c) within 75 days such parties will complete any discovery, subject to additional time being needed to conduct foreign depositions, if necessary

d) within 90 days the parties will file a joint report to the Court advising of the status and whether any issues remain to be resolved with respect to e.Digital’s claims of infringement of the ‘774 Patent and related discovery issues.Defendants do not believe depositions are necessary or appropriate, and reserve the right to object to any demand Plaintiff may make for depositions.