18 August 1997
Source: Hard copy from John Gilmore

See PGP answers to RSA: http://jya.com/rsavpgp2.htm

See RSA v. PGP suit: http://jya.com/rsavpgp.txt

See Lemcom License Exhibit A: http://jya.com/pkplem.htm

    [Computer printed form]

    SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN MATEO

    CASE NO. 400585
    DATE 16 JUN 1997

    TITLE OF ACTION: RSA DATA SECURITY, INC., VS. PRETTY GOOD PRIVACY, INC.

    NATURE OF EVENTS: 01,DEFT PRETTY GOOD PRIVACY DEMURRER TO COMPLAINT (6-13)
                      02,DEFT PRETTY GOOD PRIVACY MOTION TO COMPEL ARBITRATION (6-13)

    X OFF CALENDAR [Unused portions of form omitted]

    X [By hand] DROPPED PW STIP/ORDER Sgd bu Judge [Illegible]

    [Unused balance of form omitted]

    [1]
                                                      FILED
                                                      SAN MATEO COUNTY
                                                      JUN -4 1997
                                                      Clerk of the Superior Court
                                                      By [Illegible signature]
                                                      DEPUTY CLERK

    MICHAEL BARCLAY, State Bar No. 088993
    NINA F. LOCKER, State Bar No. 123838
    RODNEY G. STRICKLAND, JR., State Bar No. 161934
    AHMED E. TAHA, State Bar No. 184540
    WILSON SONSINI GOODRICH & ROSATI
    Professional Corporation
    650 Page Mill Road
    Palo Alto, California 94304-1050
    Telephone: (415)493-9300

    Attorneys for Defendant
    PRETTY GOOD PRIVACY, INC.

                          SUPERIOR COURT OF CALIFORNIA

                               COUNTY OF SAN MATEO

    RSA DATA SECURITY, INC., a Delaware       )  CASE NO.: 400585
    corporation                               )
                                              )  STIPULATION AND            14.-
           Plaintiff,                         )  [PROPOSED] ORDER
                                              )  CONTINUING HEARING ON
           v.                                 )  PGP'S MOTION TO COMPEL
                                              )  ARBITRATION AND
    PRETTY GOOD PRIVACY, INC., a              )  DEMURRER TO
    Delaware corporation, and DOES 1 through  )  COMPLAINT
    25, inclusive,                            )
                                              )
           Defendants.                        )
                                              )
                                              )
    __________________________________________)

                                                                          400585
                                                             06-04-1997/02:45 PM
                                                                 $14.00/03-52683

         WHEREAS, on May 6, 1997, RSA Data Security, Inc. ("RSA") filed a
    Complaint against Pretty Good Privacy, Inc. ("PGP").

         WHEREAS, RSA's Complaint alleges that it terminated a patent license
    agreement ("License Agreement") between PGP and Public Key Partners, a
    partnership between RSA and Caro-Kann Corporation, a wholly-owned subsidiary
    of Cylink Corporation, on account of PGP's alleged breach of the agreement.

        WHEREAS, after RSA filed this lawsuit, its partner, Cylink/Caro-Kann,
    disputed whether RSA had the authority to terminate PGP's License Agreement
    and suggested that RSA's only remedy for PGP's alleged breach was to demand
    arbitration.

        WHEREAS, on May 22, 1997, PGP filed a Motion to Compel Arbitration and
    Demurrer to Complaint.

        WHEREAS, PGP's motion was originally set for hearing on June 13, 1997,
    but was continued until June 16, 1997 in order to accommodate scheduling
    confiicts on the part of counsel.

        WHEREAS, on May 29, 1997, RSA requested that PGP agree to a continuance
    of the hearing date on PGP's Motion to Compel Arbitration and Demurrer to
    Complaint until after RSA and Caro-Kann arbitrate their dispute regarding
    RSA's authority to terminate PGP's License Agreement.

        WHEREAS, the arbitration between RSA and Caro-Kann is currently scheduled
    to commence on June 18, 1997.

        WHEREAS, in order to avoid unnecessary motion practice, PGP has agreed to
    RSA's request for a continuance.

        THEREFORE, plaintiff and defendant stipulate, by and through their counsel
    of record, and subject to approval by the Court, to the following:

        1) Defendant's Motion to Compel Arbitration and Demurrer to Complaint,
    currently calendared for June 16, 1997, shall be taken offcalendar without
    prejudice;

        2) Defendant shall renew its Motion to Compel Arbitration and Demurrer to
    Complaint, or otherwise respond to the Complaint, after a decision is rendered
    in the arbitration between RSA and Caro-Kann, at which time the parties shall
    agree on a briefing and hearing schedule;

        3) Nothing in this Stipulation and Proposed Order shall prejudice
    defendant's right to argue that the arbitration between RSA and Caro-Kann has
    no bearing on the outcome of PGP's Motion to Compel Arbitration and Demurrer
    to Complaint;

        4) No responsive pleading shall be due from defendant until the filing of
    its renewed Motion to Compel Arbitration and Demurrer to Complaint;

        5) Neither party shall initiate any discovery pursuant to the California
    Code of Civil Procedure until a decision on defendant's renewed motion has
    been rendered by the Court.

    STIPULATED AND AGREED TO:

    Date: June 3, 1997                WILSON, SONSINI, GOODRICH & ROSATI
                                      Professional Corporation

                                      By: [Signature] /ESG
                                          Nina F. Locker

                                      Attorneys for defendant
                                      PRETTY GOOD PRIVACY, INC.

    Date: 6/3/97                      TOMLINSON ZISKO MOROSOLI & MASER

                                      By: [Signature]
                                          Thomas E. Moore III

                                      Attorneys for Plaintiff
                                      RSA DATA SECURITY, INC.

    IT IS SO ORDERED:
    DATE:   JUN -4 1997               [Illegible Signature]
                                      Superior Court Judge

                                                   ESG::ODMA\PCDOCS\SQLI\150894\1

    [End document]