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STIPULATION AND [PROPOSED] ORDER RE AMENDMENT TO INDIRECT-PURCHASER PLAINTIFFS’ SECOND 

CONSOLIDATED AMENDED COMPLAINT

CASE NO. 3:07-MD-1827 

1

Francis O. Scarpulla (41059) 

ZELLE HOFMANN VOELBEL & MASON LLP 

44 Montgomery Street, Suite 3400 

San Francisco, CA 94104 

Telephone: (415) 693-0700 

Facsimile: (415) 693-0770 

fscarpulla@zelle.com 

Joseph M. Alioto 

THE ALIOTO LAW FIRM 

555 California Street, 31st Floor 

San Francisco, CA 94104 

Telephone: (415) 434-8900 

Facsimile: (415) 434-9200 

sexton@aliotolaw.com 

Co-Lead Class Counsel for Indirect-Purchaser 

Plaintiffs

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

IN RE: TFT-LCD (FLAT PANEL) 

ANTITRUST LITIGATION 

This Document Relates To: 

ALL INDIRECT-PURCHASER ACTIONS 

No. 3:07-md-1827 

MDL No. 1827 

STIPULATION AND [PROPOSED] 

ORDER REGARDING 

AMENDMENT TO INDIRECTPURCHASER PLAINTIFFS’ 

SECOND CONSOLIDATED 

AMENDED COMPLAINT 

Judge: Honorable Susan Y. Illston 

Crtrm: 10, 19th Floor 

TO THE COURT AND ALL PARTIES AND THEIR COUNSEL OF RECORD: 

IT IS HEREBY STIPULATED by and between the parties, INDIRECT PURCHASER 

PLAINTIFFS, and EPSON IMAGING DEVICES CORPORATION (collectively “the Parties”) 

and their respective counsel, and subject to the approval of the Court, that Indirect-Purchaser 

Case 3:07-md-01827-SI Document 1815 Filed 06/22/10 Page 1 of 4
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STIPULATION AND [PROPOSED] ORDER RE AMENDMENT TO INDIRECT-PURCHASER PLAINTIFFS’ SECOND 

CONSOLIDATED AMENDED COMPLAINT

CASE NO. 3:07-MD-1827 

2

Plaintiffs’ Second Consolidated Amended Complaint (“Complaint”), filed December 5, 2008 

(Dkt. No. 746), be deemed amended as follows. 

1. New Paragraph 95A shall state: “Defendant Epson Imaging Devices Corporation 

(“EID”) is a Japanese Company with its principal place of business in Tottori, Japan. EID was 

originally formed as Sanyo Epson Imaging Devices Corporation on October 1, 2004 as a joint 

venture co-owned by Seiko Epson Corporation and Sanyo Electric Co., Ltd. As of December 28, 

2006, Sanyo Epson Imaging Devices Corporation became a wholly-owned subsidiary of Seiko 

Epson Corporation and changed its name to EID. During the Class Period EID manufactured, 

sold and/or distributed LCD panels to customers throughout the United States.” 

2. Paragraph 98 is amended to delete the reference to “Epson Imaging Devices 

Corporation.”

3. All references to “defendants” in the Complaint, except as the term is used to 

describe a specifically-named defendant or defendants other than EID, shall be deemed to include 

EID.

Dated: June 21, 2010 FRANCIS O. SCARPULLA 

ZELLE HOFMANN VOELBEL 

& MASON LLP 

JOSEPH M. ALIOTO 

THE ALIOTO LAW FIRM 

By: /s/ Francis O. Scarpulla

Francis O. Scarpulla 

Co-Lead Class Counsel for IndirectPurchaser Plaintiffs 

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STIPULATION AND [PROPOSED] ORDER RE AMENDMENT TO INDIRECT-PURCHASER PLAINTIFFS’ SECOND 

CONSOLIDATED AMENDED COMPLAINT

CASE NO. 3:07-MD-1827 

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Dated: June 21, 2010 MELVIN R. GOLDMAN 

STEPHEN P. FRECCERO 

DEREK F. FORAN 

MORRISON & FOERSTER LLP

By: /s/ Stephen P. Freccero

Stephen P. Freccero 

Attorneys for Counsel for Defendants 

Seiko Epson Corporation; Epson 

Imaging Devices Corporation; Epson 

Electronics America, Inc. 

Attestation: Pursuant to General Order No. 45, the filer attests that concurrence in the filing of 

this document has been obtained from each of the signatories.

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STIPULATION AND [PROPOSED] ORDER RE AMENDMENT TO INDIRECT-PURCHASER PLAINTIFFS’ SECOND 

CONSOLIDATED AMENDED COMPLAINT

CASE NO. 3:07-MD-1827 

4

[PROPOSED] ORDER 

Pursuant to the stipulation of the parties, IT IS SO ORDERED. 

Dated: ____________________ 

HONORABLE SUSAN ILLSTON 

United States District Judge

Case 3:07-md-01827-SI Document 1815 Filed 06/22/10 Page 4 of 4