**IN THE UNITED DISTRICT COURT**

**FOR THE NORTHERN DISTRICT OF ILLINOIS**

**EASTERN DIVISION**

**UNITED STATES OF AMERICA, )**

**)**

**Plaintiff, )**

**) Filed: April 21, 2008**

**v. ) Civ. No. 58-C-1159**

**)**

**TRUE TEMPER CORPORATION; )**

**WILSON ATHLETIC GOODS MFG. CO., )**

**INC.; A.G. SPALDING & BROS., INC.; )**

**MACGREGOR SPORT PRODUCTS, INC. )**

**AND HILLERICH & BRADSBY CO., )**

**)**

**Defendants. )**

**\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
)**

**STIPULATION**

> It is stipulated by and between the undersigned parties, by their
> respective attorneys, that:

1\. True Temper Sports, Inc. (\"True Temper\"), successor in interest to
defendant True Temper Corporation, will file a motion requesting that
the Court terminate the Final Judgment entered by this Court on August
1, 1961 (\"1961 Final Judgment\") in the above-captioned matter. The
United States tentatively has agreed to termination of the 1961 Final
Judgment.

2\. True Temper shall publish at its own expense a notice of the
proposed termination, in the form attached hereto as Exhibit A, in (a)
two consecutive issues of *The Wall Street Journal* and (2) two
consecutive issues of *Golf World*. An Order, in the form attached
hereto as Exhibit B, directing such publication, may be filed and
entered by the Court forthwith, without any further notice to any party
or any other proceedings.

3\. The United States will publish in the *Federal Register* a notice,
in the form attached hereto as Exhibit C, announcing the motion to
terminate the 1961 Final Judgment and the United States\' tentative
consent to the motion, summarizing the Complaint and the 1961 Final
Judgment, describing the procedures for inspection and obtaining copies
of relevant papers, and inviting the submission of comments.

4\. A period for public comment shall end sixty days after the last
publication of the notices required by this Stipulation. Within a
reasonable time after the conclusion of the sixty-day public comment
period, the United States will file with the Court copies of all
comments that it receives and its response to those comments.

5\. An Order, a proposed form of which is attached hereto as Exhibit D,
terminating the 1961 Final Judgment, may be filed and entered by the
Court upon the request of any party, or by the Court *sua sponte,* at
any time after the United States has filed with the Court any comments
that it receives and any responses thereto and without further notice to
any party or any other proceedings, provided that the United States has
not withdrawn its tentative consent. The United States may withdraw its
tentative consent at any time before the entry of an Order terminating
the 1961 Final Judgment by filing a notice of withdrawal of its consent
with the Court and serving a copy of said notice upon all other parties.

6\. In the event the United States withdraws its consent, or if the
proposed Order terminating the 1961 Final Judgment is not entered
pursuant to this Stipulation, then this Stipulation shall be of no
effect whatsoever; the making of this Stipulation shall be without
prejudice to any party in this or any other proceeding; and the
Stipulation shall not thereafter be used in this or any other action or
for any other purpose.

Dated: April 15, 2008

FOR PLAINTIFF

UNITED STATES OF AMERICA

\_\_\_\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

THOMAS O. BARNETT ROSEMARY SIMOTA THOMPSON

Assistant Attorney General Attorney for the United States

United States Department of Justice

Antitrust Division

209 South LaSalle Street, Suite 600

\_\_\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Chicago, Illinois 60604

DAVID L. MEYER (312) 353-7530

Deputy Assistant Attorney General (312) 353-1046 (facsimile)

\_\_\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

PATRICIA A. BRINK

Deputy Director of Operations

\_\_\_\_\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

MARVIN N. PRICE, JR.

Chief, Chicago Field Office

FRANK J. VONDRAK

Assistant Chief, Chicago Field Office

Dated: April 8, 2008

FOR TRUE TEMPER SPORTS, INC.

\_\_\_\_/s/\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

ROBERT E. HAUBERT, JR.

JOHN G. CALENDER

Baker, Donelson, Bearman, Caldwell &

Berkowitz, P.C.

555 Eleventh Street, N.W., Sixth Floor

Washington, DC 20004

\(202\) 508-3474

\(202\) 220-2274