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Oracle USA, Inc. v. SAP AG

January 7, 2010

ORACLE USA, INC., ET AL., PLAINTIFFS,
v.
SAP AG, ET AL., DEFENDANTS.



The opinion of the court was delivered by: Elizabeth D. Laporte United States Magistrate Judge

STIPULATION AND [PROPOSED] ORDER TO AMEND THE STIPULATED PROTECTIVE ORDER

Plaintiffs Oracle USA, Inc. Oracle International Corporation, Oracle EMEA Limited, and Siebel Systems, Inc. ("Plaintiffs") and Defendants SAP AG, SAP America, Inc., and TomorrowNow, Inc. ("Defendants," and together with Oracle, the "Parties") jointly submit this Stipulation and Proposed Order to Amend the Stipulated Protective Order.

WHEREAS, on June 6, 2007, the Court issued a Stipulated Protective Order in this matter (D.I. 32);

WHEREAS, the Parties have agreed, with the permission of the Court, Exhibit D to the Stipulated Protective Order ("Exhibit D"), titled "SAP Coverage Counsel Addendum," and its related acknowledgement form titled "SAP Coverage Counsel Declaration of Compliance" ("Exhibit E") shall be made part of the Stipulated Protective Order; and

WHEREAS, the Parties have agreed, with the permission of the Court, Exhibits D and E, attached to this Joint Stipulation and Proposed Order as Attachment 1, shall immediately follow Exhibit C in the Stipulated Protective Order.

IT IS SO STIPULATED.

DATED: January 6, 2009

JONES DAY By: Scott Cowan Attorneys for Defendants SAP AG, SAP AMERICA, INC., and TOMORROWNOW, INC.

In accordance with General Order No. 45, Rule X, the above signatory attests that concurrence in the filing of this document has been obtained from the signatory below.

DATED: January 6, 2009

BINGHAM McCUTCHEN LLP By: Holly House Attorneys for Plaintiffs ORACLE USA, INC., ORACLE INTERNATIONAL CORPORATION, ORACLE EMEA LIMITED, and SIEBEL SYSTEMS, INC.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Exhibit D

SAP COVERAGE COUNSEL ...


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