CASE NO. 3:17-cv-00561-WHO 

UBIQUITI DEFENDANTS’ OPPOSITION TO SYNOPSYS’ MOTION TO EXTEND TIME FOR CMC

sf-3920562 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

JENNIFER LEE TAYLOR (SBN 161368) 

JTaylor@mofo.com 

RICHARD S.J. HUNG (SBN 197425) 

RHung@mofo.com 

ROBIN L. BREWER (SBN 253686) 

RBrewer@mofo.com 

JOYCE LIOU (SBN 277720) 

JLiou@mofo.com 

MICHAEL J. GUO (SBN 284917) 

MGuo@mofo.com 

MORRISON & FOERSTER LLP 

425 Market Street 

San Francisco, California 94105-2482 

Telephone: (415) 268-7000 

Facsimile: (415) 268-7522 

Attorneys for Defendants 

UBIQUITI NETWORKS INC. and UBIQUITI 

NETWORKS INTERNATIONAL LIMITED 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

SYNOPSYS, INC., 

Plaintiff, 

v. 

UBIQUITI NETWORKS, INC., UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

CHING-HAN TSAI, and DOES 1-20, 

inclusive 

Defendants. 

Case No. 3:17-cv-00561-WHO 

UBIQUITI NETWORKS, INC. AND 

UBIQUITI NETWORKS 

INTERNATIONAL LIMITED’S 

OPPOSITION TO PLAINTIFF 

SYNOPSYS, INC.’S MOTION TO 

EXTEND TIME FOR CASE 

MANAGEMENT CONFERENCE 

UBIQUITI NETWORKS, INC. and UBIQUITI 

NETWORKS INTERNATIONAL LIMITED, 

 Counterclaimants, 

 v. 

SYNOPSYS, INC., 

 Counterdefendant. 
1 

CASE NO. 3:17-cv-00561-WHO 

UBIQUITI DEFENDANTS’ OPPOSITION TO SYNOPSYS’ MOTION TO EXTEND TIME FOR CMC

sf-3920562 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Defendants Ubiquiti Networks, Inc. and Ubiquiti Networks International Limited 

(collectively, “Ubiquiti Defendants”) hereby oppose Plaintiff Synopsys, Inc.’s motion to extend 

the Case Management Conference (“CMC”) date currently set for September 11, 2018 to 

October 16, 2018. 

 Synopsys’ explanation for filing its motion is that unless the CMC date is extended to 

October 16, 2018, the parties cannot comply with Your Honor’s June 6, 2018 Minute Order that 

the parties should attend an additional mediation with Judge Layn Phillips prior to the next CMC. 

The Ubiquiti Defendants oppose the motion because they prefer an earlier mediation date, in part 

to accommodate work conflicts, religious holidays, and anticipated paternity leave for Ubiquiti’s 

in-house counsel beginning in early August. (Taylor Decl. ¶ 2.) Judge Phillips is available on 

only five dates prior to September 11 that do not work for both parties. (Id.) The Ubiquiti 

Defendants have asked Synopsys if it would agree to a mediation with Judge Gary Feess, who comediated the last session with Judge Phillips, and offered two specific dates in July when 

Ubiquiti, its counsel, and Judge Feess are available, but Synopsys refused. (Id. ¶ 3.) It is not 

practical or judicially efficient to modify the existing schedule by extending the September 11 

CMC date, merely to accommodate Judge Phillips’ availability, when the Ubiquiti Defendants are 

willing to mediate with another private mediator and/or attend a settlement conference before a 

magistrate judge on earlier dates. (Id. ¶ 4.) The parties cannot rule out that a continuation will 

not affect later deadlines. In addition, the Ubiquiti Defendants believe the case will benefit from 

a CMC in September, when Your Honor can address any relevant issues from expected motion 

practice prior to October 11. (Id.) 

Accordingly, the Ubiquiti Defendants respectfully request that the Court deny Synopsys’ 

motion to extend the September 11, 2018 CMC date. The solution here is to order the parties to 

explore other ADR options prior to September 11, such as a mediation with Judge Feess or a 

settlement conference with a magistrate judge, rather than grant Synopsys’ motion that effectively 

forces a late mediation in October—which will likely push any subsequent settlement conference 

into the new year, when the undersigned is unavailable due to a planned vacation in Africa, as 

discussed at the June 6 hearing.
2 

CASE NO. 3:17-cv-00561-WHO 

UBIQUITI DEFENDANTS’ OPPOSITION TO SYNOPSYS’ MOTION TO EXTEND TIME FOR CMC

sf-3920562 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Dated: July 16, 2018 JENNIFER LEE TAYLOR

RICHARD S.J. HUNG 

ROBIN L. BREWER 

JOYCE LIOU 

MICHAEL J. GUO 

MORRISON & FOERSTER LLP 

By: /s/ Jennifer Lee Taylor

JENNIFER LEE TAYLOR 

Attorneys for Defendants 

UBIQUITI NETWORKS, INC. AND 

UBIQUITI NETWORKS 

INTERNATIONAL LIMITED