1 F. Christopher Austin Nevada Bar No. 6559 2 [email protected] WEIDE & MILLER, LTD. 3 10655 Park Run Drive, Suite 100 Las Vegas, Nevada 89144 4 Tel. (702) 382-4804 Fax (702) 382-4805 5 Kerry S. Culpepper 6 Hawaii Bar No. 9837 [email protected] 7 CULPEPPER IP, LLLC 8 75-170 Hualalai Road, Suite B204 Kailua-Kona, Hawai’i 96740 9 Telephone: (808) 464-4047 Facsimile: (202) 204-5181 10 Admitted pro hac vice

11 Attorneys for Defendants

12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14

15 HURRICANE ELECTRIC LLC, Case No.: 2:20-cv-01034-JCM-DJA 16 Plaintiffs,

17 v. STIPULATION TO STAY ACTION PENDING RULING ON CO-PENDING 18 MILLENNIUM FUNDING, INC., et al. INSURANCE ACTION BY PLAINTIFF AGAINST ITS INSURER 19 Defendants. (FIRST REQUEST FOR STAY) 20

21 Whereas, HURRICANE ELECTRIC, LLC (“Plaintiff”), through its counsel Neil D. 22 Greenstein and Joshua M. Dickey, and MILLENNIUM FUNDING, INC.; BODYGUARD 23 PRODUCTIONS, INC.; UN4 PRODUCTIONS, INC.; HOMEFRONT PRODUCTIONS, INC.; 24 MILLENNIUM MEDIA, INC.; CRIMINAL PRODUCTIONS, INC.; CLEAR SKIES NEVADA, 25 LLC; HUNTER KILLER PRODUCTIONS, INC.; LHF PRODUCTIONS, INC.; RAMBO V 26 PRODUCTIONS, INC.; FALLEN PRODUCTIONS, INC.; WICKED NEVADA, LLC; 211 27 PRODUCTIONS, INC.; FATHERS & DAUGHTERS NEVADA, LLC; VOLTAGE 1 PRODUCTIONS, INC.; COBBLER NEVADA, LLC; SURVIVOR PRODUCTIONS, INC.; 2 TREVOR SHORT; and AVI LERNER (“Defendants”), through their counsel Kerry S. Culpepper 3 and F. Christopher Austin, stipulate for an order staying this action, pending resolution of Plaintiff’s 4 insurer’s duty to defend in the case entitled Hurricane Electric, LLC vs. National Fire Insurance 5 Company of Hartford, 3:20-cv-05840-CRB pending in the U.S. District Court for the Northern 6 District of California (“Co-Pending Insurance Action”). Plaintiff and the Defendants are referred to 7 collectively as “Parties.” Finally, the Parties have agreed that Defendants’ answers or other 8 responses to the complaint should be set a minimum of 60-days after the stay is lifted so that the 9 parties can engage in a settlement conference with Magistrate Judge Hixson in the case entitled 10 Hurricane Electric, LLC vs. Dallas Buyers Club, LLC et al., 3:20-CV-3813-CRB also pending in 11 the United States District Court for the Northern District of California (“Co-Pending Copyright 12 Action”) after the ruling in the Co-Pending Insurance Action. 13 Whereas, the Court entered the First Stipulation to Extend Defendants’ Deadline to Answer 14 and/or Respond to Complaint [Doc. #20]. The First Stipulation granted Defendants up until October 15 2, 2020 to respond to the Complaint. 16 Whereas, the Court entered the Second Stipulation to Extend Defendants’ Deadline to 17 Answer and/or Respond to Complaint [Doc. #23]. The Second Stipulation granted Defendants up 18 until November 2, 2020 to respond to the Complaint. 19 Whereas, the Co-pending Copyright Action was referred to Magistrate Judge Hixson of 20 the U.S. District Court for the Northern District of California for conducting an early Settlement 21 Conference per the Parties’ request; 22 Whereas, Magistrate Judge Hixson agreed to conduct the Settlement Conference on behalf 23 of the plaintiff and the defendants in both this Action and the Co-Pending Copyright Action so 24 that both disputes could be resolved together; 25 Whereas, the Parties have concluded, and Magistrate Judge Hixson after holding two 26 telephonic hearings agreed, that an early Settlement Conference would not be fruitful until after 27 the dispute over the insurer’s duty to defend between Plaintiff and its insurer, National Fire 1 or at least substantial progress has been made toward a resolution. A copy of the minutes from 2 the October 12, 2020 scheduling conference with Magistrate Hixson is attached hereto as Exhibit 3 1. 4 Whereas, on October 9, 2020, in the Co-Pending Insurance Action Plaintiff filed a Motion 5 For Partial Summary Judgment On National Fire’s Duty To Defend Hurricane Electric in the 6 dispute with defendants here and in the Co-Pending Copyright Action. 7 Whereas the Parties have agreed that all parties in this Action shall reserve all rights and 8 that this requested stay, and the slight delay in this Action, shall not be construed in any manner 9 for or against any party on any issue, whether substantive or procedural. 10 Whereas, the Parties believe that there will be no “possible damage which may result from 11 the granting of a stay” or “hardship or inequity which a party may suffer” since the parties have 12 also agreed in the Northern District of California Action that parties will be allowed to conduct 13 limited third party discovery to preserve evidence. Lockyer v. Mirant Corp.,

, 1110 14 (9th Cir. 2005) (quoting CMAX, Inc. v. Hall,

(9th Cir. 1962)). Moreover, 15 consideration of “the orderly course of justice measured in terms of the simplifying or 16 complicating issues” supports granting a stay since a stay will eliminate distraction of anticipated 17 motion practice between the parties until after the dispute between Plaintiff and its insurer, NFI, 18 in the Co-Pending Insurance Action has been resolved or at least substantial progress has been 19 made, thereby simplifying the issues.

20 Whereas, the Northern District of California entered a Stay of the Co-Pending Copyright 21 Action on October 19, 2020 per the Parties’ joint stipulation similar to the stipulation and order 22 requested in the present action. For the Court’s convenience, a filed stamped copy of the 23 Stipulation and Order of Stay issued by Northern District of California in the Co-Pending 24 Copyright Action is attached hereto as Exhibit 2. 25 IT IS HEREBY STIPULATED AND AGREED by the Parties that this Action be 26 STAYED. 27 ] The Parties intend to resume the settlement conference proceedings with Magistrate Judge 2 || Hixson in the Co-Pending Copyright Action after the Co-Pending Insurance Action has been 3 || resolved or substantially progressed. 4 The Parties shall file a status report with this Court by January 4, 2021, or if sooner, 5 || promptly after the settlement conference is conducted in the Co-Pending Copyright Action. 7 Dated this 23rd day of October, 2020. Dated this 23rd day of October, 2020. 8 CULPEPPER IP, LLLC BAILEY *#KENNEDY 10 By:___/s/ Kerry S. Culpepper By:___/s/ Joshua M. Dickey KERRY S. CULPEPPER JOSHUA M. DICKEY 11 (ADMITTED PRO Hac VICE) 8984 Spanish Ridge Avenue 75-170 Hualalai Road, Suite B204 Las Vegas, Nevada 89148-1302 12 Kailua Kona, HI 96740 In Association With: 13 F. CHRISTOPHER AUSTIN NEIL D. GREENSTEIN 14 WEIDE & MILLER, LTD. (ADMITTED PRO HAC VICE) 10655 Park Run Drive, Suite 100 TECHMARK 15 Las Vegas, Nevada 89144 1751 Pinnacle Drive, Suite 1000 Tysons, Virginia 22102 16 Attorneys for Defendants Attorneys for Plaintiff 17 Hurricane Electric LLC 18 19 IT IS SO ORDERED: 20 71 : Ga : Lata J C fs 4 l Lee Al 22 UNITED STATES DISTRICT JUDGE 23 November 16, 2020 DATED: 24 Te 25 26 27 28 IP, LLLC HUALALAI ROAD

From: [email protected] Sent: Monday, October 19, 2020 10:55 AM To: [email protected] Subject: Activity in Case 3:20-cv-03813-CRB Hurricane Electric LLC v. Dallas Buyers Club, LLC et al Telephone Conference This is an automatic e­mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e­mail because the mail box is unattended. ***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States policy permits attorneys of record and parties in a case (including pro se litigants) to receive one free electronic copy of all documents filed electronically, if receipt is required by law or directed by the filer. PACER access fees apply to all other users. To avoid later charges, download a copy of each document during this first viewing. However, if the referenced document is a transcript, the free copy and 30 page limit do not apply. U.S. District Court California Northern District Notice of Electronic Filing The following transaction was entered on 10/19/2020 at 10:54 AM and filed on 10/19/2020 Case Name: Hurricane Electric LLC v. Dallas Buyers Club, LLC et al Case Number: 3:20­cv­03813­CRB Filer: Document Number:43(No document attached) Docket Text: Minute Entry for proceedings held before Magistrate Judge Thomas S. Hixson: Telephone Conference held on 10/19/2020 at 10:30 a.m. FTR Time: Not Reported/Total Time in Court: 10:30-10:33- 3 minutes. Plaintiff Attorney: Neil Greenstein, Esq. Defendant Attorney: Kerry S. Culpepper, Esq. Proceedings: Telephone Conference Held by AT&T Conference. Counsel shall notify the Court when duty to defend is resolved in the related case. A further call will when then be scheduled to set a Settlement Conference date. If any questions please contact the Courtroom Deputy by email:[email protected] (This is a text-only entry generated by the court. There is no document associated with this entry.) (rmm2S, COURT STAFF) (Date Filed: 10/19/2020) John L. Roberts [email protected], [email protected] Kerry Steven Culpepper [email protected] Martin R. Greenstein [email protected], [email protected] Neil D. Greenstein [email protected], [email protected], [email protected], [email protected]

Tobi Carver Clinton [email protected], [email protected], [email protected], xgamertc­ [email protected] 3:20­cv­03813­CRB Please see Local Rule 5­5; Notice has NOT been electronically mailed to: 1 Kerry S. Culpepper, HI Bar No. 9837, pro hac vice Culpepper IP, LLLC 2 75-170 Hualalai Road, Suite B204 Kailua Kona, HI 96740 3 Tel: 808-464-4047 4 Fax: 202-204-5181 [email protected] 5 Tobi Clinton, (SBN 209554) 6 330 Vernon St., Unit 795 Roseville, CA 95678 7 Tel: 650-735-2137 8 Fax: 202-204-5181 [email protected] 9 Attorneys for Defendants: DALLAS BUYERS CLUB, LLC, a Texas LLC; DALLAS BUYERS 10 CLUB, LLC, a California LLC; GLACIER FILMS 1, LLC; DOUBLE LIFE PRODUCTIONS, INC.; VOLTAGE PICTURES, LLC; COOK PRODUCTIONS, LLC; WWE STUDIOS FINANCE 11 CORP.; MON, LLC; TBV PRODUCTIONS, LLC; CELL FILM HOLDINGS, LLC; VENICE PI, LLC; I AM WRATH PRODUCTION, INC.; POW NEVADA, LLC; HEADHUNTER, LLC; 12 NICOLAS CHARTIER; CRAIG FLORES; AVI LERNER; VOLTAGE PRODUCTIONS, INC.; and KILLING LINK DISTRIBUTION. 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 HURRICANE ELECTRIC LLC, Case No.: 3:20-CV-3813-CRB 17 Plaintiffs, 18 v. STIPULATION OF PLAINTIFF AND DEFENDANTS TO STAY ACTION 19 DALLAS BUYERS CLUB, LLC, et al. PENDING RULING ON CO-PENDING INSURANCE ACTION BY PLAINTIFF 20 Defendants. AGAINST ITS INSURER AND PROVIDE FOR LIMITED THIRD-PARTY 21 DISCOVERY; [PROPOSED] ORDER GRANTING STAY 22 23 Whereas, HURRICANE ELECTRIC, LLC (“Plaintiff”), through its counsel Neil D. 24 25 Greenstein, and DALLAS BUYERS CLUB, LLC, a Texas LLC, DALLAS BUYERS CLUB, 26 LLC, a California LLC; GLACIER FILMS 1, LLC; DOUBLE LIFE PRODUCTIONS, INC.; 27 VOLTAGE PICTURES, LLC; COOK PRODUCTIONS, LLC; WWE STUDIOS FINANCE 1 LLC; I AM WRATH PRODUCTION, INC.; POW NEVADA, LLC; HEADHUNTER, LLC; 2 NICOLAS CHARTIER; AVI LERNER; VOLTAGE PRODUCTIONS, INC.; CRAIG FLORES 3 and KILLING LINK DISTRIBUTION (“Defendants”), through their counsel Kerry S. Culpepper, 4 stipulate for an order staying this action, subject to the exceptions set forth below, pending resolution 5 of Plaintiff’s insurer’s duty to defend in the Co-Pending Insurance Action (defined below). Plaintiff 6 and the Defendants are referred to collectively as “Parties.” The Parties recognize that there is some 7 8 third-party data and documents that may not be regularly preserved and have agreed, 9 notwithstanding the stay, that certain third-party discovery, as explained below, may proceed during 10 the stay. Finally, the Parties have agreed that Defendants’ answers or other responses to the 11 complaint should be set a minimum of 60-days after the stay is lifted so that the parties can engage 12 in a settlement conference with Magistrate Judge Hixson after the ruling in the Co-Pending 13 Insurance Action. 14 15 Whereas, the Court endorsed the Parties’ First Stipulation to Extend Defendants’ Deadline 16 to Answer and/or Respond to Complaint [Doc. #28]. The First Stipulation granted Defendants up 17 until October 2, 2020 to respond to the Complaint. 18 Whereas, the Court endorsed the Parties’ Second Stipulation to Extend Defendants’ 19 Deadline to Answer and/or Respond to Complaint [Doc. #41]. The Second Stipulation granted 20 Defendants up until November 2, 2020 to respond to the Complaint. 21 Whereas, Plaintiff has filed a lawsuit against its insurer National Fire Insurance Company 22 of Hartford, Inc. (“NFI”) in this District in the case entitled Hurricane Electric, LLC vs. National 23 Fire Insurance Company of Hartford, 3:20-cv-05840-CRB (the “Co-Pending Insurance Action”). 24 This Court has ordered that the Co-Pending Insurance Action and the present case be treated as 25 related cases [Doc. #36]. 26 Whereas, the Court referred this present case to Magistrate Judge Hixson for conducting an 27 early Settlement Conference per the Parties’ request [Doc. #29]; however, the Parties have concluded that an early Settlement Conference would not be fruitful until after the dispute over the 1 insurer’s duty to defend between Plaintiff and NFI in the Co-Pending Insurance Action has been 2 resolved or at least substantial progress has been made toward a resolution. 3 Whereas, on October 9, 2020, in the Co-Pending Insurance Action Plaintiff filed a Motion 4 For Partial Summary Judgment On National Fire’s Duty To Defend Hurricane Electric in the Instant 5 Action. 6 Whereas the Parties have agreed that all parties in this Action shall reserve all rights and that 7 this requested stay, and the slight delay in this Action, shall not be construed in any manner for or 8 against any party on any issue, whether substantive or procedural. 9 Whereas, the Parties believe that there will be no “possible damage which may result from 10 the granting of a stay” or “hardship or inequity which a party may suffer” since the Parties have also 11 agreed that Parties will be allowed to conduct limited third party discovery. Lockyer v. Mirant 12 Corp.,

(9th Cir. 2005) (quoting CMAX, Inc. v. Hall,

(9th 13 Cir. 1962)). Moreover, consideration of “the orderly course of justice measured in terms of the 14 simplifying or complicating issues” supports granting a stay since a stay will eliminate distraction 15 of anticipated motion practice between the parties until after the dispute between Plaintiff and NFI 16 in the Co-Pending Insurance Action has been resolved or at least substantial progress has been made, 17 thereby simplifying the issues.

18 Accordingly, the Parties agree that all deadlines in this matter including the Case 19 Management Conference, any direct formal discovery between the Parties and the early settlement 20 conference be STAYED. The Parties intend to resume the settlement conference proceedings with 21 Magistrate Judge Hixson after said Co-Pending Insurance Action has been resolved. 22 Whereas, the Defendants request that the Court issue an Order granting leave to conduct 23 limited early third-party discovery prior to the Rule 26(f) Conference as follows: 24 (a) Internet Service Providers (“ISP”) only maintain internal logs of subscriber information 25 for a brief period of time. See Digital Sin, Inc. v. Does 1-176,

(S.D.N.Y. 2012) 26 (“[E]xpedited discovery is necessary to prevent the requested data from being lost forever as part of 27 routine deletions by the ISPs.”). Accordingly, Defendants request that the Court issue an Order 1 Procedure on: 2 (1) ISPs that are customers/affiliates of Plaintiff, identified in attached Exhibit “1,” where 3 Defendants’ motion pictures were allegedly infringed, but only to request subscriber identification 4 information of Internet Protocol (“IP”) addresses; and 5 (2) email providers such as Google, Microsoft and Yahoo solely to request identification 6 and IP address log records for email addresses that were used to log into the YTS website which 7 Defendants claim were allegedly used to download, through Plaintiff’s customers, torrent files of 8 Defendants’ motion pictures as identified in Exhibit “1”. 9 (b) There has been extensive litigation, depositions and documents of the defendants in other 10 copyright enforcement action involving the same copyrights and such deposition transcripts and 11 documents may be in the possession of third parties, who are not presently under a retention 12 obligation. In order to avoid the loss of such valuable and likely probative information, the Parties 13 stipulate and agree, and request leave of Court, so that Plaintiff may issue FRCP 45 subpoenas to 14 third-parties for copies of deposition transcripts and other documents from prior cases. 15 This stipulation and order is solely an authorization to issue third-party subpoenas as 16 described above, and nothing herein shall be deemed an approval as to the substance of any 17 subpoena. All Parties and third-parties retain all rights to seek to quash, modify, and/or otherwise 18 object to such subpoenas in the appropriate court. 19 On August 19, 2020, Plaintiff filed an amended complaint. A question has arisen as to 20 whether such amended complaint was timely and appropriately filed on that date. Defendants 21 hereby consent to the August 19, 2020 filing of Plaintiff’s Amended Complaint. 22 / / /

23 / / /

24 / / / 25 26 27 The Parties stipulate to the Court granting the above requested Orders. 2 The Parties shall file a status report with the Court by January 4, 2021, or if sooner, 3 || promptly after disposition of the obligation of the insurer to defend this action in the Co-Pending Insurance Action. 5 | DATED Kailua-Kona, Hawaii, October 17, 2020. 6 Respectfully submitted, 7 CULPEPPER IP, LLLC 9 /s/ Kerry S. Culpepper Kerry S. Culpepper 10 Attorney for Certain Defendants Il | IIS SO STIPULATED. 12 B Respectfully, 14 NEIL D. GREENSTEIN MARTIN R. GREENSTEIN 15 JOHN L. ROBERTS TECHMARK Dated: October 17 2020 By: Vier g Gh, sii i Ls Sa 7 Neil D. Greenstein Attorneys for Plaintiff 18 19 ORDER 20 (LR. 7-12] PURSUANT TO STIPULATION, IT IS SO ORDERED. 22 23 Date: October 19, 2020 co i — 24 Charles R. Breyer United States District Judge 25 26 27 28 IP, LLLC

KAILUA-KONA,

Exhibit "1" [No| emailaddress | DateuTC | |[email protected] —|65.49.126.194 | 6/11/2019 18:36:00 _| | |[email protected] | 65.49.126.194 6/11/2019 18:36:00 _| | |[email protected] 65.49.126.194 7/14/2019 11:35:00 □□ | |[email protected] 65.49.126.194 8/11/2019 13:21:00 _| | |[email protected] |65.49.126.194 | 11/15/2019 5:09:00 _| | |[email protected] 65.49.126.194 | 12/3/2019 15:31:00 _| | |[email protected] |65.49.126.194 12/19/2019 6:00:00 _| | |[email protected] | 65.49.126.194 | 12/28/2019 6:09:00 _| | |[email protected] 65.49.126.194 (5/18/2019 2:26:00 __| | __|[email protected] | 74.82.60.96 4/3/2019 6:33:32 |__|[email protected] |74.82.60.96 | 6/16/2019 18:16:54 | | |[email protected] | 65.49.126.173 | 12/3/2019 11:38:47 _| | |[email protected] | 65.49.126.173 | 12/28/2019 13:55:20 □□ | |[email protected] | 65.49.126.173 12/30/2019 7:07:13 | | |[email protected] | 65.49.126.173 2/10/2020 18:47:36 _| |[email protected] | 65.49.126.173 | 2/21/2020 1:07:27 | 4|[email protected] | 74.82.60.87_ 3/4/2019 19:14:17 □□□□□□□□□□□□□□□□□□□□□□□□□ | 74.82.6087 12/10/2019 14:31:10 _| | □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ |74.82.60.196 7/14/2019 1:28:15 | | □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ |74.82.60.196 | 7/29/2019 6:38:00__| | □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ |74.82.60.196 | 11/19/2019 2:51:28 | | 6|[email protected] | 74.82.60.191_|2/10/20200:50:18 | |[email protected] | 74.82.60.191_ | 7/14/20190:47:50__| | __|[email protected] | 74.82.60.191_ | 12/3/2019 12:24:15 | |[email protected] | 74.82.60.191_ 1/11/2020 21:50:11 | |nishilmehra@gmailcom (| 72.52.87.189 | 11/25/2019 18:02:13 | |nishilmehra@gmailcom | 72.52.87.189 | 12/10/2019 16:19:56 _| |nishilmehra@gmailcom “7252.87.89 *|1/1/20202:10:08 | |nishilmehra@gmailcom | 72.52.87.189 5/16/2019 14:00:18 | | 8|[email protected] «74.82.6096 | 2019-07-15 12:54:54 | | |rp8260@gmailcom «7482.60.96 | 4/8/20196:33:00 |[email protected] «74.82.6096 | 6/16/2019 18:16:00 _| | 9[[email protected] | 65.49.38.140 7/21/2019 15:59:50 _| | |[email protected] | 72.52.87.98 7/18/2019 8:13:00 | | |[email protected] (7252.87.98 8/4/2019 23:10:00 | |[email protected] | 72.52.87.98 | 11/23/2019 17:08:00 _| | |[email protected] 72.52.8798 2/12/2020 21:22:00 _| |[email protected] | 72.52.8798 |8/27/20200:41:28 | |[email protected] (| 72.52.87.97 *d1/25/2019.4:14:46 |

[email protected] 72.52.87.97 7/21/2019 20:57:06 [email protected] 72.52.87.97 8/3/2019 14:13:55 [email protected] 72.52.87.97 12/2/2019 1:50:43 [email protected] 72.52.87.97 12/4/2019 9:31:56 [email protected] 72.52.87.97 2/23/2020 19:40:45 12 [email protected] 65.49.113.50 11/26/2019 6:40:25 13 [email protected] 74.82.60.172 11/25/2019 4:43:23 [email protected] 74.82.60.172 7/9/2019 15:28:15 [email protected] 74.82.60.172 7/13/2019 18:14:15 [email protected] 74.82.60.172 10/14/2019 8:20:15 [email protected] 74.82.60.172 11/22/2019 17:54:09 14 [email protected] 65.49.126.92 1/18/2019 6:03:54 [email protected] 65.49.126.92 5/13/2019 6:57:06 [email protected] 65.49.126.92 7/14/2019 2:00:28 [email protected] 65.49.126.92 7/20/2019 4:34:31 [email protected] 65.49.126.92 10/22/2019 8:48:28 15 [email protected] 74.82.63.195 2/22/2019 11:10:22 16 [email protected] 5.152.182.191 5/29/2019 15:27:26 17 [email protected] 74.82.63.196 5/9/2019 10:52:18 18 [email protected] 74.82.60.192 6/5/2019 13:58:43 [email protected] 74.82.60.192 5/10/2019 6:54:10 [email protected] 74.82.60.192 12/7/2019 14:44:02 [email protected] 74.82.60.192 12/19/2019 2:47:48 [email protected] 74.82.60.192 2/8/2020 15:22:37 [email protected] 74.82.60.192 2/13/2020 16:10:13 [email protected] 74.82.60.192 11/21/2019 22:01:29 19 [email protected] 65.49.38.141 10/5/2019 7:36:54 20 [email protected] 72.52.87.80 1/25/2020 18:51:18 [email protected] 72.52.87.80 4/13/2019 7:35:19 [email protected] 72.52.87.80 6/11/2019 18:12:58 [email protected] 72.52.87.80 11/15/2019 9:34:09 [email protected] 72.52.87.80 12/4/2019 14:19:04 [email protected] 72.52.87.80 7/15/2019 7:57:41 21 [email protected] 64.62.219.31 1/22/2020 21:36:46 22 [email protected] 65.49.126.187 1/22/2020 21:57:07 [email protected] 65.49.126.187 5/17/2019 7:38:46 [email protected] 65.49.126.187 8/25/2019 23:00:39 [email protected] 65.49.126.187 10/20/2019 7:30:45 [email protected] 65.49.126.187 12/10/2019 14:57:04 23 [email protected] 74.82.60.193 3/19/2020 5:56:05 [email protected] 74.82.60.193 12/2/2019 10:04:49 [email protected] 74.82.60.193 12/27/2019 1:21:12 [email protected] 74.82.60.193 12/30/2019 22:03:09 24 [email protected] 72.52.87.191 10/11/2019 18:17:26 [email protected] 72.52.87.191 5/19/2019 13:39:27 [email protected] 72.52.87.191 11/17/2019 7:12:19 [email protected] 72.52.87.191 12/28/2019 4:34:33 [email protected] 72.52.87.191 2/6/2020 9:59:59 [email protected] 72.52.87.191 3/26/2020 16:57:58 25 [email protected] 65.49.126.190 8/25/2019 15:34:56 [email protected] 65.49.126.190 7/14/2019 0:36:13 [email protected] 65.49.126.190 10/21/2019 12:01:14 [email protected] 65.49.126.190 1/16/2020 6:20:37 [email protected] 65.49.126.190 1/29/2020 2:28:41 [email protected] 65.49.126.190 2/4/2020 7:47:46 [email protected] 65.49.126.190 8/29/2019 1:37:06 [email protected] 65.49.126.190 10/9/2019 17:08:49 26 [email protected] 184.104.204.2 10/25/2019 15:51:17 27 [email protected] 77.111.246.214 11/30/2019 1:26:15 Exhibit "1" [No] emailaddress ISP Hurricane Electric / Sophidea | |[[email protected] ——_— [Hurricane Electric / Sophidea | |[email protected] = —~—__—| Hurricane Electric / Sophidea | |[[email protected] ——_— [Hurricane Electric / Sophidea | |[email protected] = —~—__—| Hurricane Electric / Sophidea | |[[email protected] ——_— [Hurricane Electric / Sophidea | |[email protected] = —~—__—| Hurricane Electric / Sophidea | |[[email protected] ——_— [Hurricane Electric / Sophidea | |[email protected] = —~—__—| Hurricane Electric / Sophidea | |[[email protected] ——_— [Hurricane Electric / Sophidea Hurricane Electric / Sophidea | |[email protected] [Hurricane Electric / Sophidea |[email protected] ——__—| Hurricane Electric / Sophidea Hurricane Electric / Sophidea | □□□□□□□□□□□□□□□□□□□□□ ==~~—~—_—«s Hurricane Electric / Sophidea | [[email protected] ==~—~—_— [Hurricane Electric / Sophidea | □□□□□□□□□□□□□□□□□□□□□ ==~~—~—_—«s Hurricane Electric / Sophidea | [[email protected] ==~—~—_— [Hurricane Electric / Sophidea | □□□□□□□□□□□□□□□□□□□□□ ==~~—~—_—«s Hurricane Electric / Sophidea | 4{[email protected] [Hurricane Electric / Sophidea | |[email protected] ——__—s Hurricane Electric / Sophidea Hurricane Electric / Sophidea | [email protected] _| Hurricane Electric / Sophidea | [email protected] _| Hurricane Electric / Sophidea | —[email protected] _| Hurricane Electric / Sophidea | 6|[email protected] ——_—| Hurricane Electric / Sophidea [[email protected] □□ [Hurricane Electric / Sophidea | |[email protected] —_—| Hurricane Electric / Sophidea [[email protected] □□ [Hurricane Electric / Sophidea Hurricane Electric / Sophidea | [[email protected] = —~—__ [Hurricane Electric / Sophidea | |[email protected] = —~—_—s| Hurricane Electric / Sophidea | [[email protected] = —~—__ [Hurricane Electric / Sophidea | |[email protected] = —~—_—s| Hurricane Electric / Sophidea 8[[email protected] = ~=~—~—~—~—__ [Hurricane Electric / Sophidea | |[email protected] === ~=~——~—~—__—| Hurricane Electric / 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[email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 12 [email protected] Hurricane Electric / N.A. 13 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 14 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 15 [email protected] Hurricane Electric / SafeChat Inc 16 [email protected] Hurricane Electric / ElasticHosts Ltd 17 [email protected] Hurricane Electric / SafeChat Inc 18 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 19 [email protected] Hurricane Electric / Dynaweb Foundation 20 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 21 [email protected] Hurricane Electric / Sophidea 22 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 23 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 24 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 25 [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea [email protected] Hurricane Electric / Sophidea 26 [email protected] Hurricane Electric / Triton Digital Inc (fka Ando Media Group LLC) 27 [email protected] Opera Mini Proxy 1

2 UNITED STATES DISTRICT COURT

3 NORTHERN DISTRICT OF CALIFORNIA

4 HURRICANE ELECTRIC LLC, Case No.: 3:20-CV-3813-CRB 5 Plaintiffs,

6 v. ATTESTATION

7 DALLAS BUYERS CLUB, LLC, et al.

8 Defendants. 9

10 ATTESTATION 11 Pursuant to LR 5-1(i)(3), I attest that concurrence in the filing of this document has been 12 obtained from each of the other signatories who are listed on the signature. I have filed a scanned 13 image of the signature page, signed by the parties, of the document being electronically filed, in 14 lieu of maintaining the paper record for subsequent production if required. 15 DATED Kailua-Kona, Hawaii, October 18, 2020. 16

Respectfully submitted, 17

18 CULPEPPER IP, LLLC

19 /s/ Kerry S. Culpepper Kerry S. Culpepper 20 Attorney for Defendants

21

22 23 24 25 26 27