JOINT STIPULATION REGARDING DISCOVERY COORDINATION AND [PROPOSED] ORDER

SUSAN ILLSTON, District Judge.

Plaintiff Mount Hamilton Partners, LLC ("Mount Hamilton") and Defendant Groupon, Inc. ("Groupon"), for the purpose of facilitating mutual discovery, respectfully request that this Court enter the following order as stipulated to by Mount Hamilton and Groupon in this action.

STIPULATION

WHEREAS, the parties in this action have agreed to measures to coordinate discovery and reduce duplication and inefficiency;

WHEREAS, the parties in the related action, Mount Hamilton partners, LLC v. Google Inc., Case No. 3:12-1698-SI (N.D. Cal.), recorded by stenographic and video means the depositions of Mr. Dazhi Chen and Ms. Elayna Berean, each a named inventor of the patent asserted by Mount Hamilton in this action;

NOW, THEREFORE, THE PARTIES STIPULATE AND AGREE that Groupon will be allowed to use at trial in this action the depositions of Mr. Chen and Ms. Berean in the matter of Mount Hamilton partners, LLC v. Google Inc., Case No. 3:12-1698-SI (N.D. Cal.), as if those depositions were transcribed and/or recorded by video in this action.

[PROPOSED] ORDER

This matter having come before the Court on the Stipulation and joint request of the Parties and good cause having been shown,

IT IS SO ORDERED that that Groupon will be allowed to use at trial in this action the depositions of Mr. Dazhi Chen and Ms. Elayna Berean in the matter of Mount Hamilton partners, LLC v. Google Inc., Case No. 3:12-1698-SI (N.D. Cal.), as if those depositions were transcribed and/or recorded by video in this action.