XIII. Consent to Magistrate Judge For All Purposes

The parties have no modifications to the positions taken in their initial Joint Case Management Statement. Dkt. No. 41.

XIV. Other References

The parties have no modifications to the positions taken in their initial Joint Case Management Statement. Dkt. No. 41.

XV. Narrowing of Issues

Other than the potential for narrowing or eliminating issues through summary judgment, the Parties do not believe that there are any issues that can be narrowed at this time.

XVI. Expedited Trial Procedure

The Parties do not believe that this case is appropriate for Expedited Trial Procedure.

XVII. Scheduling

The Parties propose the Court adopt one of the following sets of proposed dates for the remaining events:

Event e.Digital’s Proposed Dates Dropcam’s Proposed Dates

Fact DiscoveryClose April 30, 2016 March 7, 2016

Mediation Deadline May 6, 2016 March 14, 2016

Designation of Expert Witnesses (Party WithBurden of Proof) April 15, 2016

Supplemental Designation of Expert Witnesses (Party WithoutBurden of Proof) April 30, 2016

Opening Expert Reports June 10, 2016 April 25, 2016

Rebuttal Expert Reports July 8, 2016 June 13, 2016

Expert Discovery Closes August 19, 2016 July 20, 2016

Deadline for Filing Dispositive Motions September 9, 2016 August 10, 2016

Final Pretrial Conference October 7, 2016

Trial October 10, 2016 90 days after orders on dispositive motions, subject to Court’s calendar

XVIII. Trial

The Parties agree that this matter should be tried before a jury. The parties estimate that trial will take 5-7 Court days.

XIX. Disclosure of Non-party Interested Entities or Persons

The Parties filed certifications pursuant to Civil L.R. 3-15. Dkt Nos. 5, 16. Dropcam filed a supplemental Federal Rule of Civil Procedure 7.1 and Northern District of California Civil Local Rule 3-15 Disclosure Statement on October 23, 2015. Dkt. No. 77. Pursuant to Fed. R. Civ. P. 7.1 and Civil L.R. 3-15, Defendant Dropcam hereby discloses that Dropcam is a wholly-owned subsidiary of Nest Labs, Inc. (“Nest”). Nest is a wholly-ownedsubsidiary of public company Google Inc. (“Google”). Google is a wholly-owned subsidiary of public company Alphabet Inc. (“Alphabet”). Accordingly, Alphabet has more than ten percent (10%) ownership of Google. No parent corporation or publicly-held corporation owns ten percent (10%) or more of Alphabet’s stock.

XX. Other

The Parties are unaware of any other matters at this time.

Dated: December 30, 2015 HANDAL & ASSOCIATES

By: /s/ Gabriel G. Hedrick

Gabriel G. Hedrick

Attorneys for Plaintiff

E.DIGITAL CORPORATION

Dated: December 30, 2015 WILSON SONSINI GOODRICH & ROSATI

By: ________/s/ Stefani E. Shanberg

Stefani E. Shanberg

Attorneys for Defendant

DROPCAM, INC.

ATTESTATION CLAUSE

Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures Manual, I, Gabriel G. Hedrick, attest that signatory, Stefani E. Shanberg, has read and approved the foregoing and consents to its filing in this action.

By: /s/ Gabriel G. Hedrick

[PROPOSED] FURTHER CASE MANAGEMENT ORDER

The above FURTHER JOINT CASE MANAGEMENT STATEMENT & PROPOSED ORDER, including the proposed schedule set forth in Section XVII, is hereby adopted by the Court and all parties shall comply with its provisions.

IT IS SO ORDERED.

Dated:

UNITED STATES DISTRICT COURT JUDGE