STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE FOR PHILIPS TAIWAN LIMITED'S AND PHILIPS DO BRASIL LTDA.'S MOTION TO DISMISS FOR INSUFFICIENT SERVICE OF PROCESS AND LACK OF PERSONAL JURISDICTION

SAMUEL CONTI, District Judge.

WHEREAS, the Indirect Purchaser Plaintiffs ("IPPs") filed a Fourth Consolidated Amended Complaint on January 10, 2013 in the United States District Court for the Northern District of California against Defendants Philips Taiwan Limited and Philips do Brasil Ltda.1 (collectively the "Philips Defendants"), among others;

WHEREAS, the Philips Defendants intend to file a Notice of Motion and Motion to Dismiss the IPPs' Fourth Consolidated Amended Complaint for Insufficient Service of Process and Lack of Personal Jurisdiction (the "Motion to Dismiss") and to notice the Motion to Dismiss for a hearing on May 30, 2014;

WHEREAS, counsel for the Philips Defendants and counsel for the IPPs have met and conferred and have agreed upon a mutually acceptable briefing schedule relating to the Philips Defendants' Motion to Dismiss;

IT IS HEREBY STIPULATED AND AGREED by and between the Philips Defendants and the IPPs that:

1. The Philips Defendants shall file their Notice of Motion and Motion to Dismiss the IPPs' Fourth Consolidated Amended Complaint for Insufficient Service of Process and Lack of Personal Jurisdiction (the "Motion to Dismiss") on or before March 26, 2014;

2. IPPs shall submit their Opposition to the Philips Defendants' Motion to Dismiss on or before April 14, 2014; and

3. The Philips Defendants shall file their Reply Brief in support of their Motion to Dismiss on or before April 24, 2014.

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

PURSUANT TO STIPULATION, IT IS SO ORDERED.