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In Re: Tft-Lcd (Flat Panel) Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


January 1, 2011

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

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

This Document Relates To: STIPULATION AND [PROPOSED] ORDER RE DIRECT PURCHASER CLASS ALL DIRECT PURCHASER ACTIONS PLAINTIFFS' OPPOSITION TO HITACHI'S MOTION TO CHANGE TIME TO FILE AN OBJECTION TO THE SPECIAL MASTER'S ORDER RE MOTION BY DIRECT PURCHASER CLASS PLAINTIFFS TO COMPEL HITACHI TO PRODUCE FOREIGN REGULATORY DOCUMENTS (USA), Inc. (together, "Hitachi") currently must file any objection to the Special Master's Produce Foreign Regulatory Documents ("the Order", Docket #2244) by Wednesday, January 5, WHEREAS the Special Master has notified Hitachi and plaintiffs that he is consulting with Judge Illston regarding Hitachi's application for a stay of the January 22, 2011 9 deadline imposed by the Order (see Dkt. No. 2258-5 (E-mail from Martin Quinn to Kent Roger 10 dated December 29, 2010)); the January 5, 2011 deadline (Docket #2257); Monday, January 3, 2011; and District of California on January 3, 2011; Hitachi, by and through their undersigned counsel, subject to the Court's approval, that plaintiffs' 19 deadline to respond to Hitachi's motion shall be extended to January 5, 2011, and Hitachi's 20 deadline to object to the Order shall be extended to January 7, 2011 or another date, if any, the Court sets as a result of its consultation with the Special Master and consideration of Hitachi's motion. WHEREAS Hitachi, Ltd., Hitachi Displays, Ltd. and Hitachi Electronic Devices December 22, 2010 Order re Motion by Direct Purchaser Class Plaintiffs to Compel Hitachi to 2011;

WHEREAS on Thursday, December 30, 2010, Hitachi filed a motion to change WHEREAS plaintiffs' response to that motion would by Local Rule be due WHEREAS undersigned plaintiffs' counsel has oral argument in the Central

IT IS HEREBY STIPULATED AND AGREED by and between plaintiffs and LIEFF CABRASER HEIMANN & BERNSTEIN, LLP

By: Brendan Glackin Richard M. Heimann (State Bar No. 063607) Joseph R. Saveri (State Bar No. 130064) Eric B. Fastiff (State Bar No. 182260) LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 275 Battery Street, 29th Floor San Francisco, CA 94111-3339 Telephone: 415.956.1000 Facsimile: 415.956.1008 Bruce L. Simon (State Bar No. 096241) PEARSON, SIMON, WARSHAW & PENNY, LLP 44 Montgomery Street, Suite 2450 San Francisco, CA 94104 Telephone: (415) 433-9000 Facsimile: (415) 433-9008 Co-Lead Counsel for the Direct Purchaser Class Plaintiffs MORGAN, LEWIS & BOCKIUS LLP

By: Kent M. Roger Kent M. Roger Kent M. Roger (State Bar No. 95987 One Market Spear Street Tower San Francisco, CA 94105 Telephone: (415) 442-1140 Facsimile: (415) 442-1001 Attorneys for Defendants Hitachi Electronic Devices (USA), Inc., Hitachi, Ltd., and Hitachi Displays, Ltd. Pursuant to General Order 45, Part X-B, the filer attests that concurrence in the filing of this document has been obtained from Kent M. Roger.

SO ORDERED thisday of , 20.

20110101

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