delay, but rather so that they may have time to finalize a written settlement agreement and dismiss this matter forthwith in its entirety.

Pursuant to Local Civil Rule 7.2, the parties hereto will separately submit a Proposed Order granting the relief requested Dated: May 28, 2015

HANDAL & ASSOCIATES By: /s/Pamela C. Chalk__________________ Anton N. Handal Pamela C. Chalk Gabriel G. Hedrick Attorneys for Plaintiff e.Digital Corporation Dated: May 28, 2015

FISH & RICHARDSON P.C. By: /s/Olga May _________________ Roger Borovoy Christopher S. Marches Olga May Kevin Kantharia Attorneys for Defendant ArcSoft, Inc