STIPULATION AND [PROPOSED] ORDER EXTENDING THE DEADLINE TO FILE A MOTION TO COMPEL ACTIONS HITACHI DEFENDANTS TO SUPPLEMENT RESPONSES TO INDIRECT PURCHASER PLAINTIFFS' FIRST SET OF INTERROGATORIES

SAMUEL CONTI, District Judge.

This Stipulation and Proposed Order between the Indirect-Purchaser Plaintiffs ( "IPPs") and Hitachi, Ltd. ("HTL"), Hitachi Displays, Ltd.("HDP"), Hitachi Asia, Ltd. ("HAS"), Hitachi America, Ltd., and Hitachi Electronic Devices (USA), Inc. (collectively, "Hitachi Defendants") (together, the "Parties") is made with respect to the following facts and recitals:

WHEREAS, the IPPs and the Hitachi Defendants have met and conferred in order to resolve all outstanding discovery issues with regard to Hitachi's responses to IPPs' First Set of Interrogatories ("Interrogatories");

WHEREAS, the Hitachi Defendants have agreed to supplement their responses to Interrogatory No. 6 to identify with greater specificity the publicly available information upon which the Hitachi Defendants intend to rely;

WHEREAS, the Hitachi Defendants have agreed to supplement their responses to Interrogatory No., 7, as it related to their affirmative defenses Nos. 8, 13, 14, 19, 25, 27, 28, 32, 33, 34, 35 and 38 only;

WHEREAS, defendants HTL, HDP and HAS have agreed to supplement their responses to Interrogatory No. 8;

WHEREAS, defendants HTL and HDP have agreed to supplement their responses to Interrogatory No. 9;

WHEREAS, the Hitachi Defendants have agreed to supplement their responses to Interrogatory Nos. 10, 11, 13, 15, 16, 18, 22, 23 and 24;

WHEREAS, the Parties are currently required to file any motion to compel by September 12, 2014;

WHEREAS, the Hitachi Defendants agree to supplement their responses to the above-described Interrogatories by Friday, September 26, 2014;

WHEREAS, the Hitachi Defendants agree to extend the deadline by which the IPPs may file a motion to compel regarding the Hitachi Defendants' Responses to the above-described Interrogatories to October 3, 2014.

IT IS HEREBY STIPLULATED AND AGREED between the undersigned counsel that the IPPs may file a motion to compel regarding the Hitachi Defendants' supplemental responses to the IPPs' Interrogatory Nos. 6, 7 (as it related to affirmative defenses Nos. 8, 13, 14, 19, 25, 27, 28, 32, 33, 34, 35 and 38), 10, 11, 13, 15, 16, 18, 22, 23 and/or 24; defendants HTL's, HDP's and HAS's supplement their responses to Interrogatory No. 8; and/or defendants HTL's and HDP's supplemental responses to Interrogatory No. 9, no later than October 3, 2014.

The undersigned Parties jointly and respectfully request that the Court enter this stipulation as an order.

PURSUANT TO STIPULATION, IT IS SO ORDERED.