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Message: CES

As we know e.DIGITAL wants full Discovery & source code review from Dropcam and will continue to pursue this negotiation.

"The Parties anticipate that further discovery may include additional written discovery, source code review, and depositions.

e.Digital asserts that its proposed discovery schedule set forth in Section XVII, below, reflects the fact that the parties have exchanged only one set of written discovery so far and the fact that the parties are still negotiating a stipulated protective order for the Court to enter. As of the date of this filing, despite Dropcam’s Patent L.R. 3-4(a) obligations and initial responses to requests for production, Dropcam has produced relatively little in the way of technical documentation. It is e.Digital’s position that Dropcam’s proposed schedule leaves too little time for the parties to finalize and submit the stipulated protective order, review any subsequent confidential technical documentation, including source code review, resolve any remaining discovery disputes, conduct depositions, and provide its expert witnesses sufficient time to review said discovery for incorporation into their expert reports. "

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