NORTHERN DISTRICT OF CALIFORNIA

e.Digital Corporation,

Plaintiff,

v.

Y-Cam Solutions, LLC,

Defendant.

Case No. 3:16-cv-05215-JST

NOTICE OF SETTLEMENT AND

MOTION TO STAY ALL PENDING

MOTIONS, HEARINGS AND

DEADLINES IN THIS MATTER

Assigned to the Hon. Jon S. Tigar

NOTICE IS HEREBY GIVEN that the aforementioned matter known as e.Digital

Corporation v. Y-Cam Solutions, LLC, Case No. 3:15-cv-05215-JST, has been resolved in its entirety. Plaintiff e.Digital Corporation (“e.Digital”)-CAMticipates filing a Motion for Dismissal in this matter no later than August 25, 2017, after all conditions for dismissal are satisfied as agreed to between the parties.

Based on the foregoing, e.Digital respectfully moves for an order from the Court staying

all motions, hearings and deadlines in this matter, including e.Digital’s pending motion for default judgment and the related motion hearing currently scheduled for June 29, 2017 at 2:00 p.m.

e.Digital does not submit this request to the Court for purposes of delay, but rather so that Defendant Y-Cam may have the necessary time to fulfill certain conditions specified in the parties’ settlement agreement required for dismissal of this matter.

Respectfully submitted.

GREENSPOON MARDER LLP

Dated: June 22, 2017 By: /s/ Gabriel G. Hedrick

Gabriel G. Hedrick

Attorneys for Plaintiff

e.DIGITAL CORPORATION