STIPULATION FOR PERMANENT INJUNCTION AND ENTRY OF JUDGMENT AND [PROPOSED] JUDGMENT AND PERMANENT INJUNCTION

JON S. TIGAR, District Judge.

STIPULATION

Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Deepak Sabharwal ("Sabharwal") have entered into a confidential settlement agreement in order to resolve this action. The settlement agreement requires, among other things, the entry of a permanent injunction. Synopsys and Sabharwal stipulate to the entry of a permanent injunction as follows:

Pursuant to California Civil Code § 3426.2(a) and (c), 17 U.S.C. §§ 502, et seq., and California Business and Professions Code §§ 17200 et seq., Sabharwal and any of his employees, employers, agents, representatives, and persons in active concert or participation with him, who have actual notice of this injunction, commencing on the date hereof are permanently restrained and enjoined from:

1. Failing to return to Synopsys any equipment or materials containing Synopsys confidential, proprietary, and/or trade secret information within 30 days. Sabharwal submits that he has returned any and all confidential and proprietary information belonging to Synopsys.

2. Possessing, using, disclosing, transferring, or copying to any person or entity including but not limited to ARM any Synopsys confidential, proprietary, and/or trade secret information. Sabharwal denies disclosing any Synopsys confidential information to any others at ARM.

3. Reproducing, preparing derivative works based on, or distributing copies of any Synopsys design sheets, manuals, or other documents that are copyrightable subject matter under 17 U.S.C. § 101, except matter properly in the public domain and authorized by Synopsys for such use.

4. Committing an unlawful, unfair, and fraudulent business acts by using Synopsys property for business purposes after his employment with Synopsys terminated.

Synopsys and Sabharwal stipulate that each side shall bear its own fees and costs and further stipulate and consent to the jurisdiction of this Court for the sole purpose of enforcing the injunction as by contempt proceedings.

Filer Attestation

Pursuant to Local Rule 5-1, I hereby attest under penalty of perjury that concurrence in the filing of the document has been obtained from its signatory.

[PROPOSED] PERMANENT INJUNCTION

The Court, having considered the Stipulation for Permanent Injunction of Plaintiff Synopsys, Inc. ("Synopsys") and Defendant Deepak Sabharwal ("Sabharwal"), hereby grants the Stipulation, and now therefore:

IT IS HERBY ORDERED, ADJUDGED AND DECREED that:

Defendant Deepak Sabharwal ("Sabharwal") and any of his employees, employers, agents, representatives, and all those in active concert or participation with him are permanently restrained and enjoined from:

1. Failing to return to Synopsys any equipment or materials containing Synopsys confidential, proprietary, and/or trade secret information within 30 days.

2. Possessing, using, disclosing, transferring, or copying to any person or entity including but not limited to ARM any Synopsys confidential, proprietary, and/or trade secret information.

3. Reproducing, preparing derivative works based on, or distributing copies of any Synopsys design sheets, manuals, or other documents that are copyrightable subject matter under 17 U.S.C. § 101, except matter properly in the public domain and authorized by Synopsys for such use.

4. Committing an unlawful, unfair, and fraudulent business acts by using Synopsys property for business purposes after his employment with Synopsys terminated. The Court shall retain jurisdiction solely to enforce the injunction as by contempt