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In Re: Cathode Ray Tube (Crt) Antitrust Litigation

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


July 28, 2011

IN RE: CATHODE RAY TUBE (CRT) ANTITRUST LITIGATION

The opinion of the court was delivered by: Hon. Samuel Conti United States District Judge

Ronald C. Redcay (SBN 67236) E-Mail: Ronald.Redcay@aporter.com 2 John D. Lombardo (SBN 187142) E-Mail: John.Lombardo@aporter.com D. Eric Shapland (SBN 193853) E-Mail: Eric.Shapland@aporter.com Eric D. Mason (SBN 259233) E-Mail: Eric.Mason@aporter.com 5 ARNOLD & PORTER LLP 777 South Figueroa Street, Forty-Fourth Floor Los Angeles, California 90017-5844 Telephone: 213.243.4000 7 Facsimile: 213.243.4199 8 Beth H. Parker (SBN 104773) Samuel R. Miller (SBN 66871) E-Mail: Beth.Parker@aporter.com E-Mail: srmiller@sidley.com 9 ARNOLD & PORTER LLP Marie L. Fiala (SBN 79676) One Embarcadero Center E-Mail: mfiala@sidley.com 10 Twenty-Second Floor Ryan M. Sandrock (SBN 251781) San Francisco, California 94111-3711 E-Mail: rsandrock@sidley.com 11 Telephone: 415.356.3000 Robert B. Martin, III (SBN 235489) Facsimile: 415.356.3099 E-Mail: rbmartin@sidley.com 12 SIDLEY AUSTIN LLP 555 California Street, 20th Floor San Francisco, California 94104 Telephone: (415) 772-1200 Facsimile: (415) 772-7400 Attorneys for Defendants LG Electronics, Inc.; and LG Electronics USA, Inc.; and LG Electronics 16 Taiwan Taipei Co., Ltd. 17 [Additional Parties and Counsel Listed on Signature Pages]

STIPULATION AND [PROPOSED] ORDER ON SPECIAL MASTER'S REPORT AND RECOMMENDATIONS REGARDING DEFENDANTS' MOTION TO COMPEL DISCOVERY ON DOWNSTREAM INFORMATION

This Document Relates To The Direct Purchaser Action defendants, on the other hand, through their respective counsel, hereby stipulate and agree as 3 follows:

Plaintiffs to Produce Downstream Discovery (Docket No. 925); to Compel the Direct Purchaser Plaintiffs to Produce Downstream Discovery (Docket No. 941); Defendants' Motion to Compel the Direct Purchaser Plaintiffs to Produce Downstream Discovery WHEREAS on June 23, 2011, Special Master Charles A. Legge heard oral argument 12 regarding the Motion to Compel the Direct Purchaser Plaintiffs to Produce Downstream Discovery; 13 and 14 Report and Recommendations on Discovery Regarding Downstream Information (Docket No. 966) 16 Direct Purchaser Plaintiffs ("DP Plaintiffs"), on the one hand, and the undersigned WHEREAS on April 29, 2011, the undersigned defendants filed a Motion to Compel the DP WHEREAS on May 31, 2011, the DP Plaintiffs filed an Opposition to Defendants' Motion WHEREAS on June 15, 2011, the undersigned defendants, filed a Reply in Support of (Docket No. 948);

WHEREAS on July 13, 2011, Special Master Charles A. Legge issued and filed via ECF his (the "Report") recommending that Defendants' Motion to Compel Downstream Discovery be 17 granted in part and denied in part; undersigned defendants and DP Plaintiffs, that:

2008 Order Appointing Special Master (Docket No. 302), the Special Master's Recommendations, 22 attached hereto as exhibit A, shall be entered as an Order of this Court.

IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the

1. Pursuant to Rule 53 of the Federal Rules of Civil Procedure and the Court's June 16,

2. Plaintiffs shall have 45 days from the entry of this Order to produce the information

2 identified in the attached Report and Recommendation. 3

IT IS SO STIPULATED.

Pursuant to General Order No. 45, § X-B, the filer attests that concurrence in the filing of this document has been obtained from each of the above signatories.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20110728

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