Case 3:25-cv-07067-JSC Document 56 Filed 09/08/26 Page 1 of 5 1 GIBSON, DUNN & CRUTCHER LLP Jessica Valenzuela, Bar No. 220934 2 jvalenzuela@gibsondunn.com Jeff Lombard, Bar No. 285371 3 jlombard@gibsondunn.com 310 University Avenue 4 Palo Alto, California 94301-1744 Telephone: 650.849.5300 5 Facsimile: 650.849.5333 6 GIBSON, DUNN & CRUTCHER LLP Jordan Estes (pro hac vice) 7 jestes@gibsondunn.com 200 Park Avenue 8 New York, NY 10166-0193 Telephone: 212.351.4000 9 Facsimile: 212.351.4035 10 Attorneys for PubMatic, Inc., Rajeev K. Goel, and Steven Pantelick 11 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 SIDNEY HSU, Individually and on Behalf of Case No. 3:25-cv-07067-JSC 15 All Others Similarly Situated, STIPULATED REQUEST AND 16 Plaintiff, [PROPOSED] ORDER SETTING BRIEFING SCHEDULE ON 17 v. DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND 18 PUBMATIC, INC., RAJEEV K. GOEL, and AMENDED COMPLAINT STEVEN PANTELICK, 19 Judge: Hon. Jacqueline Scott Corley Defendants. Date Action Filed: August 20, 2025 20 21 22 23 24 25 26 27 28 1 GIBSON, DUNN & CRUTCHER LLP STIPULATED REQUEST AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE ATTORNEYS AT LAW ON DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND AMENDED COMPLAINT CASE NO. 3:25-CV-07067-JSC Case 3:25-cv-07067-JSC Document 56 Filed 09/08/26 Page 2 of 5 1 Pursuant to Rules 6-2 and 7-12 of the Northern District of California Civil Local 2 Rules, Plaintiff Sidney Hsu (“Plaintiff”) and Defendants PubMatic, Inc. (“PubMatic”), 3 Rajeev K. Goel, and Steven Pantelick (“Defendants,” and together with Plaintiff, the 4 “Parties”), hereby agree and stipulate that good cause exists to request an order from the 5 Court setting the schedule for Defendants’ response to the Second Amended Complaint 6 (defined below) and for briefing on Defendants’ anticipated motion to dismiss. 7 WHEREAS, on August 20, 2025, Plaintiff filed a putative class action complaint 8 against Defendants for alleged violations of Sections 10(b) and 20(a) of the Securities 9 Exchange Act of 1934 and Rule 10b-5 promulgated thereunder (the “Complaint”); 10 WHEREAS, this action is governed by the Private Securities Litigation Reform Act 11 of 1995 (the “PSLRA”), which imposes an automatic stay of discovery during the pendency 12 of a motion to dismiss (15 U.S.C. § 78u-4(b)(3)(B)); 13 WHEREAS, on October 25, 2025, the Court appointed Sidney Hsu as Lead Plaintiff 14 and Glancy Prongay & Murray (now known as Glancy Prongay Wolke & Rotter LLP) as 15 Lead Counsel pursuant to 15 U.S.C. § 78u-4(a)(3)(B) (Dkt. 31); 16 WHEREAS, on February 9, 2026, Plaintiff filed the Amended Class Action 17 Complaint (Dkt. 38) (the “First Amended Complaint”); 18 WHEREAS, on April 10, 2026, Defendants moved to dismiss the First Amended 19 Complaint (Dkt. 39); 20 WHEREAS, on July 27, 2026, the Court granted Defendants’ motion to dismiss the 21 First Amended Complaint with leave to amend and ordered Plaintiff to file any further 22 amended complaint (the “Second Amended Complaint”) by September 4, 2026 (Dkt. 48); 23 WHEREAS, the Parties believe that, given the requirements of the PSLRA and in 24 order to conserve the Court’s and the Parties’ resources, good cause exists to set the 25 schedule below, which affords Defendants a reasonable opportunity to evaluate and respond 26 27 2 28 STIPULATED REQUEST AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE GIBSON, DUNN & ON DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND AMENDED CRUTCHER LLP COMPLAINT CASE NO. 3:25-CV-07067-JSC Case 3:25-cv-07067-JSC Document 56 Filed 09/08/26 Page 3 of 5 1 to the Second Amended Complaint and affords Plaintiff a comparable period in which to 2 oppose any motion to dismiss. 3 WHEREAS, the previous time modifications in this action are: (1) the Court’s 4 October 15, 2025 Order (Dkt. 14) extending Defendants’ time to respond to the Complaint 5 and vacating the Initial Case Management Conference, all associated deadlines, and the 6 ADR deadlines; and (2) the Court’s December 11, 2025 Order (Dkt. 35) setting the schedule 7 for filing of the First Amended Complaint and responsive briefing; 8 WHEREAS, the Parties do not seek to reset these dates for the purpose of delay, 9 and the proposed new dates will not have an effect on any additional pre-trial and trial dates 10 as the Court has yet to schedule these dates. 11 NOW, THEREFORE, the Parties, subject to approval of the Court, hereby stipulate 12 and agree as follows: 13 1. Defendants shall answer, move to dismiss, or otherwise respond to the Second 14 Amended Complaint on or before October 20, 2026. 15 2. Plaintiff shall file any opposition to Defendants’ motion to dismiss on or before 16 December 4, 2026. 17 3. Defendants shall file any reply in support of their motion to dismiss on or before 18 January 19, 2027. 19 4. Nothing in this stipulation shall be construed as a waiver of any of the Parties’ 20 rights or positions in law or equity, or as a waiver of any claims or defenses that the Parties 21 otherwise would have. 22 IT IS SO STIPULATED. 23 24 25 26 27 3 28 STIPULATED REQUEST AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE GIBSON, DUNN & ON DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND AMENDED CRUTCHER LLP COMPLAINT ATTORNEYS AT LAW CASE NO. 3:25-CV-07067-JSC Case 3:25-cv-07067-JSC Document 56 Filed 09/08/26 Page 4 of 5 1 Respectfully submitted, 2 Dated: September 8, 2026 GIBSON, DUNN & CRUTCHER LLP 3 By: /s/ Jessica Valenzuela Jessica Valenzuela 4 Attorney for Defendant PubMatic, Inc., Rajeev 5 K. Goel, and Steven Pantelick 6 Dated: September 8, 2026 GLANCY PRONGAY WOLKE & ROTTER LLP 7 By: /s/ Ex Kano S. Sams II Ex Kano S. Sams II 8 Attorney for Plaintiff Sidney Hsu 9 10 * * * 11 ECF ATTESTATION 12 Pursuant to Civil Local Rule 5-1(i)(3), I attest that the concurrence in the filing of this 13 document has been obtained from all other signatories. 14 Dated: September 8, 2026 15 /s/ Jessica Valenzuela 16 Jessica Valenzuela 17 18 19 20 21 22 23 24 25 26 27 4 28 STIPULATED REQUEST AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE GIBSON, DUNN & ON DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND AMENDED CRUTCHER LLP COMPLAINT ATTORNEYS AT LAW CASE NO. 3:25-CV-07067-JSC Case 3:25-cv-07067-JSC Document 56 Filed 09/08/26 Page 5 of 5 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, IT IS SO ORDERED. 3 Dated: ______________, 2026 4 5 Hon. Jacqueline Scott Corley United States District Judge 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 5 28 STIPULATED REQUEST AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE GIBSON, DUNN & ON DEFENDANTS’ ANTICIPATED MOTION TO DISMISS THE SECOND AMENDED CRUTCHER LLP COMPLAINT ATTORNEYS AT LAW CASE NO. 3:25-CV-07067-JSC