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Site Update Solutions LLC v. Adobe Systems

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


December 6, 2011

SITE UPDATE SOLUTIONS LLC
PLAINTIFF,
v.
ADOBE SYSTEMS, INCORPORATED ET AL.,
DEFENDANTS.

The opinion of the court was delivered by: Honorable Phyllis J. Hamilton United States District Judge

STIPULATION AND [PROPOSED] ORDER TO DISMISS ALL CLAIMS BETWEEN SITE UPDATE SOLUTIONS LLC AND WAL-MART STORES , INC. WITHOUT PREJUDICE DEMAND FOR JURY TRIAL

Pursuant to Rule 41(a)(2) of the Federal Rules of Civil Procedure and the terms of a 2 separate agreement, the Plaintiff, Site Update Solutions LLC ("Site Update") and Defendant, Wal-3 Mart Stores, Inc. ("Wal-Mart") have agreed to dismiss all claims against each other in the above-4 captioned action. The parties, therefore, move this Court to dismiss the above-entitled cause and 5 all claims by Site Update against Wal-Mart and all claims by Wal-Mart against Site Update made 6 therein without prejudice. 7

The parties further move the Court to order that all costs and expenses relating to this 8 litigation (including attorney and expert fees and expenses) shall be borne solely by the party 9 incurring same. 10

So Stipulated.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

IT IS SO ORDERED

DATED: December __, 2011

R F C GOLDSTEIN & LIPSKI, P.L.L.C. FOLEY & LARDNER LLP By: _/s/ Edward W. Goldstein_____________ By: _/s/ Victor de Gyarfas Edward W. Goldstein (Pro Hac Vice) Victor de Gyarfas 22 Attorneys for Plaintiff Attorneys for Defendant 23

ATTESTATION

I hereby attest pursuant to General Order 45.X.B that concurrence in the electronic filing of 3 this document has been obtained from the signatories.

Dated: December 5, 2011 /s/ Edward W. Goldstein________ Edward W. Goldstein

CERTIFICATE OF SERVICE

The undersigned hereby certifies that all counsel of record who are deemed to have 3 consented to electronic service are being served with a copy of this document via the Court's ECF 4 System.

Dated: December 5, 2011 /s/ Edward W. Goldstein________ Edward W. Goldstein

20111206

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