SUPPLEMENTAL STIPULATED PROTECTIVE ORDER GOVERNING THE EXCHANGE AND HANDLING OF CONFIDENTIAL AND HIGHLY CONFIDENTIAL MATERIALS AND SOURCE CODE AND SOURCE CODE RELATED MATERIAL

JAMES V. SELNA, District Judge.

WHEREAS, In Re: Toyota Motor Corp. Unintended Acceleration Marketing, Sales Practices, and Products Liability Litigation was commenced in the State of California ("the U.S. MDL");

WHEREAS, the Protective Order for the Protection of Confidential and Highly Confidential Materials (the "Protective Order") has been in effect since January 19, 2011 and the First Amended Stipulated Protective Order Governing the Exchange and Handling of Source Code and Source Code Related Material ("SCPO") has been in effect since November 16, 2011;

WHEREAS, the Protective Order and SCPO address the production and use of Confidential, Highly Confidential, and Highly Confidential-Source Code Material in the U.S. MDL;

WHEREAS, the action Selmani and Celaj v. Toyota Motor Corporation et al., court file number CV-10-401396-00CP was commenced in Ontario, Canada on April 29, 2010 ("the Ontario action");

WHEREAS, Plaintiffs in the Ontario action have engaged experts who have signed or will sign the "Agreement Concerning Information Covered by Stipulated Protective Order" and the "Agreement Concerning Information Covered by Protective Order" attached to the Protective Order as Exhibit A;

WHEREAS, Plaintiffs in the Ontario action have engaged certain experts who have previously been designated by MDL Plaintiffs to receive access to Source Code and Source Code Related Materials as defined by the SCPO, in the course of the U.S. MDL; and

WHEREAS, to submit expert evidence to pursue certification and to prosecute the Ontario action to trial, the Plaintiffs of the Ontario action require a supplemental order in this Court to the Protective Order and SCPO.

WHEREAS, Plaintiffs of the Ontario action will also submit appropriate orders in the Ontario Courts to ensure the equivalent protections of Confidential, Highly Confidential and Highly Confidential — Source Code Material in the Ontario action, including, but not limited to ensuring protection through expert rebuttal reports, expert cross-examination, filing of class certification papers and through prosecution at trial.

Accordingly, IT IS HEREBY ORDERED that the terms and conditions of the Protective Order and SCPO shall not exclude the Ontario action but instead shall govern the exchange of confidential and highly confidential materials and source code and source code related materials, as defined in the Protective Order and SCPO, in the Ontario action.

IT IS SO ORDERED.