SUPP. DECL. OF DENISE M. MINGRONE ISO

MOTION TO EXTEND TIME FOR CMC 

3:17-CV-00561-WHO 

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ORRICK, HERRINGTON &

SUTCLIFFE LLP 

ATTORNEYS AT LAW

SILICON VALLEY

DENISE M. MINGRONE (STATE BAR NO. 135224)

dmingrone@orrick.com 

ROBERT L. URIARTE (STATE BAR NO. 258274) 

ruriarte@orrick.com 

ORRICK, HERRINGTON & SUTCLIFFE LLP 

1000 Marsh Road 

Menlo Park, CA 94025-1015 

Telephone: +1 650 614 7400 

Facsimile: +1 650 614 7401 

CLAUDIA WILSON FROST (Pro Hac Vice) 

cfrost@orrick.com 

ORRICK, HERRINGTON & SUTCLIFFE LLP 

609 Main Street, 40th Floor 

Houston, TX 77002-3106 

Telephone: +1 713 658 6460 

Facsimile: +1 713 658 6401 

Attorneys for Plaintiff/Counterdefendant 

SYNOPSYS, INC. 

IN THE 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 (LB)

SUPPLEMENTAL DECLARATION 

OF DENISE M. MINGRONE IN 

SUPPORT OF SYNOPSYS’ MOTION 

TO EXTEND TIME FOR CASE 

MANAGEMENT CONFERENCE 

Dept. Courtroom 2, 17th Floor 

Judge: Hon. William H. Orrick 

UBIQUITI NETWORKS, INC. 

Counterclaimant, 

v. 

SYNOPSYS, INC., 

Counterdefendant. 
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SUPP. DECL. OF DENISE M. MINGRONE ISO

MOTION TO EXTEND TIME FOR CMC 

3:17-CV-00561-WHO 

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ORRICK, HERRINGTON &

SUTCLIFFE LLP 

ATTORNEYS AT LAW

SILICON VALLEY

I, Denise M. Mingrone, declare as follows: 

1. I am a member of the California State Bar, admitted to practice before this Court, 

and am a partner in the law firm of Orrick, Herrington & Sutcliffe LLP, counsel of record for 

Plaintiff Synopsys, Inc. (“Synopsys”) in this matter. I have personal knowledge of the facts 

stated in this declaration. I could and would testify competently to the matters stated herein. 

2. On Friday afternoon July 13, the day after Synopsys filed its motion, 

Ubiquiti/UNIL informed me that they had reconsidered and were “willing to do a mediation with 

Judge Phillips or Judge Feess prior to the end of July.” See Ex. C at 2-3 (7/13/2018 email from J. 

Taylor). Specifically, however, Defendants demanded that Synopsys mediate with Judge Gary 

Feess (not Judge Phillips as ordered by the Court) and only on July 19 or 23. Id. I reminded 

counsel that the parties currently have depositions scheduled for July 18, 19, 24, 25, and 27 and 

need to prepare for said depositions, but I nevertheless agreed to ask Synopsys about its 

availability to mediate on those two dates. Id. at 1 (7/13/2018 email from D. Mingrone). 

3. After determining Synopsys could not accommodate either date based on such late 

notice and pre-planned travel, on Sunday, July 15, I informed Ubiquiti/UNIL that Synopsys was 

not available to attend a mediation on either date. Id. (7/15/2018 email from D. Mingrone). I 

renewed Synopsys’ requests that Ubiquiti/UNIL agree to one of the several later dates already 

proposed by Judge Phillips for prior to the September 11 CMC, or, in the alternative, that it 

stipulate to move the CMC to October 16 in order to accommodate its own schedule. Id. 

4. A true and correct copy of the parties’ email correspondence described above is 

attached hereto as Exhibit C.

5. Synopsys remains committed to mediating before Judge Phillips, who is the 

mediator selected by both parties and who is intimately familiar with the facts of the case and the 

parties’ positions. Synopsys believes that the parties’ best chance at settlement is to attend a 

further mediation session with Judge Phillips now that the parties have engaged in substantially 

more discovery than they had at the time of the original mediation session. 

6. Again, Synopsys foresees no reason why extending the CMC to October 16 would 

affect any existing deadlines or schedules in this case. 
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SUPP. DECL. OF DENISE M. MINGRONE ISO

MOTION TO EXTEND TIME FOR CMC 

3:17-CV-00561-WHO 

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ORRICK, HERRINGTON &

SUTCLIFFE LLP 

ATTORNEYS AT LAW

SILICON VALLEY

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct. Executed this 17th day of July, 2018 at Menlo Park, California. 

_/s/ Denise M. Mingrone______

DENISE M. MINGRONE