STIPULATION AND [PROPOSED] ORDER REGARDING CASE CONSOLIDATION

RICHARD G. SEEBORG, District Judge.

WHEREAS, Crowell & Moring LLP ("Crowell") filed a lawsuit on behalf of Hewlett-Packard Company ("HP"), entitled Hewlett-Packard Company v. Toshiba Corp., et al., No. 3:13-cv-05370-RS (N.D. Cal.) (the "First HP Lawsuit"), which alleges that certain defendants engaged in a price-fixing conspiracy involving optical disk drives ("ODDs");

WHEREAS, Bartlit Beck Herman Palenchar & Scott LLP ("Bartlit") filed a lawsuit on behalf of HP, entitled Hewlett-Packard Company v. LG Electronics, Inc., et al., No. 3:13-cv-05371-RS (N.D. Cal.) (the "Second HP Lawsuit"), which alleges that certain other defendants engaged in a price-fixing conspiracy involving ODDs;

WHEREAS, defendants in the First HP Lawsuit and Second HP Lawsuit deny the allegations that they engaged in a price-fixing conspiracy involving ODDs;

WHEREAS, the First HP Lawsuit and Second HP Lawsuit each allege that the defendants in each lawsuit participated in the same alleged conspiracy with each other;

WHEREAS, certain defendants in the Second HP Lawsuit filed a Motion to Consolidate the First HP Lawsuit and Second HP Lawsuit (Case No. 3:13-cv-05371-RS, Docket No. 36);

WHEREAS, HP opposed the Motion to Consolidate (Case No. 3:13-cv-05371-RS, Docket No. 47) and the Court denied the motion (Case No. 3:13-cv-05371-RS, Docket No. 52);

WHEREAS, Crowell has since been substituted for Bartlit as HP's counsel in the Second HP Lawsuit (Case No. 3:13-cv-05371-RS, Docket No. 61);

WHEREAS, HP now seeks to consolidate the First HP Lawsuit and Second HP Lawsuit and defendants do not oppose;

WHEREAS, consolidation of the First HP Lawsuit and Second HP Lawsuit pursuant to Federal Rule of Civil Procedure 42(a) will promote judicial efficiency going forward;

NOW THEREFORE, IT IS HEREBY STIPULATED by and between the undersigned counsel for the parties as follows:

IT IS SO STIPULATED.

FILER ATTESTATION

Pursuant to Rule 5-1(i)(3) of the Local Rules of Practice in Civil Proceedings Before the United States District Court for the Northern District of California, I, Beatrice B. Nguyen, hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

CERTIFICATE OF SERVICE

In accordance with Rule 5-5 of the Local Rules of Practice in Civil Proceedings Before the United States District Court for the Northern District of California, I, Beatrice B. Nguyen, hereby certify under penalty of perjury under the laws of the United States of America that on December 21, 2015, a true copy of the above document was filed through the Court's Case Management/Electronic Case Filing ("CM/ECF") System and served by that System upon all counsel of record registered for the System and deemed to have consented to electronic service in the above-captioned case. Any other counsel of record will be served by electronic mail and/or first-class mail on the same date.