Invisible Narratives v. Next Level Apps Technology - FZCO

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
Bobby A. Ghajar (SBN 198719)
COOLEY LLP
355 S. Grand Avenue, Suite 900
Los Angeles, California 90071
Telephone: 310.883.6400
Email: bghajar@cooley.com
Stephanie J. Schuyler (Pro Hac Vice)
COOLEY LLP
55 Hudson Yards
New York, New York 10001
Telephone: (212) 479-6000
Email: sschuyler@cooley.com
Justin A. MacLean (Pro Hac Vice)
GREENBERG TRAURIG, LLP
One Vanderbilt Avenue
New York, New York 10017
Telephone: 212.801.9200
Email: 	Justin.MacLean@gtlaw.com
Amy L. Kramer (Pro Hac Vice)
GREENBERG TRAURIG, LLP
1144 15th Street, Suite 3300
Denver, Colorado 80202
Telephone: 303.572.6500
Email: 	Amy.Kramer@gtlaw.com
Jonathan Lagarenne (Pro Hac Vice)
Cali Spota (Pro Hac Vice)
Jonathan Madara (Pro Hac Vice)
FOX ROTHSCHILD LLP
212 Carnegie Center, Suite 400
Princeton, New Jersey 08540
Email: jlagarenne@foxrothschild.com
cspota@foxrothschild.com
jmadara@foxrothschild.com
Jack Praetzellis (SBN 267765)
FOX ROTHSCHILD LLP
345 California Street, Suite 2200
San Francisco, California 94104
Email:jpraetzellis@foxrothschild.com
John Joseph Shaeffer (SBN138331)
FOX ROTHSCHILD
10250 Constellation Blvd, Ste 900
Los Angeles, California 90067-6275
Email: jshaeffer@foxrothschild.com
Attorneys for Defendant
Next Level Apps Technology – FZCO
Attorneys for Plaintiff
Invisible Narratives LLC
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
INVISIBLE NARRATIVES LLC,
Plaintiff,
v.
NEXT LEVEL APPS TECHNOLOGY –
FZCO,
Defendant.
CASE NO. 5:25-cv-01644-NW
STIPULATION AND [PROPOSED]
ORDER REGARDING NEXT
LEVEL’S AGREEMENT TO PAY
REASONABLE FEES AND COSTS
INCURRED BY INVISIBLE
NARRATIVES RELATING TO ITS
MOTION FOR CIVIL CONTEMPT
AND SANCTIONS
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 1 of 6

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
Plaintiff 	Invisible 	Narratives 	LLC 	(“Plaintiff” 	or 	“Invisible 	Narratives”) 	and
Defendant 	Next 	Level 	Apps 	Technology–FZCO 	(“Defendant” 	or 	“Next 	Level”)
(collectively the “Parties”), hereby stipulate as follows:
WHEREAS, on February 6, 2026, the Court issued an Order granting Plaintiff’s
motion to hold Defendant in civil contempt and ordering Defendant to pay Plaintiff’s
reasonable attorneys’ fees and associated costs (“Order”) (ECF 102);
WHEREAS, in the Order, the Court directed the Parties to meet and confer to seek
agreement regarding Invisible Narratives’ reasonable attorneys’ fees and costs;
WHEREAS, the Order further provided that any agreement regarding Invisible
Narratives’ reasonable attorneys’ fees and costs shall be filed as a stipulation by February
11, 2026;
WHEREAS, on February 6, 2026, the Court extended the deadline to file a stipulation
regarding Invisible Narratives’ reasonable attorneys’ fees and costs to February 18, 2026
(ECF 106); and
WHEREAS, the Parties have further met and conferred and have come to a
compromise agreement on the amount of fees and costs payable under the Order without
the need for further motion practice, an amount less than the amount of fees and costs sought
by Invisible Narratives;
NOW, THEREFORE, the Parties hereby stipulate and agree that:
1. 	Next Level shall pay Invisible Narratives a total of $160,000 in United States
dollars, payable as follows:
a. 	$75,000 payable within seven (7) days of the Court’s entry of an order
pursuant to this stipulation (“first installment”);
b. 	$42,500 payable within thirty (30) days of the deadline to pay the first
installment (“second installment”); and
c. 	$42,500 payable within thirty (30) days of the deadline to pay the
second installment (“third installment”).
2. 	Next Level’s payments shall be made by wire transfer in immediately
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 2 of 6

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
available funds from Fox Rothschild LLP to Greenberg Traurig, LLP pursuant to separate
wire instructions to be provided in writing by counsel for Invisible Narratives to counsel
for Next Level. Payment shall be deemed made when it is actually received by Greenberg
Traurig LLP. If any date for payment falls upon a weekend or banking holiday, the
payment shall be due on the first business day after such weekend or banking holiday.
3. 	If Invisible Narratives does not timely receive any payment required from
Next Level hereunder, subject to Paragraph 4 below, Next Level shall owe and
immediately pay Invisible Narratives the sum of (i) $200,000, less any payments actually
received by Invisible Narratives pursuant to this stipulation, and (ii) any additional
reasonable attorneys’ fees and costs incurred by Invisible Narratives in securing
compliance with this stipulation. This amount ($200,000) is less than the amount of fees
and costs actually sought by Invisible Narratives in connection with the DMCA takedown
that was the subject of the contempt proceedings, including the motion practice and
hearing. The foregoing agreement does not preclude Invisible Narratives from seeking a
finding of contempt of any Order entered pursuant to this stipulation, and such additional
relief from the Court as warranted.
4. 	Notwithstanding Paragraph 3 above, if Invisible Narratives does not timely
receive a payment required from Next Level hereunder, then Invisible Narratives shall
promptly meet and confer with Next Level in good faith in an effort to resolve any
disputes between the Parties relating to the actual or asserted violation of this stipulation
before seeking relief from the Court, so long as (a) Next Level is able to prove that
technical issues or events constituting force majeure not within Next Level’s or Next
Level’s counsel’s control caused Next Level’s payment to be untimely; (b) the delay is no
more than one (1) business day; and (c) Next Level provides notice and verification of
such events to Invisible Narratives promptly. Failure to satisfy all of the requirements of
this Paragraph 4(a)-(c) may not be used as an excuse for any delayed payment.
5. 	The Parties agree that this stipulation shall be subject to an Order of this
Court and fully enforceable by the Court.
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 3 of 6

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
Respectfully submitted,
DATED: February 18, 2026 	GREENBERG TRAURIG, LLP
By /s/ Justin A. MacLean
Justin A. MacLean
Amy L. Kramer
Attorneys for Plaintiff
Invisible Narratives LLC
DATED: February 18, 2026 	FOX ROTHSCHILD, LLP
By /s/ Cali Spota
Jonathan Lagarenne
Cali Spota
Jonathan Madara
Attorneys for Defendant
Next Level Apps Technology – FZCO
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 4 of 6

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3):
I, Justin A. MacLean, counsel for Invisible Narratives LLC, attest that all
Signatories have concurred in the filing of the document.
DATED: February 18, 2026 	Greenberg Traurig, LLP
By /s/ Justin A. MacLean
Justin A. MacLean
Attorneys for Invisible Narratives LLC
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 5 of 6

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JOINT STIPULATION REGARDING AGREEMENT TO PAY REASONABLE FEES AND COSTS INCURRED BY
INVISIBLE NARRATIVES RELATING TO ITS MOTION FOR CIVIL CONTEMPT AND SANCTIONS
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: _____________, 2026 	By:
Hon. Noël Wise
UNITED STATES DISTRICT JUDGE
February 19
Case 5:25-cv-01644-NW Document 109 Filed 02/19/26 Page 6 of 6