STIPULATION AND [PROPOSED] ORDER C09-01151 JSW (BZ) 

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DANIEL J. BERGESON, Bar No. 105439 

dbergeson@be-law.com 

MELINDA M. MORTON, Bar No. 209373 

mmorton@be-law.com 

BERGESON, LLP 

303 Almaden Boulevard, Suite 500 

San Jose, CA 95110-2712 

Telephone: (408) 291-6200 

Facsimile: (408) 297-6000 

R. TERRANCE RADER, Esq., (Pro Hac Vice) 

rtr@raderfishman.com 

THOMAS E. BEJIN, Esq., (Pro Hac Vice) 

teb@raderfishman.com 

RADER, FISHMAN & GRAUER PLLC 

39533 Woodward Ave., Suite 140 

Bloomfield Hills, Michigan 48304 

Telephone: (248) 594-0600 

Facsimile: (248) 594-0610 

Attorneys for Defendant 

NATIONAL SEMICONDUCTOR CORPORATION 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

GREGORY BENDER, an individual, 

Plaintiff, 

 vs. 

NATIONAL SEMICONDUCTOR 

CORPORATION, a Delaware corporation, 

Defendant. 

Case No. C09-01151 JSW (BZ) 

STIPULATION AND [PROPOSED] ORDER 

RE: SUPPLEMENTAL INFRINGEMENT 

CONTENTIONS 

Judge: Hon. Jeffrey S. White 

Ctrm: 11 

Date Filed: March 16, 2009 

Trial Date: None 

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STIPULATION AND [PROPOSED] ORDER C09-01151 JSW (BZ) 

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Plaintiff Gregory Bender (“Bender”) served infringement contentions on Defendant National 

Semiconductor Corporation (“National Semiconductor”) on February 19, 2010. National 

Semiconductor contended that Bender’s infringement contentions failed to comply with Patent L.R. 3-

1. In accordance with Magistrate Judge Zimmerman’s Initial Discovery Order dated February 9, 2010, 

Bender and National Semiconductor conducted a tape-recorded meet and confer on April 8, 2010 

regarding the issue of compliance with Patent L.R. 3-1. Following the meet and confer, Bender agreed 

that he will provide supplemental infringement contentions by May 20, 2010 that are compliant with 

Patent L.R. 3-1 and include information regarding the accused products in accordance with Judge 

Patel’s order dated March 23, 2010 in Bender v. Broadcom (entered as D.I. 49 in Northern District of 

California, Civil Case Number 3:09-cv-01147-MHP). 

THE PARTIES HEREBY STIPULATE THAT: 

Plaintiff shall provide supplemental infringement contentions by May 20, 2010 that comply 

with Patent L.R. 3-1 and include the following information: 

 a) A detailed description of the information that plaintiff, plaintiff’s counsel, or his expert(s) 

reviewed and analyzed in order to prepare the initial and the supplemental infringement contentions, 

including all efforts made to acquire, inspect, reverse engineer, or study the accused products. 

b) A detailed description of the similarities between any “representative” products and the 332 

accused products that they allegedly represent. 

As previously set forth in this Court’s Order dated March 31, 2010, National Semiconductor is 

relieved from its obligations under Patent L.R. 3-3 and 3-4 until 45 days following the final resolution 

of the issue regarding whether Bender’s infringement contentions or supplemental infringement 

contentions comply with Patent L.R. 3-1. 

/// 

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STIPULATION AND [PROPOSED] ORDER C09-01151 JSW (BZ) 

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 

Dated: April 16, 2010 BERGESON, LLP 

By: /s/ 

Melinda M. Morton, Esq. 

Attorneys for National Semiconductor 

In accordance with General Order No. 45, Rule X, the above signatory attests that 

concurrence in the filing of this document has been obtained from the signatory below. 

Dated: April 16, 2010 DAVID N. KUHN 

By: /s/ 

David N. Kuhn, Esq. 

Attorney for Bender 

ORDER

In accordance with the foregoing stipulation of the parties, the Court enters the Stipulation 

as an Order of the Court. 

IT IS SO ORDERED. 

Dated: ______________, 2010 By: __________________________ 

 Honorable Jeffrey S. White 

 United States District Judge 

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