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In re TFT-LCD Flat Panel Antitrust Litigation

August 13, 2009

IN RE: TFT-LCD (FLAT PANEL ANTITRUST LITIGATION


MDL NO. 1827

DEFENDANTS' REQUEST TO SEAL DOCUMENTS PURSUANT TO COURT'S JULY 7, 2009 ORDER RE SEALING

This Document Relates To: DOCUMENTS FOR CLASS CERTIFICATION MOTIONS

ALL INDIRECT PURCHASER ACTIONS

On July 7, 2009, the Court issued an Order Re: Sealing Documents for Class Certification Motions (Dkt. #1108), which states, in relevant part, that "[a]ll documents as to which any sealing request has been made to date will be filed entirely under seal. Any other documents filed in connection with the class certification motions will likewise be filed under seal, if requested.

No further motions or declarations concerning sealing are required." Pursuant to this Order, Defendants hereby request to file the following documents under seal:

* The Defendants' Joint Opposition to Indirect Purchaser Plaintiffs' Motion for Class Certification;

DECLARATION OF MICHAEL R. LAZERWITZ IN SUPPORT OF DEFENDANTS' JOINT OPPOSITION TO INDIRECT PURCHASER PLAINTIFFS' MOTION FOR CLASS CERTIFICATION, Case No. M: 07-1827 SI, FS

* The Declaration, and attached Exhibits, of Michael R. Lazerwitz in Support of Defendants' Joint Opposition to Indirect Purchaser Plaintiffs' Motion for Class Certification; and

* The Declaration, and attached Exhibits, of Edward A. Snyder, Ph.D., in Support of Defendants' Joint Opposition to Indirect Purchaser Plaintiffs' Motion for Class Certification LG Display Co., Ltd. and LG Display America, Inc. submit this request as the defendant responsible for filing and lodging the documents described above, which they have designated as "confidential" or "highly confidential."

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