WHEREAS, the Parties, having met and conferred, were able to reach a compromise with respect to the claim terms "social template," "unique social signature," "optical sensor," and "accurate," as set forth in the table below; Claim Term or Phrase

Agreed Construction

"social template"

"data structure associated with a social hierarchy and one or more social signatures"

"unique social signature"

"social signature associated with a specific social template at the time of processing"

"optical sensor"

plain and ordinary meaning

"accurate"

"capable of desired processing"

/s/ Madeleine E. Greene

/s/ Pamela C. Chalk

the Court’s Scheduling Order and Patent LR 4-2, 4-3 and 4-5, and reserves the right to raise arguments not raised in its briefs in rebuttal should the Court be inclined to consider the same;

WHEREAS, the Parties also agree that neither will call witnesses at the Claim Construction Hearing and that the Claim Construction Hearing can be completed in three (3), rather than four (4), hours;

WHEREAS, the Parties make a stipulated request to amend the Joint Statement to reflect mutual agreement having been reached regarding the construction of the claim terms "social template," "unique social signature," "optical sensor," and "accurate," and to reflect the narrowing of the dispute regarding the construction of the claim term "social signature," as reflected in the Proposed Amended Joint Claim Construction Statement and Pre-Hearing Statement (Patent L.R. 4-3), attached hereto as Exhibit A.

IT IS HEREBY STIPULATED AND AGREED, pursuant to Civil Local Rule 6-1, by e.Digital and Dropcam, through their respective counsel, that the Parties shall file an Amended Joint Claim Construction Statement and Pre-Hearing Statement (Patent L.R. 4-3), attached hereto as Exhibit A.

IT IS SO STIPULATED, through Counsel of Record.

Dated: July 30, 2015 WILSON SONSINI GOODRICH & ROSATI Professional Corporation

By:

Madeleine E. Greene

Attorneys for Defendant DROPCAM, INC.

Dated: July 30, 2015 HANDAL & ASSOCIATES

By:

Pamela C. Chalk

Attorneys for Plaintiff

E.DIGITAL CORPORATION