JOINT STIPULATION AND [PROPOSED] ORDER FOR ENTRY OF FINAL CONSENT JUDGMENT

JON S. TIGAR, District Judge.

Plaintiff and Counterdefendant Asia Vital Components Co., Ltd. ("AVC") and Defendant and Counterclaimant Asetek Danmark A/S ("Asetek") have agreed on a confidential binding term sheet (the "Agreement") to fully resolve this case, and as a condition of the Agreement Asetek and AVC (the "Parties") jointly stipulate to the following:

1. The Proposed Final Consent Judgment in the form attached hereto as Exhibit A be entered by the Court;

2. Without admitting to liability but to resolve this action and to preserve resources, AVC agrees to pay Asetek the amount specified in the Agreement;

3. Asetek will not sue AVC and/or AVC's Customers (defined in the Agreement), officers, directors, agents, servants, representatives, attorneys, employees, subsidiaries and Affiliates for infringement of United States Patent Nos. 8,240,362 and 8,245,764 based on the Accused Products in this action (defined in the Agreement and Proposed Final Consent Judgment) shipped to AVC's Customers before the Effective Date of the Agreement;

4. AVC may not and will not assert invalidity (by claim, counterclaim, or otherwise) or in any way challenge or contest the validity or patentability of any claim of any Asetek AIO Patent (defined in the Agreement) in any proceeding in any court or tribunal in any country, or in the United States Patent Office (including the Patent Trial and Appeal Board) or in any patent office or patent tribunal in any country, and AVC will terminate, withdraw, and/or dismiss any and all existing challenges to any and all Asetek AIO Patents or claims anywhere in the world within fifteen (15) days after the Effective Date;

5. AVC will not accuse Asetek's existing or future AIO Devices (defined in the Agreement) of infringing any patents or utility models issued anywhere in the world that are owned by or assigned to AVC, nor will AVC file any lawsuits or claims alleging such infringement. AVC will terminate, withdraw and/or dismiss any infringement allegations, lawsuits, or claims against Asetek AIO Devices (if any), within fifteen (15) days of the Effective Date of the Agreement;

6. The Parties shall each bear their own attorneys' fees, costs, and expenses;

7. The Court retains jurisdiction over the Parties and to enforce the terms of the Agreement and the stipulated Final Consent Judgment; and

8. All remaining issues, claims, defenses, and counterclaims in this action are dismissed with prejudice.

ATTESTATION

Counsel for Asetek hereby attests by her signature below that concurrence in the signing and filing of this document was obtained from counsel for AVC.

[PROPOSED] ORDER

The Court, having considered the Stipulation of Plaintiff and Counterdefendant Asia Vital Components Co., Ltd. ("AVC") and Defendant and Counterclaimant Asetek Danmark A/S ("Asetek") (together the "Parties") for entry of Final Consent Judgment, and FOR GOOD CAUSE SHOWN, HEREBY ORDERS THAT THE PARTIES' STIPULATION IS GRANTED AND AS FOLLOWS:

1. This Court has jurisdiction over the Parties and the subject matter of this action;

2. In accordance with the Stipulation, the Clerk of the Court is hereby directed to enter the Final Consent Judgment (Exhibit A to the Stipulation) after it is signed by the Court;

3. The Final Consent Judgment is binding upon the Parties, their agents, and others acting in concert with them or legally identified with them;

4. This Court retains jurisdiction to enforce this Order, the stipulated Final Consent Judgment, and the Agreement between the Parties.