STIPULATION AND [PROPOSED] ORDER REGARDING SCHEDULING

SAMUEL CONTI, District Judge.

Plaintiffs Dell Inc. and Dell Products L.P. (collectively "Dell") and Defendants Koninklijke Philips N.V. and Philips Electronics North America Corporation (collectively "Philips") have conferred by and through their counsel and, subject to the Court's approval, HEREBY STIPULATE AS FOLLOWS:

WHEREAS, on July 30, 2014, Dell served its Second Set of Interrogatories and Second Set of Requests for Production on Philips.

WHEREAS, Philips responded and objected to Dell's Second Set of Interrogatories and Second Set of Requests for Production on September 2, 2014.

WHEREAS, Philips objected to Dell's Second Set of Interrogatories on the basis that Dell had exceeded its allotted 25 interrogatories as provided for under Federal Rule 33.

WHEREAS, other plaintiffs in the above-stated action have received discovery responses with similar objections and intend to file motions to compel with the Special Master challenging the defendants' calculation of the number of interrogatories received from the plaintiffs groups.

WHEREAS, September 5, 2014 was the deadline to complete fact discovery in the Dell action.

WHEREAS, September 12, 2014 is the deadline for all parties to object to or move to compel additional responses for all written discovery responses in the Dell action.

WHEREAS, Dell and Philips have agreed to await the Special Master's ruling on the proper method of calculating the number of interrogatories under Federal Rule 33 before evaluating whether Philips is required to provide more substantive responses to Dell's Second Set of Interrogatories.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED between counsel as follows: the deadline for Dell to move to compel additional responses for written discovery in the Dell action with respect to Dell's Second Set of Interrogatories shall be moved to fourteen days after any order by the Special Master addressing the proper method of calculating the number of interrogatories under Federal Rule 33. All other dates in the Scheduling Order are unaffected by this stipulation.

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

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Pursuant to Local Rule 5-1(i), the filer attests that the concurrence in the filing of this document has been obtained from each of the above signatories.