granting three-year stay to allow the parties to perform under a settlement 2 agreement
How later courts described this case
- granting three-year stay to allow the parties to perform under a settlement 2 agreement
Written by the judges who cited it.
The opinion
1 BOIES, SCHILLER FLEXNER LLP GIBSON, DUNN & CRUTCHER LLP
RICHARD J. POCKER (NV Bar No. 3568) SAMUEL LIVERSIDGE (pro hac vice)
2 300 South Fourth Street, Suite 800 ERIC D. VANDEVELDE (pro hac vice)
Las Vegas, NV 89101 ILISSA S. SAMPLIN (pro hac vice)
3 Telephone: 702.382.7300 333 South Grand Avenue
Facsimile: 702.382.2755 Los Angeles, CA 90071-3197
4 rpocker@bsfllp.com Telephone: 213.229.7000
sliversidge@gibsondunn.com
5 DUNN ISAACSON RHEE LLP evandevelde@gibsondunn.com
WILLIAM A. ISAACSON (pro hac vice) isamplin@gibsondunn.com
6 KAREN DUNN (pro hac vice)
JESSICA PHILLIPS (pro hac vice) GIBSON, DUNN & CRUTCHER LLP
7 401 9th Street, NW BLAINE H. EVANSON (pro hac vice)
Washington, DC 20004 CASEY J. MCCRACKEN (pro hac vice)
8 Telephone: 202.240.2900 JOSEPH A. GORMAN (pro hac vice)
wisaacson@dirllp.com 3161 Michelson Drive
9 kdunn@dirllp.com Irvine, CA 92612-4412
jphillips@dirllp.com Telephone: 949.451.3800
10 jtthomas@gibsondunn.com
MORGAN, LEWIS & BOCKIUS LLP bevanson@gibsondunn.com
11 BENJAMIN P. SMITH (pro hac vice) cmccracken@gibsondunn.com
One Market, Spear Street Tower jgorman@gibsondunn.com
12 San Francisco, CA 94105
Telephone: 415.442.1000 HOWARD & HOWARD ATTORNEYS PLLC
13 Facsimile: 415.442.1001 W.WEST ALLEN (Nevada Bar No. 5566)
benjamin.smith@morganlewis.com 3800 Howard Hughes Parkway, Suite 1000
14 sharon.smith@morganlewis.com Las Vegas, NV 89169
Telephone: 702.667.4843
15 JAMES C. MAROULIS (pro hac vice) wwa@h2law.com
ORACLE CORPORATION
16 500 Oracle Parkway, M/S 5op7 RIMINI STREET, INC.
Redwood City, CA 94070 JOHN P. REILLY (pro hac vice)
17 Telephone: 650.506.4846 1700 S. Pavilion Center Drive, Suite 330
Facsimile: 650.506.7114 Las Vegas, NV 89135
18 dorian.daley@oracle.com Telephone: 336.908.6961
jim.maroulis@oracle.com jreilly@riministreet.com
19
Attorneys for Plaintiffs Oracle International WEIL, GOTSHAL & MANGES LLP
20 Corporation and Oracle America, Inc. MARK A. PERRY (pro hac vice)
2001 M Street, N.W., Suite 600
21 Washington, DC 20036
Telephone: 202.682.7511
22 mark.perry@weil.com
23 Attorneys for Defendants Rimini Street, Inc.,
and Seth Ravin
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1 IN THE UNITED STATES DISTRICT COURT
2 FOR THE DISTRICT OF NEVADA
3
4 ORACLE INTERNATIONAL CORP., and CASE NO. 2:14-cv-01699-MMD-DJA
ORACLE AMERICA, INC.,
5
ORDER GRANTING JOINT
Plaintiffs, STIPULATION TO STAY ALL
6
PROCEEDINGS PENDING
7 v. SETTLEMENT RESOLUTION AND TO
VACATE THE SCHEDULING ORDER
8 RIMINI STREET, INC., and SETH RAVIN,
Judge: Hon. Miranda M. Du
9 Defendants.
10
JOINT STIPULATION TO STAY PROCEEDINGS AND
11 VACATE SCHEDULING ORDER
12 Plaintiffs Oracle International Corp. and Oracle America, Inc. (“Oracle”) and Defendants
13 Rimini Street, Inc. and Seth Ravin (collectively, “Rimini,” and with Oracle, the “Parties”) executed
14 a settlement agreement with an effective date of July 7, 2025 (“Settlement Agreement”) to resolve
15 the entirety of this case pending Rimini’s wind down of its offering of support services for Oracle’s
16 PeopleSoft software product, and therefore, by and through their respective counsel of record,
17 respectfully request that this Court (1) stay all proceedings in this case and (2) vacate all current
18 deadlines and hearing dates set forth in the existing Scheduling Order (ECF No. 1637) to allow
19 the Parties to perform under and effectuate the Settlement Agreement.
20 1. WHEREAS, on July 31, 2024, Rimini unilaterally announced its decision to wind
21 down its offering of support services for Oracle’s PeopleSoft software product;
22 2. WHEREAS, following remand from the Ninth Circuit in March 2025, the only
23 product line at issue in the pending remand proceedings is PeopleSoft;
24 3. WHEREAS, on June 26, 2025, the Parties conducted a successful in-person
25 mediation;
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1 4. WHEREAS, the parties seek to avoid the time and expense of further litigation
2 concerning alleged copyright infringement of a software product Rimini has represented it will no
3 longer support;
4 5. WHEREAS, the Parties’ full performance under the Parties’ Settlement Agreement
5 will fully resolve the entirety of this litigation, including all issues remanded by the Ninth Circuit,
6 as well as any dispute regarding attorneys’ fees, although the Parties agree that this Court will
7 retain jurisdiction to enforce, as necessary, the permanent injunction entered in the Rimini I action
8 (Rimini I ECF No. 1166; Oracle USA, Inc. v. Rimini St. Inc., 783 F. App’x 707, 710-711 (9th Cir.
9 2019)), as well as the Modified Permanent Injunction entered in this action (ECF No. 1635);
10 6. WHEREAS, under the Settlement Agreement, Rimini will complete its previously
11 announced wind down of support services related to PeopleSoft by no later than July 31, 2028;
12 7. WHEREAS, following Rimini’s successful completion of the wind down as
13 described in the Settlement Agreement, and Rimini’s notice to Oracle of such completion in
14 compliance with the terms of the Settlement Agreement (including a declaration under penalty of
15 perjury that Rimini has in fact completed its wind down), Oracle has agreed to dismiss this case
16 with prejudice;
17 8. WHEREAS, the Parties agree that a stay of all proceedings during the wind down
18 period serves the interests of judicial economy by vacating all existing deadlines provided in this
19 Court’s Scheduling Order (ECF No. 1637) such that the Court will be substantially relieved of any
20 further administration of this case;
21 9. WHEREAS, in the unlikely event of an unexpected material breach of the
22 Settlement Agreement during the wind down, the Parties jointly agree that it would be more
23 efficient to lift the stay and resume the proceedings in this matter rather than requiring the non-
24 breaching Party to commence new litigation;
25 10. WHEREAS, the Court may “stay[] the case while retaining jurisdiction over
26 possible disputes concerning compliance with a settlement agreement” under Kokkonen v.
27 Guardian Life Ins. Co. of Am., 511 U.S. 375, 381–82 (1994) and its inherent authority to control
1 Mass. 2012) (granting three-year stay to allow the parties to perform under a settlement
2 agreement);
3 11. WHEREAS, a stay of proceedings will not harm the Parties, will avoid the
4 additional hardship of continuing to actively litigate this decade-long dispute, will allow the parties
5 to focus exclusively on satisfying the terms of the Settlement Agreement, and will promote judicial
6 economy, see Epstein v. US Foods, Inc., 2025 WL 330544, at *1 (W.D. Wash. Jan. 29, 2025)
7 (describing factors courts consider in evaluating a request for a stay and granting joint stipulation
8 to stay “to allow the mediation process to play out”); In re W. States Wholesale Nat. Gas Antitrust
9 Litig., 2019 WL 2098350 (D. Nev. Apr. 5, 2019) (staying all proceedings “until further order of
10 the Court, except such proceedings as may be necessary either to implement the Settlements or to
11 comply with or effectuate the terms of the Agreements or Fed. R. Civ. P. 23”);
12 12. THEREFORE, the Parties stipulate and agree that all proceedings in this matter
13 should be stayed for the duration of the three-year wind down period required to effectuate the
14 Parties’ agreement to settle the above-captioned matter, and that all deadlines set forth in the
15 Scheduling Order (ECF No. 1637) should be vacated.
16 Dated: July 17, 2025
17
18 GIBSON, DUNN & CRUTCHER LLP MORGAN, LEWIS & BOCKIUS LLP
19
By: /s/ Eric D. Vandevelde By: /s/ Benjamin P. Smith
20 Eric D. Vandevelde Benjamin P. Smith
21 Attorneys for Defendants Rimini Street, Inc., Attorneys for Plaintiffs Oracle
and Seth Ravin International Corporation and Oracle
22 America, Inc.
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Pursuant to the Parties’ joint stipulation, and for good cause shown, IT IS ORDERED that
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all deadlines set forth in the Scheduling Order (ECF No. 1637) are VACATED and all proceedings
27
in this case are STAYED until the earlier of July 31, 2028, or the dismissal of this case with
1 || prejudice following Rimini’s completion of its wind down relating to its PeopleSoft support
2 || services.
3
IT IS SO ORD
5
‘ ITED STATES DISTRICT JUDGE
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DATED: July 18, 2025.
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TAIT CTTIDITD ATIAN TA DDAPELRTI Me APATE CATERTH REZ ADED