JOINT MOTION FOR TEMPORARY STAY AS TO

SUMMIT TECHNOLOGY GROUP, LLC

Plaintiff e.Digital Corporation (“e.Digital”) and Defendant Summit Technology Group,

LLC (”Summit”), by and through their counsel of record, hereby submit this Motion for

Temporary Stay of Litigation as to Summit Technology Group, LLC.

Plaintiff e.Digital and Defendant Summit have been engaged in confidential settlement

negotiations which both parties anticipate are likely to lead to resolution of the lawsuit as to

Summit. The settlement resolution as currently contemplated is contingent upon Summit’s

business performance during the next few months. Summit is one of twenty-eight defendants

in the above-captioned litigation.

Accordingly, e.Digital and Summit jointly request that the Court stay the case as to

Summit only for the period of four months, ending April 15, 2011 (the “Stay Period”) to

enable these parties to attempt to resolve the litigation as to Summit.

To ensure the Stay will not impact the ongoing litigation, Summit agrees to be bound by

any substantive decisions rendered by the Court during the period of the Stay. Summit

reserves the right to join in any appeal taken by any of the remaining defendants of any

substantive decision made during the Stay Period.

For the convenience of Court, a proposed Order has been submitted contemporaneously

with this motion.

Respectfully Submitted this 14th day of December, 2010.