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In Re: Tft-Lcd (Flat Panel)

July 21, 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

Bruce L. Simon (State Bar No. 96241) PEARSON, SIMON, WARSHAW & PENNY, LLP 44 Montgomery Street, Suite 2450 San Francisco, CA 94104 Telephone: (415) 433-9000 Facsimile: (415) 433-9008 Richard M. Heimann (State Bar No. 63607) LIEFF, CABRASER, HEIMANN & BERNSTEIN, LLP 275 Battery Street, 29th Floor San Francisco, CA 94111-3339 Telephone: (415) 956-1000 Facsimile: (415) 956-1008 Direct Purchaser Co-Lead Class Counsel

STIPULATION AND [PROPOSED]

This Document Relates to: ORDER DISMISSING TATUNG

COMPANY OF AMERICA, INC.

ALL DIRECT PURCHASER CLASS ACTIONS

WHEREAS, Plaintiffs are prosecuting the Direct Purchaser Class Action, Master File No. 3:07-md-1827 SI (the "Action") in In re TFT-LCD (Flat Panel) Antitrust Litigation, MDL 24 No. 1827 (N.D. Cal.) on their own behalf and on behalf of the Direct Purchaser Classes against, 25 among others, defendant Tatung Company of America, Inc. ("Tatung America");

WHEREAS, Plaintiffs allege that Tatung America participated in an unlawful conspiracy to raise, fix, maintain, or stabilize the price of TFT-LCD Products at artificially high levels in 28 violation of Section 1 of the Sherman Act;

WHEREAS, Tatung America denies Plaintiffs' allegations and has asserted defenses to Plaintiffs' claims; regarding the Action and have concluded that dismissing their claims against Tatung America is 5 in the best interest of Plaintiffs and the Classes; undersigned that the Action be dismissed pursuant to Federal Rule of Civil Procedure 41(a)(2) 8 without prejudice as to Tatung America, without costs to Plaintiffs, the Class, or Tatung America, 9 and state as follows: action without prejudice pursuant to Federal Rule of Civil Procedure 41(a)(2).

costs and fees.

against the Direct Purchaser Class Plaintiffs and their counsel, as long as the action against it 16 remains dismissed.

WHEREAS, Plaintiffs have conducted an investigation into the facts and the law

NOW, THEREFORE, it is agreed by and among Plaintiffs, Tatung America, and the

1. Direct Purchaser Class Plaintiffs and Tatung America seek the dismissal of this

2. Both Direct Purchaser Class Plaintiffs and Tatung America are ...


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