STIPULATION AND [PROPOSED] ORDER REGARDING WAIVER OF SERVICE AND EXTENSION OF TIME TO RESPOND TO COMPLAINTS

SAMUEL CONTI, District Judge.

WHEREAS, Plaintiffs Costco Wholesale Corporation (No. 13-cv-02037, W.D. Wash.); Alfred H. Siegel, as Trustee of the Circuit City Stores, Inc. Liquidating Trust (No. 13-cv-05261, N.D. Cal.); Best Buy Co., Inc., Best Buy Purchasing LLC, Best Buy Enterprise Services, Inc., Best Buy Stores, L.P., BestBuy.com, L.L.C., and Magnolia Hi-Fi, LLC (No. 13-cv-05264, N.D. Cal.); P.C. Richard & Son Long Island Corporation, Marta Cooperative of America, Inc., and ABC Appliance, Inc. (No. 13-cv-06327, E.D.N.Y.); Electrograph Systems, Inc., and Electrograph Technologies Corp. (13-cv-06325, E.D.N.Y.); Schultze Agency Services, LLC (No. 13-cv-06323, E.D.N.Y.); Office Depot, Inc. (No. 13-cv-81174, S.D. Fla.); Interbond Corporation of America (No. 13-cv-62482, S.D. Fla.); Sears, Roebuck and Co. and Kmart Corp. (No. 13-cv-05262, N.D. Cal.); and Target Corp. (No. 13-cv-05686, N.D. Cal.) (collectively "Direct Action Plaintiffs") filed complaints in the above-referenced actions against, among others, Technicolor SA (f/k/a Thomson SA) and Technicolor USA, Inc. (f/k/a Thomson Consumer Electronics, Inc.) (collectively "Thomson Defendants");

WHEREAS, the above-referenced out-of-district actions were transferred to the In re Cathode Ray Tube (CRT) Multidistrict Litigation in the United States District Court for the Northern District of California, MDL No. 1917, on December 4, 2013 (Dkt. No. 2244);

WHEREAS, the Direct Action Plaintiffs wish to avoid the burden and expense of serving process on the Thomson Defendants and the Thomson Defendants desire a reasonable amount of time to respond to Plaintiffs' Complaints;

WHEREAS, Thomson SA has moved to dismiss the First Amended Complaint of Sharp Electronics Corporation and Sharp Electronics Manufacturing Company of America, Inc. (collectively "Sharp Plaintiffs") (Dkt. No. 2235);

WHEREAS, Thomson Consumer Electronics, Inc., has separately moved to dismiss the Sharp Plaintiffs' First Amended Complaint (Dkt. No. 2236);

WHEREAS, the Direct Action Plaintiffs and the Thomson Defendants believe that proceeding on a unified response date after the Court has ruled on the Thomson Defendants' motions to dismiss the Sharp Plaintiff's First Amended Complaint will create efficiency for the Court and for the parties;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and among the undersigned counsel, on behalf of their respective clients, as follows:

1. Pursuant to Federal Rule of Civil Procedure 4(d), the Thomson Defendants waive service of the Complaints filed by the Direct Action Plaintiffs.

2. Technicolor USA, Inc.'s (f/k/a Thomson Consumer Electronics, Inc.) deadline to move to dismiss, answer, or otherwise respond to the Direct Action Plaintiffs' Complaints will be the later of (1) February 4, 2014, or (2) thirty days after the Court enters an order on Thomson Consumer Electronics, Inc.'s Motion to Dismiss the Sharp Plaintiffs' First Amended Complaint;

3. Technicolor SA's (f/k/a Thomson SA) deadline to move to dismiss, answer, or otherwise respond to the Direct Action Plaintiffs' Complaints will be the later of (1) March 6, 2014, or (2) thirty days after the Court enters an order on Thomson SA's Motion to Dismiss the Sharp Plaintiffs' First Amended Complaint;

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

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.