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Full title: Request for Entry of Default Re: (Request for Entry of Order Sustaining Amended Objections to Late Claims by Default) (RE: related document(s)1335 Objection). Filed by Debtor Wave Computing, Inc. (Attachments: # 1 Declaration of Julie H. Rom-Banks # 2 Certificate of Service) (Rome-Banks, Julie) (Entered: 05/20/2021)

Document posted on May 19, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

LATE CLAIMS BY DEFAULT 17 18 WAVE COMPUTING, INC., MIPS TECH, INC. and CAUSTIC GRAPHICS, INC., 19 the Reorganized Debtors and Debtors-in-Possession (together the “Debtors” and each a 20 “Debtor”) hereby requests entry of an order by default sustaining the Amended Objections to Lat21 Claims (the “Claim Objections”).On April 19, 2021, the Debtors also served the Claim Objections on the effected 4 claimants together with a supporting Amended Declaration of Julie H. Rome-Banks (the 5 “Declaration”) and an Amended Notice of Objections to Late Claims and Opportunity to Request 6 The Claim Objections, the Declaration, and the Notice were all served o7 April 19, 2021 by mail upon the counterparties to each identified claim that was the subject of the8 Claim Objections at the addresses listed on the cover page of the proofs of claim filed by the 9 effected creditors.The Claim Objections, supporting Declaration and Notice together with the Certificates o12 Service by Mail thereof were electronically filed through the Court’s ECF system and reflected o13 the Court’s Docket in the above-captioned case as Docket Numbers 1335, 1335-1, 1336, and 14 1336-1 and are incorporated herein by such reference.True and correct copies of the first 3 pages of each of the proofs of claim that are 16 the subject of the Claim Objections and which reflect the service addresses that the Debtor used 17 for each of the affected creditors are attached as Exhibits “A” through “E” to the Declaration of 18 Julie H. Rome-Banks concurrently filed in support of this Request and are incorporated herein by 19 reference.

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Document Contents

1 BINDER & MALTER, LLP Michael W. Malter (SBN 96533) 2 Robert G. Harris (SBN 124678) Julie H. Rome-Banks (SBN 142364) 3 2775 Park Avenue, Santa Clara CA 95050 4 Telephone: 408.295.1700 Facsimile: 408.295.1531 5 Email: michael@bindermalter.com Email: rob@bindermalter.com 6 Email: julie@bindemalter.com 7 Attorneys for the Reorganized Debtors 8 UNITED STATES BANKRUPTCY COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11 In re: Case No. 20-50682 (MEH) 12 WAVE COMPUTING, INC., et al., Chapter 11 (Jointly Administered) 13 Debtors.1 14 NO HEARING REQUESTED 15 REQUEST FOR ENTRY OF ORDER SUSTAINING AMENDED OBJECTIONS TO 16 LATE CLAIMS BY DEFAULT 17 18 WAVE COMPUTING, INC., MIPS TECH, INC. and CAUSTIC GRAPHICS, INC., 19 the Reorganized Debtors and Debtors-in-Possession (together the “Debtors” and each a 20 “Debtor”) hereby requests entry of an order by default sustaining the Amended Objections to Lat21 Claims (the “Claim Objections”). The Debtor respectfully represents as follows in support of this 22 request: 23 1. The Debtors each filed a voluntary petition under chapter 11 on April 27, 2020 (th24 “Petition Date”). 25 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’federal tax identification number, as applicable, are: Wave Computing, Inc. (4264), MIPS Tec26 Inc. (8247), Hellosoft, Inc. (8640), Wave Computing (UK) Limited (None), Imaginatio27 Technologies, Inc. (6967), Caustic Graphics, Inc. (7272), and MIPS Tech, LLC (2161). Th

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1 2. On April 19, 2021, the Debtors filed the Claim Objections, therein objecting to the2 allowance of certain claims filed in this bankruptcy case for the reasons stated therein. 3 3. On April 19, 2021, the Debtors also served the Claim Objections on the effected 4 claimants together with a supporting Amended Declaration of Julie H. Rome-Banks (the 5 “Declaration”) and an Amended Notice of Objections to Late Claims and Opportunity to Request 6 Hearing (“the Notice”). The Claim Objections, the Declaration, and the Notice were all served o7 April 19, 2021 by mail upon the counterparties to each identified claim that was the subject of the8 Claim Objections at the addresses listed on the cover page of the proofs of claim filed by the 9 effected creditors. In addition, the U.S. Trustee and parties requesting special notice in this 10 bankruptcy case were also served with the Notice through the Court’s CM/ECF electronic noticin11 system. The Claim Objections, supporting Declaration and Notice together with the Certificates o12 Service by Mail thereof were electronically filed through the Court’s ECF system and reflected o13 the Court’s Docket in the above-captioned case as Docket Numbers 1335, 1335-1, 1336, and 14 1336-1 and are incorporated herein by such reference. 15 4. True and correct copies of the first 3 pages of each of the proofs of claim that are 16 the subject of the Claim Objections and which reflect the service addresses that the Debtor used 17 for each of the affected creditors are attached as Exhibits “A” through “E” to the Declaration of 18 Julie H. Rome-Banks concurrently filed in support of this Request and are incorporated herein by 19 reference. 20 5. More than thirty (30) days have passed since the Claim Objections, the supporting 21 Declaration and the Notice were served upon the affected creditors pursuant to BLR 3007-1 and 22 9014-1(b)(3). No request for a hearing has been filed or served and Debtor’s bankruptcy counsel, 23 Binder & Malter, LLP, has not been contacted by any creditor or party in interest expressing 24 opposition to the relief requested in the Claim Objections. Accordingly, the Debtors requests entr25 of this order granting the relief sought in the Claim Objections by default pursuant to FRBP 9014-26 1(b)(4). 27

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1 WHEREFORE, the Debtors respectfully request that the Court enter the order submitted 2 concurrently herewith sustaining the Claim Objections by default. 3 4 Dated: May 20, 2021 BINDER & MALTER, LLP 5 By: /s/ Julie H. Rome-Banks Julie H. Rome-Banks 6 Attorneys for Reorganized Debtors 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

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