The opinion of the court was delivered by: Hon. Susan Illston United States District Judge
MORGAN, LEWIS & BOCKIUS LLP KENT M. ROGER, State Bar No, 95987 HERMAN J. HOYING, State Bar No. 257495 JENNIFER L. CALVERT, State Bar No. 258018 One Market, Spear Street Tower San Francisco, CA 94105-1126 Tel: 415.442.1000 Fax: 415.442.1001 5 email@example.com firstname.lastname@example.org 6 email@example.com Attorneys for Defendants HITACHI, LTD., HITACHI DISPLAYS, LTD., HITACHI ELECTRONIC DEVICES (USA), INC.
Master File No. 3:07-md-1827
STIPULATION AND [PROPOSED] ORDER REGARDING TIME TO RESPOND TO AMENDED COMPLAINT
WHEREAS plaintiff State of Oregon ("Oregon") filed the above captioned lawsuit on August 10, 2010; 3
WHEREAS Oregon filed a first amended complaint on April 15, 2011 ("Amended Complaint");
WHEREAS Defendants Hitachi Displays, Ltd., Hitachi Electronic Devices
and Hitachi, Ltd. (collectively, the "Hitachi Defendants") and
Defendants Chi Mei Corporation,
Chi Mei Innolux Corporation, CMO Japan Co., Ltd., and Chi Mei
Optoelectronic USA, Inc.
(collectively, the "Chi Mei Defendants") jointly filed with other
defendants a motion to dismiss
Count III in its entirety and Count IV to the extent it seeks
"disgorgement of profits" as a remedy 11 on June 6, 2011; 12
WHEREAS the Court denied Defendants' joint motion to dismiss Counts III and IV of the Amended Complaint on July 12, 2011;
WHEREAS all defendants, including the Hitachi Defendants and Chi Mei Defendants, entered into a stipulation with Oregon on July 21, 2011 that Defendants' deadline to answer the Amended Complaint was August 12, 2011;
WHEREAS on July 21, 2011, the Court entered an order extending Defendants' deadline to answer the Amended Complaint until August 12, 2011;
WHEREAS the Hitachi Defendants and Chi Mei Defendants entered into a stipulation with Oregon on August 11, 2011 that the Hitachi Defendants' and Chi Mei Defendants' deadline to answer the Amended Complaint is September 12, 2011; 24
WHEREAS on August 24, 2011, the Court entered an order extending the Hitachi Defendants' and Chi Mei Defendants' deadline to answer the Amended Complaint until September 12, 2011;
WHEREAS extending the Hitachi Defendants' and Chi Mei Defendants' time to respond 2 to the Amended Complaint will not alter the date of any other event or deadline already fixed by 3 the Court;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and among the 5 undersigned counsel, on behalf of their respective clients, Oregon, on the one hand, and the 6 7 Hitachi Defendants and ...