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REQUEST FOR SUPPLEMENTAL ORDER IN LIGHT OF PENDING APPEAL

Mark R. Figueiredo, Esq. (SBN 178850)

Ethan G. Solove, Esq. (SBN 308026)

STRUCTURE LAW GROUP, LLP

1754 Technology Drive, Suite 135

San Jose, California 95110

Telephone: (408) 441-7500

Facsimile: (408) 441-7501 

Attorneys for Defendants 

INDYZEN, INC. and PRAVEEN NARRA KUMAR

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

PARKRIDGE LIMITED, a Hong Kong 

corporation, by Mabel Mak, and MABEL 

MAK, an individual,

Plaintiffs,

v.

INDYZEN, INC., a California corporation, 

and PRAVEEN NARRA KUMAR, an 

individual,

Defendants.

 CASE NO. 16-CV-07387-JSW

REQUEST FOR SUPPLEMENTAL 

ORDER FOR DEFENDANTS’ 

PETITION TO COMPEL 

ARBITRATION IN LIGHT OF THE 

LOSING PARTIES’ PENDING APPEAL 

OF JUDGE WHITE’S ORDER

Date: N/A

Time: N/A

Dept.: N/A

Judge: Hon. Jeffrey S. White

Defendants Indyzen, Inc. and Praveen Narra Kumar (“Defendants”) hereby request a 

supplemental order from this Court on Defendants’ previously-ruled upon petition to compel 

arbitration, in light of the losing parties’ pending appeal of that order. With their appeal, the 

losing parties seek to overturn Hon. Judge Jeffrey White’s order and to continue their efforts to 

evade justice. 

On April 13, 2018, after extensive briefing from both sides, Judge White of this Court 

granted Defendants’ petition to compel several parties to the arbitration related to this case and 

denied the other sides’ motion to dismiss. In doing so, Judge White ruled that the losing parties 

“are closely related with Randy Dobson”, (“Dobson”) who signed an Agreement with an 

arbitration clause on behalf of his company Plaintiff Parkridge Limited (“Parkridge”). (See Dkt. 

Case 4:16-cv-07387-JSW Document 71 Filed 07/25/18 Page 1 of 3
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REQUEST FOR SUPPLEMENTAL ORDER IN LIGHT OF PENDING APPEAL

63 – Judge White’s Order Granting Petition to Compel Arbitration and Denying Motions to 

Dismiss.) The losing parties subsequently filed a petition for a writ of mandamus with the 9th

Circuit Court of Appeals on May 9, 2018, attempting to overturn Judge White’s decision. Since 

this Court’s ruling on the petition to compel arbitration, the losing parties have all been ordered to 

join the arbitration by the Arbitrator, and the arbitration has been proceeding against them. 

Last week on July 19, 2018, the 9th Circuit Court of Appeals entered an order requesting

an answer to the petition for a writ of mandamus. The Appeals Court also ordered that “[t]he 

district court, within 14 days after the date of this order, may address the petition if it so desires. 

The district court may elect to file an answer with this court or to issue a supplemental order and 

serve a copy on this court.” (Dkt. 67 – Appeals Court Procedural Order.) The deadline for either 

action is set for a week from Thursday, on August 2, 2018.

In light of the Appeals Court’s order, Defendants respectfully request that this Court

submit a supplemental order that would assist the Appeals Court in its analysis. One of the issues 

raised by the losing parties in their petition for a writ of mandamus is that Judge White’s order 

focused on Dobson’s signing of the agreement with the arbitration clause, rather than the 

company for which he signed, Parkridge. However, in his order, Judge White found and ruled 

that the “Dobson Companies and their business dealings are sufficiently interrelated and 

interdependent on conduct governed by” the agreement with the arbitration clause, and that “the 

doctrine of equitable estoppel enables the Court to find that the nonsignatories may be bound by 

the agreement despite not having signed it.” (Dkt. 63.) Dobson and the Dobson Companies are 

equally closely related, interrelated, and interdependent with Parkridge, all of which was briefed 

extensively in Defendants papers for the petition. 

Given the above, Defendants respectfully request that this Court issue a supplemental 

order finding and ruling that Dobson and the Dobson Companies are also compelled to arbitration 

because of their close ties to Parkridge, in addition to the findings and ruling that this Court has 

already made. This supplemental order would provide further explanation to the Appeals court 

for why the losing parties were compelled to arbitration and would serve the interests of justice 

///

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REQUEST FOR SUPPLEMENTAL ORDER IN LIGHT OF PENDING APPEAL

intended by this Court’s original order on the petition.

Dated: July 25, 2018 STRUCTURE LAW GROUP, LLP

By: /s/ Ethan G. Solove

Ethan G. Solove, Esq.

Attorneys for Defendants

INDYZEN, INC., and PRAVEEN NARRA 

KUMAR 

Case 4:16-cv-07387-JSW Document 71 Filed 07/25/18 Page 3 of 3