Rimini Street, Inc. v. Oracle International Corporation

Opinion

BOIES, SCHILLER FLEXNER LLP GIBSON, DUNN & CRUTCHER LLP RICHARD J. POCKER (NV Bar No. 3568) SAMUEL LIVERSIDGE (pro hac vice) 300 South Fourth Street, Suite 800 ERIC D. VANDEVELDE (pro hac vice) Las Vegas, NV 89101 ILISSA S. SAMPLIN (pro hac vice) Telephone: 702.382.7300 333 South Grand Avenue Facsimile: 702.382.2755 Los Angeles, CA 90071-3197 rpocker@bsfllp.com Telephone: 213.229.7000 sliversidge@gibsondunn.com DUNN ISAACSON RHEE LLP evandevelde@gibsondunn.com WILLIAM A. ISAACSON (pro hac vice) isamplin@gibsondunn.com KAREN DUNN (pro hac vice) JESSICA PHILLIPS (pro hac vice) GIBSON, DUNN & CRUTCHER LLP 401 9th Street, NW BLAINE H. EVANSON (pro hac vice) Washington, DC 20004 CASEY J. MCCRACKEN (pro hac vice) Telephone: 202.240.2900 JOSEPH A. GORMAN (pro hac vice) wisaacson@dirllp.com 3161 Michelson Drive kdunn@dirllp.com Irvine, CA 92612-4412 jphillips@dirllp.com Telephone: 949.451.3800 jtthomas@gibsondunn.com MORGAN, LEWIS & BOCKIUS LLP bevanson@gibsondunn.com BENJAMIN P. SMITH (pro hac vice) cmccracken@gibsondunn.com One Market, Spear Street Tower jgorman@gibsondunn.com San Francisco, CA 94105 Telephone: 415.442.1000 HOWARD & HOWARD ATTORNEYS PLLC Facsimile: 415.442.1001 W.WEST ALLEN (Nevada Bar No. 5566) benjamin.smith@morganlewis.com 3800 Howard Hughes Parkway, Suite 1000 sharon.smith@morganlewis.com Las Vegas, NV 89169 Telephone: 702.667.4843 JAMES C. MAROULIS (pro hac vice) wwa@h2law.com ORACLE CORPORATION 500 Oracle Parkway, M/S 5op7 RIMINI STREET, INC. Redwood City, CA 94070 JOHN P. REILLY (pro hac vice) Telephone: 650.506.4846 1700 S. Pavilion Center Drive, Suite 330 Facsimile: 650.506.7114 Las Vegas, NV 89135 dorian.daley@oracle.com Telephone: 336.908.6961 jim.maroulis@oracle.com jreilly@riministreet.com Attorneys for Plaintiffs Oracle International WEIL, GOTSHAL & MANGES LLP Corporation and Oracle America, Inc. MARK A. PERRY (pro hac vice) 2001 M Street, N.W., Suite 600 Washington, DC 20036 Telephone: 202.682.7511 mark.perry@weil.com Attorneys for Defendants Rimini Street, Inc., and Seth Ravin ORACLE INTERNATIONAL CORP., and CASE NO. 2:14-cv-01699-MMD-DJA ORACLE AMERICA, INC., ORDER GRANTING JOINT Plaintiffs, STIPULATION TO STAY ALL PROCEEDINGS PENDING v. SETTLEMENT RESOLUTION AND TO VACATE THE SCHEDULING ORDER RIMINI STREET, INC., and SETH RAVIN, Judge: Hon. Miranda M. Du Defendants. JOINT STIPULATION TO STAY PROCEEDINGS AND Plaintiffs Oracle International Corp. and Oracle America, Inc. (“Oracle”) and Defendants Rimini Street, Inc. and Seth Ravin (collectively, “Rimini,” and with Oracle, the “Parties”) executed a settlement agreement with an effective date of July 7, 2025 (“Settlement Agreement”) to resolve the entirety of this case pending Rimini’s wind down of its offering of support services for Oracle’s PeopleSoft software product, and therefore, by and through their respective counsel of record, respectfully request that this Court (1) stay all proceedings in this case and (2) vacate all current deadlines and hearing dates set forth in the existing Scheduling Order (ECF No. 1637) to allow the Parties to perform under and effectuate the Settlement Agreement. 1. WHEREAS, on July 31, 2024, Rimini unilaterally announced its decision to wind down its offering of support services for Oracle’s PeopleSoft software product; 2. WHEREAS, following remand from the Ninth Circuit in March 2025, the only product line at issue in the pending remand proceedings is PeopleSoft; 3. WHEREAS, on June 26, 2025, the Parties conducted a successful in-person mediation; 4. WHEREAS, the parties seek to avoid the time and expense of further litigation concerning alleged copyright infringement of a software product Rimini has represented it will no longer support; 5. WHEREAS, the Parties’ full performance under the Parties’ Settlement Agreement will fully resolve the entirety of this litigation, including all issues remanded by the Ninth Circuit, as well as any dispute regarding attorneys’ fees, although the Parties agree that this Court will retain jurisdiction to enforce, as necessary, the permanent injunction entered in the Rimini I action (Rimini I ECF No. 1166; Oracle USA, Inc. v. Rimini St. Inc., 783 F. App’x 707, 710-711 (9th Cir. 2019)), as well as the Modified Permanent Injunction entered in this action (ECF No. 1635); 6. WHEREAS, under the Settlement Agreement, Rimini will complete its previously announced wind down of support services related to PeopleSoft by no later than July 31, 2028; 7. WHEREAS, following Rimini’s successful completion of the wind down as described in the Settlement Agreement, and Rimini’s notice to Oracle of such completion in compliance with the terms of the Settlement Agreement (including a declaration under penalty of perjury that Rimini has in fact completed its wind down), Oracle has agreed to dismiss this case with prejudice; 8. WHEREAS, the Parties agree that a stay of all proceedings during the wind down period serves the interests of judicial economy by vacating all existing deadlines provided in this Court’s Scheduling Order (ECF No. 1637) such that the Court will be substantially relieved of any further administration of this case; 9. WHEREAS, in the unlikely event of an unexpected material breach of the Settlement Agreement during the wind down, the Parties jointly agree that it would be more efficient to lift the stay and resume the proceedings in this matter rather than requiring the non- breaching Party to commence new litigation; 10. WHEREAS, the Court may “stay[] the case while retaining jurisdiction over possible disputes concerning compliance with a settlement agreement” under Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 381–82 (1994) and its inherent authority to control Mass. 2012) (granting three-year stay to allow the parties to perform under a settlement agreement); 11. WHEREAS, a stay of proceedings will not harm the Parties, will avoid the additional hardship of continuing to actively litigate this decade-long dispute, will allow the parties to focus exclusively on satisfying the terms of the Settlement Agreement, and will promote judicial economy, see Epstein v. US Foods, Inc., 2025 WL 330544, at *1 (W.D. Wash. Jan. 29, 2025) (describing factors courts consider in evaluating a request for a stay and granting joint stipulation to stay “to allow the mediation process to play out”); In re W. States Wholesale Nat. Gas Antitrust Litig., 2019 WL 2098350 (D. Nev. Apr. 5, 2019) (staying all proceedings “until further order of the Court, except such proceedings as may be necessary either to implement the Settlements or to comply with or effectuate the terms of the Agreements or Fed. R. Civ. P. 23”); 12. THEREFORE, the Parties stipulate and agree that all proceedings in this matter should be stayed for the duration of the three-year wind down period required to effectuate the Parties’ agreement to settle the above-captioned matter, and that all deadlines set forth in the Scheduling Order (ECF No. 1637) should be vacated. Dated: July 17, 2025 GIBSON, DUNN & CRUTCHER LLP MORGAN, LEWIS & BOCKIUS LLP By: /s/ Eric D. Vandevelde By: /s/ Benjamin P. Smith Eric D. Vandevelde Benjamin P. Smith Attorneys for Defendants Rimini Street, Inc., Attorneys for Plaintiffs Oracle and Seth Ravin International Corporation and Oracle America, Inc. Pursuant to the Parties’ joint stipulation, and for good cause shown, IT IS ORDERED that all deadlines set forth in the Scheduling Order (ECF No. 1637) are VACATED and all proceedings in this case are STAYED until the earlier of July 31, 2028, or the dismissal of this case with prejudice following Rimini’s completion of its wind down relating to its PeopleSoft support services. IT IS SO ORD

‘ ITED STATES DISTRICT JUDGE

DATED: July 18, 2025. 1] I TAIT CTTIDITD ATIAN TA DDAPELRTI Me APATE CATERTH REZ ADED