Plaintiff-Appellant Wi-LAN Inc. (“Wi-LAN”) respectfully moves for a 30-

day extension of the due date for its opening brief. The opening brief is currently

due on July 30, 2014, and the extension sought here would extend the due date up

to and including August 29, 2014. This is Wi-LAN’s second request for an

extension of time to file its opening brief, having previously sought and received a

first, 30-day extension.

The requested 30-day extension is needed due to a joint motion of Wi-LAN

and Apple at the district court to seal certain trial exhibits to be included in the

parties’ appeal submissions. The motion to seal is required so that both sides can

make their appeal submissions with proper confidentiality designations and

protections for certain highly confidential materials included among the trial

exhibits in the record. The extension is also sought because of the press of a heavy

caseload in preparation for an upcoming trial between the parties.

Both Wi-LAN and Apple seek the district court’s order sealing certain trial

exhibits under the district court’s Protective Orders in the underlying case, which

order will affect the parties’ preparation of their non-confidential and confidential

briefs and the Joint Appendix. Undersigned counsel also has competing deadlines

and obligations in other matters, including Wi-LAN, Inc. v. Apple, Inc., Case No.

3:13-CV-798-DMS (BLM) (S.D. Cal.).

Under the circumstances, Wi-LAN submits that the 30-day extension it is

seeking is both necessary and reasonable.

Defendant-Cross-Appellant Apple does not oppose the requested extension.

A proposed order believed appropriate for entry by the Court is attached to this

motion.