STIPULATION AND  ORDER GRANTING LEAVE TO FILE SECOND AMENDED COMPLAINT
Plaintiff SecuGen Corporation ("SecuGen") and defendant Union Community Co. Ltd., ("Union Community") submit the following Joint Stipulation and request that the Court grant SecuGen leave to file a Second Amended Complaint pursuant to Rule 15(a) of the Federal Rules of Civil Procedure:
1. SecuGen filed its complaint on March 6, 2008 in the United States District Court for the Northern District of California;
2. On March 27, 2008, prior to Union Community filing any response, SecuGen filed its First Amended Complaint;
3. Union Community filed and served its Answer to the First Amended Complaint on May 22, 2008;
4. SecuGen has informed Union Community of its intent to file a Second Amended Complaint;
5. Union Community has received a copy of the proposed Second Amended Complaint;
6. By stipulating to the filing for leave to file the Second Amended Complaint, Union Community is not stipulating to the accuracy or relevance of the factual allegations or legal conclusions made in the proposed Second Amended Complaint or to the inferences that may be drawn from those allegations, nor does Union Community waive its right to move to dismiss any claim alleged in the Second Amended Complaint; and
7. SecuGen and Union Community stipulate that Union Community's response to Goodwin Procter LLP 135 Commonwealth Drive Menlo Park, California 94025 SecuGen's Second Amended Complaint shall be due 30 days from the date of the entry of the Court's grant of the proposed order below.
THEREFORE, the parties hereby stipulate and request that the Court grant SecuGen leave to file a Second Amended Complaint in this action, a true and correct copy of which is attached as Exhibit A hereto.
Plaintiff SecuGen Corporation By its attorneys, Ruby M. Wayne Email: email@example.com GOODWIN PROCTER LLP 135 Commonwealth Drive Menlo Park, California 94025 Telephone: 650-752-3100 Facsimile: 650-853-1038
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