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In re TFT-LCD Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


June 22, 2010

IN RE: TFT-LCD (FLAT PANEL) ANTITRUST LITIGATION

The opinion of the court was delivered by: Honorable Susan Illston United States District Judge

This Document Relates To:

MDL No. 1827

STIPULATION AND [PROPOSED] ORDER REGARDING AMENDMENT TO INDIRECT- ALL INDIRECT-PURCHASER ACTIONS PURCHASER PLAINTIFFS' SECOND CONSOLIDATED AMENDED COMPLAINT Judge: Honorable Susan Y. Illston Crtrm: 10, 19th Floor

TO THE COURT AND ALL PARTIES AND THEIR COUNSEL OF RECORD:

IT IS HEREBY STIPULATED by and between the parties, INDIRECT PURCHASER PLAINTIFFS, and EPSON IMAGING DEVICES CORPORATION (collectively "the Parties") and their respective counsel, and subject to the approval of the Court, that Indirect-Purchaser

Plaintiffs' Second Consolidated Amended Complaint ("Complaint"), filed December 5, 2008 (Dkt. No. 746), be deemed amended as follows.

1. New Paragraph 95A shall state: "Defendant Epson Imaging Devices Corporation ("EID") is a Japanese Company with its principal place of business in Tottori, Japan. EID was 5 originally formed as Sanyo Epson Imaging Devices Corporation on October 1, 2004 as a joint venture co-owned by Seiko Epson Corporation and Sanyo Electric Co., Ltd. As of December 28, 2006, Sanyo Epson Imaging Devices Corporation became a wholly-owned subsidiary of Seiko Epson Corporation and changed its name to EID. During the Class Period EID manufactured, sold and/or distributed LCD panels to customers throughout the United States."

2. Paragraph 98 is amended to delete the reference to "Epson Imaging Devices Corporation."

3. All references to "defendants" in the Complaint, except as the term is used to describe a specifically-named defendant or defendants other than EID, shall be deemed to include EID.

Dated: June 21, 2010

MELVIN R. GOLDMAN STEPHEN P. FRECCERO DEREK F. FORAN MORRISON & FOERSTER LLP Stephen P. Freccero Attorneys for Counsel for Defendants Seiko Epson Corporation; Epson Imaging Devices Corporation; Epson Electronics America, Inc.

Attestation: Pursuant to General Order No. 45, the filer attests that concurrence in the filing of this document has been obtained from each of the signatories.

Pursuant to the stipulation of the parties, IT IS SO ORDERED.

20100622

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