EX-10.20





 Exhibit
10.20                    
 EXECUTION
VERSION 
 SETTLEMENT AGREEMENT 

This SETTLEMENT AGREEMENT (the “Agreement”) is entered into by and between Power Integrations, Inc., a
Delaware corporation with an office at 5245 Hellyer Avenue, San Jose, California 95138 (together with its Affiliates, as defined below, “PI”), and ON Semiconductor Corporation, a Delaware corporation with an office at 5005 East
McDowell Road, Phoenix, Arizona 85008 (together with its Affiliates, “ON”), as of October 19, 2019 (the “Effective Date”). 
  

	1.	 Definitions. 



“Acquirer” means the person or entity or group of persons or entities acquiring the stock or assets of a Party (or otherwise assuming
control of a Party) in a Change of Control Transaction. 
 “Affiliate(s)” of a Party means any and all Entities, past,
present, or future, that are or were Controlled, directly or indirectly, by the Party, but only for so long as such Control exists or existed. 

“Agreement” shall have the meaning ascribed to it in the preamble. 

“Assert” (or “Assertion”) means bringing, commencing, filing, prosecuting, or otherwise instituting, or
funding, encouraging or assisting any third party in bringing, commencing, filing, prosecuting, or otherwise instituting, any patent infringement claim, petition for declaratory judgment of non-infringement of
any patent, or other proceeding alleging infringement or non-infringement, invalidity, or unenforceability of any patent before any legal, judicial, arbitral, administrative, executive, or other body or
tribunal, anywhere in the world, that has or claims to have authority to adjudicate such claim, including without limitation any court or arbitral body, the U.S. International Trade Commission, the U.S. Patent and Trademark Office, the Chinese
Patent Office, the Taiwan Patent Office, and the European Patent Office. 
 “Binding Term Sheet” means the Binding Term
Sheet by and between the Parties executed on October 2, 2019. 
 “Change of Control” means the transfer, assignment, sale,
lease, loan, or other disposition of any material portion of the tangible or intangible assets, personnel, technology, equipment, or business, equity interest, or voting interest of a Party that are related to this Agreement. 

“Change of Control Transaction” means a single transaction, or a transaction that is part of a series of transactions (including a merger and
a triangular merger) to effect a Change of Control. 
 “Control” means the legal, beneficial, or equitable ownership of more than fifty
percent (50%) of (i) the voting power representing the right to vote for directors or other managing authority, (ii) equity ownership interest in an Entity, or (iii) other ownership interest in an Entity. 

“Cooling Off Period” shall mean the period commencing on the Effective Date and continuing for a period of three
(3) years from the Release Date. 
 “Effective Date” shall have the meaning ascribed to it in the preamble. 

  
 1 














 EXECUTION VERSION 
  

 

 “Entity” means a corporation, association, partnership, business trust,
joint venture, limited liability company, proprietorship, unincorporated association, or other entity that can exercise independent legal standing. 

“Fee” means One Hundred Seventy-Five Million United States Dollars (US$175,000,000), subject to Section 5. 

“ON” shall have the meaning ascribed to it in the preamble. 

“Party” means PI or ON and “Parties” means PI and ON. 

“Pending Proceedings” means the proceedings set forth in Exhibit A, some of which are further classified therein as either
“Fairchild Legal Proceedings” or “ON Semi Legal Proceedings.” 
 “PI” shall have the meaning ascribed to it in the
preamble. 
 “Released Claims” means any and all claims and judgments for damages or monetary relief for acts of patent infringement
asserted in any of the Pending Proceedings occurring on or before the Release Date. 
 “Release Date” means June 30, 2020. 

2.        Dismissals. Within five (5) business days after PI has received the Fee, the Parties shall
jointly submit to the relevant court or administrative body a document in the applicable form attached hereto as Exhibits C through L in order to withdraw, dismiss, or terminate (with or without prejudice as reflected in the applicable form) all
claims made and judgments entered in the Pending Proceedings, including appeals therefrom, and the Parties will cooperate to terminate each such proceeding. The Parties intend and will request that each Fairchild Legal Proceeding will be dismissed
with prejudice and that each ON Semi Legal Proceeding will be dismissed without prejudice. For the IPRs and associated appeals listed in Exhibit A, (1) for any IPRs having a pending appeal to the Federal Circuit, the Parties will jointly
request the appeal be dismissed, (2) for any IPRs for which the final written decision has been vacated by the Federal Circuit, the Parties will jointly request that the IPR be dismissed per the applicable order of the Federal Circuit, and
(3) for any IPR that is currently pending before the PTAB, the Parties will jointly request termination. 

3.        Mutual Releases. Contingent upon ON’s performance under Section 5, PI does
hereby for itself and its Affiliates irrevocably and forever release and absolutely discharge (a) ON, including its Affiliates, and their respective employees, representatives, agents, officers, directors, past, present, and future, of and from
any and all Released Claims, and (b) each of the direct and indirect distributors, resellers, representatives, customers, and end users of ON, including its Affiliates, of and from any and all Released Claims to the extent directed to a product
of ON, including its Affiliates. ON does hereby for itself and its Affiliates irrevocably and forever release and absolutely discharge (a) PI, including its Affiliates, and their respective employees, representatives, agents, officers,
directors, past, present, and future, of and from any and all Released Claims, and (b) each of the direct and indirect distributors, resellers, representatives, customers, and end users of PI, including its Affiliates, of and from any and all
Released Claims to the extent directed to a product of PI, including its Affiliates. The Parties acknowledge and 

  
 2 














 EXECUTION VERSION 
  

 

 
agree that this Agreement fully and finally releases and forever resolves the Released Claims that are unknown, unanticipated, or unsuspected or that may hereafter arise as a result of the
discovery of new or additional facts. The Parties acknowledge and understand the significance and potential consequence of the release of unknown claims. The Parties intend that the Released Claims released under this Agreement be construed as
broadly as possible and agree to waive and relinquish all rights and benefits each may have under Section 1542 of the Civil Code of the State of California, or any similar statute or law of any other jurisdiction, with respect to the Released
Claims. Section 1542 reads as follows: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM
OR HER WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.” 

4.        Standstill. Each Party represents and warrants as of the Effective Date that it has not made any new
Assertion that is not identified in Exhibit A, which each Party represents contains an up-to-date list of all Assertions by either Party as of the Effective Date. Each
Party further represents and warrants as of the Effective Date that it has no knowledge of any Assertion outside the United States by a third-party Entity or individual against the other Party, other than the assertions identified in Exhibit A and
other than the assertion initiated by Huizhou Jinhu Industrial Development Co., Ltd. with respect to the Chinese patent number ZL200410061704.6. Provided that PI has received the Fee, during the Cooling Off Period, neither Party nor any of its
Affiliates shall make any Assertion against the other Party or any of its Affiliates. Further, provided that PI has received the Fee, neither Party, nor any of its Affiliates, during the Cooling Off Period will make any Assertion against any direct
or indirect distributor, representative, reseller, customer, or end user of the other Party to the extent based on an allegation of patent infringement directed to a product of the other Party. The foregoing constitutes a limited, non-exhaustive standstill during the Cooling Off Period only and not a license, release, or other intellectual property right or immunity. For the avoidance of doubt and without limitation, after the end of the
Cooling Off Period, a Party is not precluded by this Agreement from filing suit, seeking recovery of damages occurring during or after the Cooling Off Period for alleged or actual infringement, or from seeking an injunction against future
infringement occurring after the Cooling Off Period, subject to all applicable laws anywhere in the world, including 35 U.S.C. § 286 and other applicable statutes of limitations. For the further avoidance of doubt, the absence of an Assertion
during the Cooling Off Period shall not be relied on by either Party as a basis for a denial of an injunction. Notwithstanding the foregoing, a Party may initiate a challenge to the validity and enforceability of any patent Asserted against such
Party or any of its Affiliates, or against any of their respective products during the Cooling Off Period. Each Party agrees that breach of this Section 4 by one Party will cause irreparable harm and significant injury to the other Party, the
extent of which will be difficult to ascertain and for which there will be no adequate remedy at law. Accordingly, each Party agrees that the other Party, in addition to any other available remedies, shall have the right to an immediate injunction
and other equitable relief enjoining any breach or threatened breach of this Section 4 without the necessity of posting any bond or other security and the court may dismiss or terminate the claims brought in violation of this Section 4
without prejudice to Assertion after the Cooling Off Period. Neither Party may assign or otherwise transfer any of its rights under any patents the Assertion of which is subject to this Section 4 unless such assignment or transfer is expressly
made subject to this Agreement. The Parties agree that during the Cooling Off Period they will not manufacture or sell copies of 

  
 3 














 EXECUTION VERSION 
  

 

 the other Party’s products derived from reverse engineering at the schematic level (copying to be
determined at the overall product level, and not just with reference to a single feature or subset of features) provided that this sentence shall in no case apply to (a) a Party’s products that were on sale or otherwise publicly announced
prior to or as of the Effective Date, or (b) a Party’s products that were accused of infringement in any of the Pending Proceedings. 

5.        Payment. Semiconductor Components Industries, LLC, an Affiliate of ON Semiconductor Corporation, will
pay Power Integrations, Inc. the Fee no later than October 23, 2019, via electronic transfer to the following account: 
  

									
	
                    
	 	 Bank Name:
	  	 [Redacted]
	  		  	
		 	 SWIFT Code:
	  	 [Redacted]
	  		  	
		 	 ABA#:
	  	 [Redacted]
	  		  	
		 	 Account Name:
	  	 [Redacted]
	  		  	
		 	 Account Number:
	  	 [Redacted]
	  		  	

 The Fee is non-refundable and constitutes the complete monetary
consideration for PI to enter into this Agreement and complete satisfaction for any and all judgments entered in the Pending Proceedings. 

6.        No Admission of Liability. The Parties agree that the settlement of the Released
Claims is intended solely as a compromise of the disputed claims, and without any acknowledgment of liability, fault, damages, or any other merits of the Released Claims and the Pending Proceedings. Nothing in this Agreement shall extinguish,
impair, or otherwise affect any defense or position of PI or ON that patents are not infringed, invalid, or not enforceable, or that any claims are barred by equitable estoppel, implied license, statute of limitation, or laches. Nor shall this
Agreement be admissible in any legal proceeding as a basis to claim infringement or non-infringement of any patent. Neither Party is waiving any argument or position (now or in the future) that any order,
ruling or judgment that is currently the subject of any pending appeal that is being dismissed with or without prejudice in connection with the Settlement was in error. 

7.        No License. Nothing contained in this Agreement shall be construed as conferring or
granting by implication, estoppel or otherwise, any right or license, express or implied, under any patent, copyright, mask work, trade name, trademark, service mark, trade secret right, other identification of source or origin belonging to the
other Party, other proprietary right or other intellectual property right, whether now existing or hereafter obtained, and no such license or other right shall arise from this Agreement or from any acts or omissions in connection with the execution
of this Agreement or the performance of the obligations of the Parties hereunder. 

8.        Payment of Costs and Expenses. Each Party shall be responsible for payment of its own
attorneys’ fees and other costs, disbursements and expenses arising out of or relating to the Parties’ legal proceedings through the Effective Date. 

9.        Notices. Any notice or communication required or permitted to be given by either
Party hereunder shall be in written form and shall be considered to be sufficiently given if transmitted and confirmed by overnight courier, addressed to the Parties hereto as follows: 

 To PI: 

  
 4 














 EXECUTION VERSION 
  

 

 Power Integrations, Inc. 

5245 Hellyer Avenue 

San Jose, California 95138 

ATTN:  President 

With copy to: 

Fish & Richardson 

One Marina Park Drive 

Boston, Massachusetts 02210 

ATTN: Frank E. Scherkenbach 

To ON: 

ON Semiconductor Corporation 

5005 East McDowell Road 

Phoenix, Arizona 85008 

ATTN:  Vice President and Chief IP Counsel 

With copy to: 

Morrison & Foerster LLP 

755 Page Mill Road 

Palo Alto, California 94304 

ATTN:  Colette Reiner Mayer 

or to such changed address as the addressee shall have specified by written notice in accordance with this provision. 

10.        Governing Law. The Parties hereto agree that this Agreement shall be considered to have been made
in, and construed and interpreted in accordance with the substantive laws of Delaware. The Parties consent to the exclusive jurisdiction of the United States District Court for the District of Delaware to resolve any disputes relating to or arising
out of this Agreement and agree to have that court retain jurisdiction to enforce the terms of the Agreement as part of the Parties’ dismissal papers; provided, however, that any Party against whom an action is brought may, at its sole
election, assert a claim arising from this Agreement as a defense or counterclaim in such an action and, in those circumstances, the court in that action shall also have jurisdiction to resolve the asserted defense or counterclaim based on this
Agreement and to provide an appropriate remedy. 
 11.        Representations and Warranties.
Each of Power Integrations, Inc. and ON Semiconductor Corporation represents and warrants that it is a corporation in good standing under the laws of the state of Delaware; that it has the authority to enter into this Agreement; and that this
Agreement is valid, binding and enforceable in accordance with its terms. Each of Power Integrations, Inc. and ON Semiconductor Corporation further represents and warrants that it has sufficient right, title, and interest to grant the releases and
enter into the standstill set forth in this Agreement. 

  
 5 














 EXECUTION VERSION 
  

 

 12.        408+ Agreement Modification. Each
Party agrees that the Binding Term Sheet dated October 2, 2019 and this Agreement shall not be subject to the Confidentiality and Federal Rule of Evidence 408+ Agreement dated August 22, 2019 (the “408+ Agreement,” as amended
pursuant to the immediately following sentence), and waives and releases the other Party from any claim to liability, including without limitation any claim of actual or liquidated damages, due to the public disclosure or public discussion of the
terms of the Binding Term Sheet or this Agreement. 
 13.        No Right to Terminate.
Neither Party may terminate this Agreement without the express, written consent of the other Party. 

14.        Fee shifting. The Parties agree that the prevailing Party in any action relating to or arising out
of this Agreement will be awarded its reasonable attorneys’ fees and costs incurred as a result of such a proceeding. 

15.        Waiver. No waiver of this Agreement or any of the promises, obligations, terms, or
conditions herein shall be valid unless it is written and signed by the Party against whom the waiver is to be enforced. No valid waiver of any of the promises, obligations, terms, or conditions herein shall be deemed a subsequent waiver of any of
such promises, obligations, terms, or conditions, nor shall any such waiver constitute a continuing waiver. Failure to insist on compliance with a term, covenant, or condition contained in this Agreement shall not be deemed a waiver of that term,
covenant, or condition. 
 16.        Severability. In the event that any provision of this
Agreement is prohibited by any law governing its construction, performance or enforcement, such provision shall be ineffective to the extent of such prohibition without invalidating thereby any of the remaining provisions of this Agreement and the
Parties shall craft a substitute provision that most closely effects the Parties’ intent. 

17.        Amendment. The terms and conditions of this Agreement may not be modified or amended except in a
writing which states that it is a modification, and is signed by an officer or a duly authorized representative of each Party. 

18.        Change of Control. Notwithstanding any other statement in this Agreement, this Agreement and/or the
Binding Term Sheet (or any parts thereof) may not be assigned other than in, or in connection with, any Change of Control Transaction, and then only on the condition that the Acquirer first enters into an agreement of the form set out in Exhibit
B (Written Declaration of Assumption), acknowledging and transferring obligations under the Agreement and the Binding Term Sheet to the Acquirer. Any attempted assignment in derogation of the foregoing sentence is null and void. Any violation of
the foregoing condition shall constitute a material breach of the Agreement and the Non-Acquired Party reserves the right to terminate the Agreement upon notice to the Acquired Party. 

After the Written Declaration of Assumption has been signed by the Acquirer and the Acquired Party, and the Change of Control Transaction effected, the
covenants provided in the Agreement and the Binding Term Sheet: (i) apply to any patent (x) owned, controlled, or enforceable by the Acquired Party prior to the Change of Control Transaction; and (y) based on any invention conceived
of by Acquirer after the Change of Control Transaction in the context of the continuation of Acquired Party’s business, but (ii) do not apply to any patent (x) owned, 

  
 6 














 EXECUTION VERSION 
  

 

 
controlled or enforceable by Acquirer before the Change of Control Transaction; or (y) based on any invention conceived of by Acquirer after the Change of Control Transaction outside the
context of the continuation of the Acquired Party’s business. 
 19.        Headings for Convenience
Only. The headings contained in this Agreement are for convenience and reference purposes only and shall not affect the meaning or interpretation of this Agreement. 

20.        Rules of Construction. The Parties hereto agree that they have been represented by
counsel during the negotiation and execution of this Agreement. The language used in this Agreement shall be deemed to be language chosen by all Parties to express their mutual intent, and no rule of strict construction against any Party shall be
applied to any term or provision hereof. 
 21.        Entire Agreement. This Agreement
constitutes the entire agreement between the Parties concerning the subject matter hereof and supersedes all written and oral prior agreements and understandings with respect thereto, including without limitation the Binding Term Sheet. No variation
or modification of the terms of this Agreement, nor any waiver of any of the terms or provisions hereof, shall be valid unless in writing and signed by an authorized representative of each Party. 

22.        Counterparts. This Agreement may be executed in two counterparts in the English
language and each such counterpart shall be deemed an original thereof. Facsimile signatures or signatures delivered by e-mail in .pdf or similar format will be deemed original signatures for purposes of this
Agreement. 
 [The remainder of this page is blank; signature page follows.] 

  
 7 














 EXECUTION VERSION 
  

 

 IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed
as of the Effective Date. Each individual signing below represents and warrants that he or she has authority to sign for and enter into this Agreement on behalf of his or her respective Party. 

 

									
	 Agreed to:
	 		 	 Agreed to:

			
	 POWER INTEGRATIONS, INC.
	 		 	 ON SEMICONDUCTOR CORPORATION

					
	 By:
	 	 /s/ Balu Balakrishnan
	 		 	 By:
	 	 /s/ Keith Jackson

	 Name:
	 	 Balu Balakrishnan
	 		 	 Name:
	 	 Keith Jackson

	 Title:
	 	 President & CEO
	 		 	 Title:
	 	 President and CEO















 EXECUTION VERSION 
  

 

 EXHIBIT A 

PENDING PROCEEDINGS 

    UNITED STATES 

							
	 Case Name
	  	 Case No.
	  	 Venue
	  	
Classification

	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation	  	No. 04-1371-LPS	  	Delaware	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation	  	 No. 2019-1246,

No. 2019-1247
	  	Fed. Cir.	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	No. 08-309 LPS	  	Delaware	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	 No. 2019-2377,

No. 2020-1007
	  	Fed. Cir.	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	No. 09-cv-05235-MMC	  	N.D. Cal.	  	Fairchild Legal Proceeding
	Fairchild Semiconductor Corporation and Fairchild (Taiwan) Corporation v. Power Integrations, Inc.	  	No.
12-cv-00540-LPS	  	Delaware	  	Fairchild Legal Proceeding
	Fairchild Semiconductor Corporation and Fairchild (Taiwan) Corporation v. Power Integrations, Inc.	  	 No. 2019-2378,

No. 2020-1003
	  	Fed. Cir.	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	No. 15-cv-04854-MMC	  	N.D. Cal.	  	Fairchild Legal Proceeding
	Power Integrations, Inc. v. ON Semiconductor Corporation and Semiconductor Components Industries, LLC	  	 No. 16-cv-6371-BLF,
 No. 17-cv-3189-BLF
	  	N.D. Cal.	  	ON Semi Legal Proceeding
	ON Semiconductor Corporation and Semiconductor Components Industries, LLC v. Power Integrations, Inc.	  	No.
17-cv-00247-LPS	  	Delaware	  	ON Semi Legal Proceeding
	In re: Application Pursuant to 28 U.S.C. § 1782 of SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC v. Power Integrations, Inc.	  	No.
19-mc-80163-NC	  	N.D. Cal.	  	ON Semi Legal Proceeding


  
 9 














 EXECUTION VERSION 
  

 


							
	 In re: Application Pursuant to 28 U.S.C. § 1782 of SEMICONDUCTOR COMPONENTS
INDUSTRIES, LLC
 Semiconductor Components, LLC v. Power Integrations, Inc.

 
	  	No. 19-16936	  	Ninth Cir.	  	ON Semi Legal Proceeding


  
 10 














 EXECUTION VERSION 
  

 


			
	     PEOPLE’S REPUBLIC OF CHINA
	  	
	Beijing IP Bureau:	  	 ON Semi

	Case number: 2019-1361	  	 Legal

	Patent number: ZL200410061704.6	  	 Proceeding

	Title of invention: 半导体装置及混合集成电路装置
(Semiconductor Device and Hybrid Integrated Circuit Device)	  	 
	Patentee: 半导体元件工业有限责任公司 (Semiconductor Components
Industries, LLC)	  	 
	Petitioner: 半导体元件工业有限责任公司 (Semiconductor Components
Industries, LLC)	  	 
	Respondent 1: 北京九大洲通讯设备有限责任公司 (Beijing
Jiudazhou Communication Instrument Co., Ltd.)	  	 
	 Respondent 2:
惠州市锦湖事业发展有限公司 (Huizhou Jinhu Industrial Development Co., Ltd.)
  
	  	 
	Shanghai IP Court:	  	 ON Semi

	Case number: (2019) Hu 73 Zhi Min Chu 679 [(2019)



73知民初679号]	  	 Legal

	Plaintiff: Semiconductor Components Industries, LLC	  	 Proceeding

	Defendants: Power Integrations Netherlands B.V., Huizhou Jinhu Industrial Development Co., Ltd.
(惠州市锦湖实业发展有限公司), Shanghai Jiading Anting Chuanglian Communication Devices Shop
(上海市嘉定区安亭镇创联通讯器材店)	  	 
	 	 
	Case number: (2019) Hu 73 Zhi Min Chu 680 [(2019)



73知民初680号]	  	 
	Plaintiff: Semiconductor Components Industries, LLC	  	 
	 Defendants: Power
Integrations Netherlands B.V., Huizhou Jinhu Industrial Development Co., Ltd. (惠州市锦湖实业发展有限公司), Shanghai Jiading Anting Chuanglian Communication Devices Shop
(上海市嘉定区安亭镇创联通讯器材店)
  
	  	 
		
	    TAIWAN	  	
	 Semiconductor Components Industries, LLC v. Power Integrations, Inc. and Power
Integrations Netherlands, B.V., Taiwan Branch (November 2017, Taiwan Intellectual Property Court,
107-Ming-Chung-Su-Tzu-22, Appeal Docket No.: 108-Min-Zhuan-Shang- Zi-#21)
  
	  	ON Semi Legal Proceeding


  
 11 














 EXECUTION VERSION 
  

     IPRs and associated appeals 

					
	 Patent and IPR #
	  	 USPTO Case
Number
	  	
CAFC Appeal (if any)

	 ’871#1
	  	
IPR2018-01810
	  	
n/a (still pending at USPTO)

	 ’871#2
	  	
IPR2018-01812
	  	
n/a (still pending at USPTO)

	 ’483#1
	  	
IPR2018-01816
	  	
n/a (still pending at USPTO)

	 ’483#2
	  	
IPR2018-01818
	  	
n/a (still pending at USPTO)

	 ’475#1
	  	
IPR2018-01811
	  	
n/a (still pending at USPTO)

	 ’475#2
	  	
IPR2018-01813
	  	
n/a (still pending at USPTO)

	 ’788#1
	  	
IPR2018-01814
	  	
n/a (still pending at USPTO)

	 ’788#2
	  	
IPR2018-01815
	  	
n/a (still pending at USPTO)

	 ’272
	  	
IPR2018-01539
	  	
n/a (still pending at USPTO)

	 ’623
	  	
IPR2018-00166
	  	 CAFC
19-2173
 (consolidated with 19-2174, 19-2177)

	 ’471
	  	
IPR2018-00165
	  	
CAFC 19-2177 (con with 19-2173)

	 ’119
	  	
IPR2018-00160
	  	
CAFC 19-2178

	 ’221
	  	
IPR2018-00180
	  	
CAFC 19-2212

	 ’624
	  	
IPR2017-01907
	  	
CAFC 19-1863 (con with 19-1868)

	 ’764#1
	  	
IPR2017-01329
	  	
CAFC 19-1414

	 ’841
	  	
IPR2016-01453
	  	
CAFC 19-1448

	 ’605
	  	
IPR2016-01600
	  	
CAFC 18-1852

	 ’876#2
	  	
IPR2016-01589
	  	
CAFC 18-1705

	 ’457#2
	  	
IPR2016-01595
	  	
CAFC 18-1851

	 ’079#1
	  	
IPR2016-00809
	  	
CAFC 18-1607

	 ’079#2
	  	
IPR2016-01590
	  	
CAFC 18-2085 (con with 18-2086)

	 ’079#3
	  	
IPR2016-01592

	 ’908#1
	  	
IPR2016-00995
	  	
CAFC 18-1602 (con with 18-1741)

	 ’908#2
	  	
IPR2016-01597



  
 12 














 EXECUTION VERSION 
  

 Exhibit B 

Written Declaration of Assumption 

General Counsel 
 Non-Acquired Party 
 XXXXXXXXXXXX 

XXXXXXXXXXXX 
 Re:
Acquirer’s Agreement to Perform Obligations of Acquired Party 
 Dear General Counsel: 

A Change of Control Transaction, as defined in the Settlement Agreement entered into on _____________, 2019, between Power Integrations, Inc., a Delaware
Corporation with a principal place of business at 5245 Hellyer Avenue, San Jose, CA 95138, and On Semiconductor, a Delaware corporation, with a principal place of business at __________________ (the Agreement) has occurred with respect to the
Acquired Party, _________, having a principal place of business at _________________________________. 
 The
Non-Acquired Party consents to the Acquired Party assigning the Agreement, and the Binding Term sheet entered into between the Acquired Party and the Non-Acquired Party
dated as of October 2, 2019 to the Acquirer. In consideration of such consent, the Acquirer, ________________, having a principal place of business at _________________, hereby agrees to keep, perform, and fulfill all of the terms, covenants,
conditions and obligations required to be kept, performed, and fulfilled by the Acquired Party under the Agreement and the Binding Term Sheet as of and following the effective date of the Change of Control Transaction. 

IN WITNESS WHEREOF, the Parties hereto have caused this Agreement to be executed as of the Effective Date. Each individual
signing below represents and warrants that he or she has authority to sign for and enter into this Agreement on behalf of his or her respective Party. 
  

			
	 Agreed to:
	  	 Agreed to:

		
	 [ACQUIRER]
	  	 [NON-ACQUIRED PARTY]

		
	 By:____________________________________________
	  	 By:____________________________________________

		
	 Name:__________________________________________
	  	 Name:__________________________________________

		
	 Title:___________________________________________
	  	 Title:___________________________________________

		
	 Date:___________________________________________
	  	 Date:___________________________________________



  
 13 














 EXECUTION VERSION 
  

 

 EXHIBIT C AND FOLLOWING 

  
 14 













  
 EXHIBIT C













 IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF DELAWARE 
  

			
	 POWER INTEGRATIONS, INC.,
	  	
	 	
	 Plaintiff,
	  	
	 	
	 v.
	  	
	 	  	 C.A. No.
04-1371-LPS

	 FAIRCHILD SEMICONDUCTOR
	  	
	 INTERNATIONAL, INC. and FAIRCHILD
	  	
	 SEMICONDUCTOR CORPORATION,
	  	
	 	
	 Defendant.

 
	  	

 JOINT MOTION AND [PROPOSED] ORDER FOR 

VOLUNTARY DIMISSAL WITH PREJUDICE [F.R.C.P. RULE 41(a)(2)] 

Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, the parties jointly move that this Court dismiss this action
with prejudice, with each party to bear its own costs and attorneys’ fees. 
 Neither Party is waiving any argument or position (now or
in the future) that any order, ruling, or judgment was in error in any of the parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the
subject of any appeal dismissed pursuant to the parties’ settlement agreement. 













					
	 ASHBY & GEDDES
	 		  	 FISH & RICHARDSON P.C.

			
	 /s/
	 	     
	  	 /s/

	 John G. Day (#2403)
	 		  	 Douglas E. McCann (#3852)

	 Andrew C. Mayo (#5207)
	 		  	 222 Delaware Ave, 17th Floor

	 500 Delaware Avenue, 8th Floor
	 		  	 Wilmington, DE 19801

	 P.O. Box 1150
	 		  	 (302) 652-5070

	 Wilmington, DE 19899
	 		  	 DMcCann@fr.com

	 (302) 654-1888

jday@ashbygeddes.com
	 		  	 Frank E. Scherkenbach

	 amayo@ashbygeddes.com
	 		  	 One Marina Park Drive

		 		  	 Boston, MA 02210-1878

	 Attorneys for Defendants
	 		  	 (617) 542-5070

			
		 		  	 Howard G. Pollack

		 		  	 Michael R. Headley

		 		  	 500 Arguello Street, Suite 500

		 		  	 Redwood City, CA 94063

		 		  	 (650) 839-5070

			
		 		  	 Attorneys for Plaintiff

			
	 Dated: October __, 2019
	 		  	

  
 SO ORDERED this
____ day of _______________, 2019. 
  
  

			
		 	  
 Chief
Judge



  
 2 













  
 EXHIBIT D


  
 1 













 IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF DELAWARE 
  

			
	 POWER INTEGRATIONS, INC.,
	  	
	 	
	 Plaintiff,
	  	
	 	
	 v.
	  	
	 	  	 C.A. No.
08-309-LPS

	 FAIRCHILD SEMICONDUCTOR
	  	
	 INTERNATIONAL, INC., FAIRCHILD
	  	
	 SEMICONDUCTOR CORPORATION, and
	  	
	 FAIRCHILD (TAIWAN) CORPORATION
	  	
	 	
	 Defendant.

 
	  	

 JOINT MOTION AND [PROPOSED] ORDER FOR 

VOLUNTARY DIMISSAL WITH PREJUDICE [F.R.C.P. RULE 41(a)(2)] 

Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, the parties jointly move that this Court dismiss this action
with prejudice, with each party to bear its own costs and attorneys’ fees. 
 Neither Party is waiving any argument or position (now or
in the future) that any order, ruling, or judgment was in error in any of the parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the
subject of any appeal dismissed pursuant to the parties’ settlement agreement. 













					
	 ASHBY & GEDDES
	 		  	 FISH & RICHARDSON P.C.

			
	 /s/
	 	     
	  	 /s/

	 John G. Day (#2403)
	 		  	 Douglas E. McCann (#3852)

	 Andrew C. Mayo (#5207)
	 		  	 222 Delaware Ave, 17th Floor

	 500 Delaware Avenue, 8th Floor
	 		  	 Wilmington, DE 19801

	 P.O. Box 1150
	 		  	 (302) 652-5070

	 Wilmington, DE 19899
	 		  	 DMcCann@fr.com

	 (302) 654-1888

jday@ashbygeddes.com
	 		  	 Frank E. Scherkenbach

	 amayo@ashbygeddes.com
	 		  	 One Marina Park Drive

		 		  	 Boston, MA 02210-1878

	 Attorneys for Defendants
	 		  	 (617) 542-5070

			
		 		  	 Howard G. Pollack

		 		  	 Michael R. Headley

		 		  	 500 Arguello Street, Suite 500

		 		  	 Redwood City, CA 94063

		 		  	 (650) 839-5070

			
		 		  	 Attorneys for Plaintiffs

			
	 Dated: October __, 2019
	 		  	

 SO ORDERED this ____ day of _______________, 2019. 

 

			
		 	  
 Chief
Judge



  
 2 













  
 EXHIBIT E














			
	 COLETTE REINER MAYER (SBN 263630)
	  	 FRANK E. SCHERKENBACH

	 CRMayer@mofo.com
	  	 (SBN 142549)

	 MORRISON & FOERSTER LLP
	  	 scherkenbach@fr.com

	 755 Page Mill Road
	  	 FISH & RICHARDSON P.C.

	 Palo Alto, CA 94304-1018
	  	 One Marina Park Drive

	 Tel: (650) 813-5600
	  	 Boston, MA 02110-2804

	 Fax: (650) 494-0792
	  	 Telephone: (617) 542-5070

		
	 Attorneys for Defendants
	  	 HOWARD G. POLLACK

	 FAIRCHILD SEMICONDUCTOR
	  	 (SBN 162897)

	 INTERNATIONAL, INC., FAIRCHILD
	  	 pollack@fr.com

	 SEMICONDUCTOR CORPORATION, and
	  	 MICHAEL R. HEADLEY

	 FAIRCHILD (TAIWAN) CORPORATION
	  	 (SBN 220834)

		  	 headley@fr.com

		  	 FISH & RICHARDSON P.C.

		  	 500 Arguello Street, Suite 500

		  	 Redwood City, CA 94063

		  	 Telephone: (650) 839-5070

		
		  	 Attorneys for Plaintiff

		  	 POWER INTEGRATIONS, INC.


 UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 
  

			
	POWER INTEGRATIONS, INC.,	  	 Case
No.  3:09-cv-5235-MMC

	a Delaware corporation,	  	
	 	  	 STIPULATION AND [PROPOSED]

	 Plaintiff,
	  	 ORDER FOR VOLUNTARY

	 v.
	  	 DIMISSAL WITH PREJUDICE

	 	  	 [F.R.C.P. RULE 41(A)(2)]

	 FAIRCHILD SEMICONDUCTOR INTERNATIONAL,

INC., a Delaware corporation, FAIRCHILD SEMICONDUCTOR CORPORATION, a Delaware corporation, and FAIRCHILD (TAIWAN) CORPORATION, a Taiwanese
corporation,
	  	  
 Hon. Maxine M. Chesney

	 	
	 Defendants.

 
	  	


  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:09-cv-5235-MMC
	  	














 Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, it is
hereby stipulated by the parties to this action, through their respective counsel, that this Court dismiss this action with prejudice. It is further stipulated and agreed that each party will bear its own costs and attorneys’ fees. 

Neither Party is waiving any argument or position (now or in the future) that any order, ruling, or judgment was in error in any of the
parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the subject of any appeal dismissed pursuant to the parties’ settlement
agreement. 
  

					
	 Dated:  October ___, 2019
	  	 Respectfully submitted,

		
		  	 MORRISON & FOERSTER LLP

			
		  	 By:
	  	  /s/ DRAFT

		  		  	 COLETTE REINER MAYER

			
		  		  	 Attorney for Defendants

		  		  	 FAIRCHILD SEMICONDUCTOR

		  		  	 INTERNATIONAL, INC.,

		  		  	 FAIRCHILD SEMICONDUCTOR

		  		  	 CORPORATION, AND FAIRCHILD

		  		  	 (TAIWAN) CORPORATION

		
	 Dated: October __, 2019
	  	 FISH & RICHARDSON P.C.

			
		  	 By:
	  	  /s/ DRAFT 

		  		  	 MICHAEL R. HEADLEY

			
		  		  	 Attorneys for Plaintiff

		  		  	 POWER INTEGRATIONS, INC.



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:09-cv-5235-MMC
	  	1














 SIGNATURE ATTESTATION 

Pursuant to Civil Local Rule 5-1(i)(3), I attest under penalty of perjury that
concurrence in the filing of this document has been obtained from counsel for Plaintiff. 
  

					
	 Dated: October ___, 2019
	  	  /s/ DRAFT
	  	         

		  	     COLETTE REINER MAYER
	  	

 PURSUANT TO STIPULATION, IT IS SO ORDERED. 

 

			
	 Dated: _______________
	  	  

		  	 MAXINE M. CHESNEY

		  	 UNITED STATES DISTRICT JUDGE



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:09-cv-5235-MMC
	  	2














  
 EXHIBIT F














			
	 ERIK J. OLSON (SBN 175815)

EJOlson@mofo.com
 COLETTE REINER
MAYER (SBN 263630)
 CRMayer@mofo.com

PIETER S. DE GANON (SBN 320385)

PdeGanon@mofo.com
 STEPHEN LIU
(SBN 318533)
 SLiu@mofo.com

MORRISON & FOERSTER LLP

755 Page Mill Road
 Palo Alto, CA
94304-1018
 Tel: (650) 813-5600 | Fax: (650)
494-0792
  

JIANING LIU (SBN 305568)

JennyLiu@mofo.com

MORRISON & FOERSTER LLP

425 Market Street
 San Francisco,
California 94105-2482
 Tel: (415) 268-7000 | Fax: (415) 268-7522
  
 ROGER
FULGHUM (Pro Hac Vice)
 roger.fulghum@bakerbotts.com

BAKER BOTTS L.L.P.
 910 Louisiana
Street
 Houston, Texas 77002

Tel: (713) 229-1234 | Fax: (713) 229-1522

 
 Attorneys for Defendants

FAIRCHILD SEMICONDUCTOR

INTERNATIONAL, INC., FAIRCHILD

SEMICONDUCTOR CORPORATION, and

FAIRCHILD (TAIWAN) CORPORATION
	  	 FRANK E. SCHERKENBACH

(SBN 142549)

scherkenbach@fr.com

FISH & RICHARDSON P.C.

One Marina Park Drive
 Boston, MA
02110-2804
 Telephone: (617) 542-5070

 
 HOWARD G. POLLACK

(SBN 162897)
 pollack@fr.com

MICHAEL R. HEADLEY
 (SBN
220834)
 headley@fr.com

FISH & RICHARDSON P.C.

500 Arguello Street, Suite 500

Redwood City, CA 94063
 Telephone:
(650) 839-5070
  

Attorneys for Plaintiff
 POWER
INTEGRATIONS, INC.






























 UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 
  

 

			
	POWER INTEGRATIONS, INC.,	  	 Case No.
    3:15-cv-04854-MMC

	 	
	 Plaintiff,
	  	 STIPULATION AND [PROPOSED]

	 	  	 ORDER FOR VOLUNTARY

	    v.	  	 DIMISSAL WITH PREJUDICE

[F.R.C.P. RULE 41(A)(2)]

	 FAIRCHILD SEMICONDUCTOR

INTERNATIONAL, INC., a Delaware corporation, FAIRCHILD SEMICONDUCTOR CORPORATION, a Delaware corporation, and FAIRCHILD (TAIWAN) CORPORATION, a Taiwanese
corporation,
	  	  
 Hon. Maxine M. Chesney

	 	
	 Defendants.

 
	  	


  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:15-cv-04854-MMC
	  	














 Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, it is
hereby stipulated by the parties to this action, through their respective counsel, that this Court dismiss this action with prejudice, including all claims and counterclaims by any of the parties. It is further stipulated and agreed that each party
will bear its own costs and attorneys’ fees. 
 Neither Party is waiving any argument or position (now or in the future) that any
order, ruling, or judgment was in error in any of the parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the subject of any appeal
dismissed pursuant to the parties’ settlement agreement. 
  

					
	 Dated:   October ___, 2019
	  	 Respectfully submitted,

		
		  	 MORRISON & FOERSTER LLP

			
		  	 By:
	  	  /s/ DRAFT

		  		  	 COLETTE REINER MAYER

			
		  		  	 Attorney for Defendants

		  		  	 FAIRCHILD SEMICONDUCTOR

		  		  	 INTERNATIONAL, INC.,

		  		  	 FAIRCHILD SEMICONDUCTOR

		  		  	 CORPORATION, AND FAIRCHILD

		  		  	 (TAIWAN) CORPORATION

		
	 Dated: October __, 2019
	  	 FISH & RICHARDSON P.C.

			
		  	 By:
	  	  /s/ DRAFT

		  		  	 MICHAEL R. HEADLEY

			
		  		  	 Attorneys for Plaintiff

		  		  	 POWER INTEGRATIONS, INC.



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:15-cv-04854-MMC
	  	1














 SIGNATURE ATTESTATION 

Pursuant to Civil Local Rule 5-1(i)(3), I attest under penalty of perjury that concurrence in the
filing of this document has been obtained from counsel for Plaintiff. 
  
  

					
	 Dated:   October ___, 2019
	  	   /s/ DRAFT
	  	         

		  	     COLETTE REINER MAYER
	  	

 PURSUANT TO STIPULATION, IT IS SO ORDERED. 

 

			
	 Dated: ____________
	  	  

		  	 MAXINE M. CHESNEY

		  	 UNITED STATES DISTRICT JUDGE



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
3:15-cv-04854-MMC
	  	2














  
 EXHIBIT G














			
	 Roger Fulghum (Pro hac vice)
	  	 Frank E. Scherkenbach (CA #142549)

	 roger.fulghum@bakerbotts.com
	  	 scherkenbach@fr.com

	 BAKER BOTTS L.L.P.
	  	 FISH & RICHARDSON P.C.

	 910 Louisiana Street
	  	 One Marina Park Drive

	 Houston, TX 77002
	  	 Boston, Massachusetts 02210-1878

	 Telephone: (713) 229-1234
	  	 Telephone: (617) 542-5070

	 Facsimile: (713) 229-1522
	  	 Facsimile: (617) 542-8906

		
	 Colette Reiner Mayer (CA SBN 263630)
	  	 Howard G. Pollack (CA #162897)

	 CRMayer@mofo.com
	  	 pollack@fr.com

	 MORRISON & FOERSTER LLP
	  	 Michael R. Headley (CA #220834)

	 755 Page Mill Road
	  	 headley@fr.com

	 Palo Alto, California 94304-1018
	  	 FISH & RICHARDSON P.C.

	 Telephone: (650) 813-5600
	  	 500 Arguello Street, Suite 500

	 Facsimile: (650) 494-0792
	  	 Redwood City, California 94063

		  	 Telephone: (650) 839-5070

	 Attorneys for ON SEMICONDUCTOR
	  	 Facsimile: (650) 839-5071

	 CORP. AND SEMICONDUCTOR
	  	
	 COMPONENTS INDUSTRIES, LLC
	  	 Attorneys for POWER INTEGRATIONS, INC.


 UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN JOSE DIVISION 
  

			
	POWER INTEGRATIONS, INC.,	  	Case No.     16-cv-06371-BLF
	 	
	 Plaintiff,
	  	 STIPULATION AND [PROPOSED]

	 	  	 ORDER FOR VOLUNTARY

	v.	  	 DIMISSAL WITHOUT PREJUDICE

	 	  	 [F.R.C.P. RULE 41(A)(2)]

	ON SEMICONDUCTOR CORP. and	  	
	SEMICONDUCTOR COMPONENTS	  	
	 INDUSTRIES, LLC,

 
	  	
	 Defendants.

 
	  	
	 	  	Case No. 3:17-cv-03189 BLF
	 ON SEMICONDUCTOR CORPORATION;

and SEMICONDUCTOR COMPONENTS
	  	
	INDUSTRIES, LLC,	  	
	  

Plaintiffs,
	  	
	 	
	 v.
	  	
	 	
	POWER INTEGRATIONS, INC.	  	
	 	
	 Defendant.

 
  
	  	


  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
16-cv-06371-BLF
	  	














 Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, the parties
hereby stipulate and jointly move that this Court dismiss this action without prejudice, with each party to bear its own costs and attorneys’ fees. 

Neither Party is waiving any argument or position (now or in the future) that any order, ruling, or judgment was in error in any of the
parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the subject of any appeal dismissed pursuant to the parties’ settlement
agreement. 
  

					
	 Dated:   October ___, 2019
	  	 Respectfully submitted,

		
		  	 MORRISON & FOERSTER LLP

			
		  	 By:
	  	  /s/ DRAFT

		  		  	 COLETTE REINER MAYER

			
		  		  	 Attorneys for ON SEMICONDUCTOR

		  		  	 CORP. AND SEMICONDUCTOR

		  		  	 COMPONENTS INDUSTRIES, LLC

		
	 Dated: October __, 2019
	  	 FISH & RICHARDSON P.C.

			
		  	 By:
	  	  /s/ DRAFT

		  		  	 MICHAEL R. HEADLEY

			
		  		  	 Attorneys for POWER

		  		  	 INTEGRATIONS, INC.



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
16-cv-06371-BLF
	  	1














 SIGNATURE ATTESTATION 

Pursuant to Civil Local Rule 5-1(i)(3), I attest under penalty of perjury that
concurrence in the filing of this document has been obtained from counsel for Plaintiff. 
  

					
	 Dated:   October ___, 2019
	  	  /s/ DRAFT
	  	         

		  	     COLETTE REINER MAYER
	  	

 PURSUANT TO STIPULATION, IT IS SO ORDERED. 

 

			
	 Dated:
                    
	  	  

		  	 BETH LABSON FREEMAN

		  	 UNITED STATES DISTRICT JUDGE



  

			
	 STIPULATION AND [PROPOSED] ORDER FOR VOLUNTARY
DISMISSAL
 Case No.
16-cv-06371-BLF
	  	2














  
 EXHIBIT H


  
 1 













 IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF DELAWARE 
  

			
	  
  

ON SEMICONDUCTOR CORPORATION and SEMICONDUCTOR COMPONENTS
	  	 C.A. No.     17-247-LPS-CJB

	INDUSTRIES, LLC,
	 	
	 Plaintiffs,
	  	
	 	
	 v.

 
	  	
	 	
	POWER INTEGRATIONS, INC.,	  	
	 	
	  

Defendant.
	  	
	 	  	

  
 JOINT MOTION AND [PROPOSED] ORDER FOR

 VOLUNTARY DIMISSAL WITHOUT PREJUDICE [F.R.C.P. RULE 41(a)(2)] 

Pursuant to Federal Rule of Civil Procedure 41(a)(2) and the Settlement Agreement, the parties jointly move that this Court dismiss this
action without prejudice, with each party to bear its own costs and attorneys’ fees. 
 Neither Party is waiving any argument or
position (now or in the future) that any order, ruling or judgment that is currently the subject of any pending appeal that is being dismissed with or without prejudice in connection with the Settlement was in error. 

This Court retains jurisdiction for the purpose of ensuring compliance with the Settlement Agreement entered into by the parties on October
___, 2019, a redacted version of which is attached as Exhibit A. 













					
	 ASHBY & GEDDES
	 		  	 FISH & RICHARDSON P.C.

			
	 /s/
	 	     
	  	 /s/

	 John G. Day (#2403)
	 		  	 Joseph B. Warden

	 Andrew C. Mayo (#5207)
	 		  	 Warren K. Mabey, Jr.

	 500 Delaware Avenue, 8th Floor
	 		  	 222 Delaware Ave, 17th Floor

	 P.O. Box 1150
	 		  	 Wilmington, DE 19801

	 Wilmington, DE  19899
	 		  	 (302) 652-5070

	 (302) 654-1888
	 		  	 warden@fr.com

	 jday@ashbygeddes.com
	 		  	 mabey@fr.com

	 amayo@ashbygeddes.com
	 		  	
		 		  	 John W. Shaw (No. 3362)

	 Attorneys for Plaintiffs
	 		  	 Andrew E. Russell (No. 5382)

		 		  	 SHAW KELLER LLP

		 		  	 I.M. Pei Building

		 		  	 1105 North Market Street, 12th Floor

		 		  	 Wilmington, DE 19801

		 		  	 (302) 298-0700

		 		  	 jshaw@shawkeller.com

		 		  	 arussell@shawkeller.com

		 		  	
	 Dated: October __, 2019
	 		  	 Attorneys for Defendant


 SO ORDERED this ____ day of _______________, 2019. 

 

			
		 	  
 Chief
Judge



  
 2 













  
  

EXHIBIT I 












 Nos. 19-1246,
19-1247 
  

 
 IN THE UNITED
STATES COURT OF APPEALS 
 FOR THE FEDERAL CIRCUIT 

 
  

POWER INTEGRATIONS, INC., 

                       
                                         
            Plaintiff-Cross-Appellant, 
 v. 

FAIRCHILD SEMICONDUCTOR INTERNATIONAL, INC., 

FAIRCHILD SEMICONDUCTOR CORPORATION 

                      
                                         
             Defendants-Appellants. 
  

 

 
 JOINT MOTION
TO DISMISS INTERLOCUTORY APPEALS 
  

 

 

Appellants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation and cross-appellant Power
Integrations, Inc. respectfully request under Federal Rule of Appellate Procedure 42(b) that the Court dismiss these appeals from an order that the District Court certified pursuant to 28 U.S.C. § 1292(b). Pursuant to Federal Rule of Civil
Procedure 41(a)(2) and a settlement agreement, the parties have dismissed the underlying district court action with prejudice. The parties have agreed that each side will bear its own costs associated with the appeals. 












 Neither Party is waiving any argument or position (now or in the future)
that any order, ruling, or judgment that is currently the subject of the present appeal and cross-appeal was in error. 
  

 

			
	Dated: October _, 2019	  	Respectfully submitted,
		
	s/	  	s/
	KATHLEEN M. SULLIVAN	  	FRANK SCHERKENBACH
	QUINN EMANUEL URQUHART &	  	FISH & RICHARDSON, PC
	SULLIVAN, LLP	  	One Marina Park Drive
	51 Madison Avenue, 22nd Floor	  	Boston, MA 02210
	New York, NY 10010	  	Telephone: (617) 542-5070
	Telephone: (212) 849-7000	  	
	KEVIN ALEXANDER SMITH	  	 MICHAEL R. HEADLEY

HOWARD G. POLLACK

	QUINN EMANUEL URQUHART &	  	NEIL WARREN
	SULLIVAN, LLP	  	FISH & RICHARDSON, PC
	50 California Street, 22nd Floor	  	500 Arguello Street
	San Francisco, CA 94111	  	Redwood City, CA 94063
	Telephone: (415) 875-6600	  	Telephone: (650) 839-5070
		
		  	JOHN WINSTON THORNBURGH
		  	FISH & RICHARDSON, PC
		  	12390 El Camino Real
		  	San Diego, CA 921303
		  	Telephone: (858) 678-5070
		
	Counsel for Defendants-Appellants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation	  	Counsel for Plaintiff-Cross-Appellant Power Integrations, Inc.


  
 2 













 CERTIFICATE OF INTEREST 

Counsel for plaintiffs-cross-appellants Power Integrations certify the following: 

1.      The full name of every party or amicus represented by me is: 

Power Integrations, Inc. 

2.      The name of the Real Party in interest (Please only include any real party in interest NOT identified in Question 3)
represented by me is: 
 N/A 

3.      All parent corporations and any publicly held companies that own 10% or more of the stock of the party or amicus curiae
represented by me are: 
 BlackRock, Inc. 

4.      The names of all law firms and the partners or associates that appeared for the party or amicus now
represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

Fish & Richardson P.C.: Frank. E. Scherkenbach, Howard G. Pollack, Michael R. Headley, Neil A. Warren, John W. Thornburgh, Craig Countryman, Jonathan
J. Lamberson, Michael J. Kane, Douglas E. McCann, Joseph B. Warden, William J. Marsden,* Tamara D. Fraizer,* Kyle W. Compton,* David J. Miclean,* Gina M. Steele,* Sean P. Hayes,*Desa L. Burton*, John D. Hamann*, John Horvath*; and Abrams &
Bayliss LLP: John M. Seaman. 
 (*No longer with firm.) 

5.      The title and number of any case known to counsel to be pending in this or any other court or agency that will directly
affect or be directly affected by this court’s decision in the pending appeal: 
 Power Integrations, Inc. v. Fairchild Semiconductor et al., USDC-D. DE Case 04-1371-LPS; Power Integrations, Inc v. Fairchild Semiconductor et al., USDC-D.
DE Case 08-309-LPS. 
  

					
	Dated:  October _, 2019	  	 /s/
	  	
		  	[NAME]                	  	













 CERTIFICATE OF INTEREST 

Counsel for defendants-appellants Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation certify the following: 

1.      The full name of every party or amicus represented by me is: 

Fairchild Semiconductor International, Inc.; Fairchild Semiconductor Corp. 

2.      The name of the Real Party in interest (Please only include any real party in interest NOT identified in Question 3)
represented by me is: 
 N/A 

3.      All parent corporations and any publicly held companies that own 10% or more of the stock of the party or amicus curiae
represented by me are: 
 Fairchild Semiconductor International, Inc. and Fairchild Semiconductor Corporation are 100% owned direct or indirect subsidiaries
of ON Semiconductor Corporation. Except for ON Semiconductor Corporation, none of the foregoing entities or any other direct or indirect subsidiary of ON Semiconductor Corporation is publicly traded. 

4.      The names of all law firms and the partners or associates that appeared for the party or amicus now
represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

QUINN EMANUEL URQUHART & SULLIVAN, LLP: Kathleen M. Sullivan, Kevin A. Smith, Cleland B. Welton II 

ASHBY & GEDDES: John G. Day, Steven J. Balick, Andrew Colin Mayo, Tiffany Geyer Lydon, Lauren E. Maguire* 

ORRICK HERRINGTON & SUTCLIFFE LLP. Bas de Blank, George Hopkins Guy III*, Vickie L. Feeman, Raymis H. Kim*, Duo Chen, Brian H. VanderZanden*, William
L. Anthony*, Gabriel M. Ramsey* 
 MCDERMOTT WILL & EMERY LLP: Brett E. Bachtell, Terrence P. MacMahon, Leigh J. Martinson, Eric W. Hagen 












 MORRISON & FOERSTER LLP: Colette Reiner Mayer 

PAUL HASTINGS LLP: Blair M. Jacobs, Christina A. Ondrick, Patrick Stafford* 

ON Semiconductor: Joshua Engel 
 * Attorneys no longer with
designated firms. 
 5.      The title and number of any case known to counsel to be pending in this or any other court or
agency that will directly affect or be directly affected by this court’s decision in the pending appeal: 
 Power Integrations, Inc v. Fairchild
Semiconductor et al., USDC-D. DE Case 04-1371-LPS. 
  


			
	 Dated:  October _, 2019
	  	 /s/ Kathleen M. Sullivan

		  	  

		  	 Kathleen M. Sullivan














 CERTIFICATE OF COMPLIANCE 

This motion complies with the type-volume limitations in Federal Rules of Appellate Procedure 27 and 32 because it contains __
words. 
  

			
	 Dated:  October _, 2019
	  	   /s/

		  	   [NAME]














 CERTIFICATE OF SERVICE 

I hereby certify that I electronically filed the foregoing with the Clerk of the Court for the United States Court of Appeals
for the Federal Circuit by using the CM/ECF system on October _, 2019. 
 I certify that all participants in the case are
registered CM/ECF users and that service will be accomplished by the CM/ECF system. 
  

			
	 Dated:  October _, 2019
	  	 /s/

		  	  

		  	 [NAME]














  
 EXHIBIT J













 Nos. 19-2377,
20-1007 
  

 
 IN THE UNITED
STATES COURT OF APPEALS 
 FOR THE FEDERAL CIRCUIT 

 
  

POWER INTEGRATIONS, INC., 

                       
                                         
            Plaintiff-Cross-Appellant, 
 v. 

FAIRCHILD SEMICONDUCTOR INTERNATIONAL, INC., 

FAIRCHILD SEMICONDUCTOR CORPORATION, 

FAIRCHILD (TAIWAN) CORPORATION 

                       
                                         
            Defendants-Appellants. 
  

 

 
 JOINT MOTION
TO DISMISS APPEALS 
  
  

 

Appellants Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan)
Corporation and cross-appellant Power Integrations, Inc. respectfully request under Federal Rule of Appellate Procedure 42(b) that the Court dismiss these appeals. The parties have agreed that each side will bear its own costs associated with the
appeals. 
 Neither Party is waiving any argument or position (now or in the future) that any order, ruling, or judgment
that is currently the subject of the present appeal and cross-appeal was in error. 













			
	Dated: October _, 2019	  	Respectfully submitted,
		
	s/	  	s/
	KATHLEEN M. SULLIVAN	  	FRANK SCHERKENBACH
	QUINN EMANUEL URQUHART &	  	FISH & RICHARDSON, PC
	SULLIVAN, LLP	  	One Marina Park Drive
	51 Madison Avenue, 22nd Floor	  	Boston, MA 02210
	New York, NY 10010	  	Telephone: (617) 542-5070
	Telephone: (212) 849-7000	  	
		  	MICHAEL R. HEADLEY
	FELIPE CORREDOR	  	HOWARD G. POLLACK
	KEVIN ALEXANDER SMITH	  	FISH & RICHARDSON, PC
	QUINN EMANUEL URQUHART &	  	500 Arguello Street
	SULLIVAN, LLP	  	Redwood City, CA 94063
	50 California Street, 22nd Floor	  	Telephone: (650) 839-5070
	San Francisco, CA 94111	  	
	Telephone: (415) 875-6600	  	JOHN WINSTON THORNBURGH
		  	FISH & RICHARDSON, PC
		  	12390 El Camino Real
		  	San Diego, CA 921303
		  	Telephone: (858) 678-5070
		
	Counsel for Defendants-Appellants Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	Counsel for Plaintiff-Cross-Appellant Power Integrations, Inc.


  
 2 













 CERTIFICATE OF INTEREST 

Counsel for plaintiff-cross-appellant Power Integrations, Inc. certify the following: 

1.      The full name of every party or amicus represented by me is: 

Power Integrations, Inc. 

2.      The name of the Real Party in interest (Please only include any real party in interest NOT identified in Question 3)
represented by me is: 
 None 

3.      All parent corporations and any publicly held companies that own 10% or more of the stock of the party or amicus curiae
represented by me are: 
 BlackRock, Inc. 

4.      The names of all law firms and the partners or associates that appeared for the party or amicus now
represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

FISH & RICHARDSON P.C.: Frank E. Scherkenbach, Howard G. Pollack, Michael R. Headley, Neil Warren, John Thornburgh,
Douglas E. Mccann, James Huguenin-Love, Joseph B. Warden, Craig E. Countryman*, William J. Marsden*, Keeley I. Vega*, Kyle Wagner Compton*, Scott A. Penner*. 

*No longer with firm 
 5.      The
title and number of any case known to counsel to be pending in this or any other court or agency that will directly affect or be directly affected by this court’s decision in the pending appeal: 

 

					
	 None
	  		  	
			
	 Dated: October _, 2019
	  	 /s/      
	  	
		  	     [NAME]
	  	













 CERTIFICATE OF INTEREST 

Counsel for defendants-appellants Fairchild Semiconductor International, Inc., Fairchild Semiconductor Corporation, and Fairchild (Taiwan)
Corporation certify the following: 
 1.      The full name of every party or amicus represented by me is:

 Fairchild Semiconductor International, Inc.; Fairchild Semiconductor Corp.; and Fairchild (Taiwan) Corp. 

2.      The name of the Real Party in interest (Please only include any real party in interest NOT identified in
Question 3) represented by me is: 
 N/A 

3.      All parent corporations and any publicly held companies that own 10% or more of the stock of the party
or amicus curiae represented by me are: 
 Fairchild Semiconductor Corporation, Fairchild Semiconductor International, Inc., and Fairchild (Taiwan) Corp.
are 100% owned direct or indirect subsidiaries of ON Semiconductor Corporation. Except for ON Semiconductor Corporation, none of the foregoing entities or any other direct or indirect subsidiary of ON Semiconductor Corporation is publicly traded.

 4.      The names of all law firms and the partners or associates that appeared for the party or amicus now
represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

QUINN EMANUEL URQUHART & SULLIVAN, LLP: Kathleen M. Sullivan, Kevin A. Smith, Felipe Corredor, Lance Yang, Patrick Stafford, John
(Jay) M. Neukom* 
 MORRISON & FOERSTER LLP: Erik J. Olson, Colette Reiner Mayer, Scott F. Llewellyn, Esther Chang, Thomas J.
Pardini 
 ASHBY & GEDDES, P.A.: John G. Day, Andrew Colin Mayo, Tiffany Geyer Lydon, Lauren E. Maguire*, Caroline Hong* 

PAUL HASTINGS LLP: Blair M. Jacobs, Christina A. Ondrick 












 BAKER BOTTS LLP: Roger J. Fulghum, Brett J. Thompsen, George Hopkins Guy, III 

MCDERMOTT WILL & EMERY LLP: Leigh J. Martinson*, Michael F. Martin*, Rose S. Whelan* 

ORRICK HERRINGTON & SUTCLIFFE LLP: Bas de Blank, Diana M. Rutowski, Vicki L. Feeman, Ulysses Hui* 

ON SEMICONDUCTOR CORP.: Joshua Engel 

* Attorneys no longer with designated firms. 

5.      The title and number of any case known to counsel to be pending in this or any other court or agency that will directly
affect or be directly affected by this court’s decision in the pending appeal: 
 Fairchild Semiconductor Corp. v. Power
Integrations, Inc., No. 19-2378 (Fed. Cir.). 
  

					
	 Dated:  October _, 2019
	 	                 
	  	 /s/ Kathleen M. Sullivan        

		 		  	     Kathleen M. Sullivan














 CERTIFICATE OF COMPLIANCE 

This motion complies with the type-volume limitations in Federal Rules of Appellate Procedure 27 and 32 because it contains __
words. 
  
  
  

 

			
	 Dated: October _, 2019
	  	   /s/

		  	   [NAME]














 CERTIFICATE OF SERVICE 

I hereby certify that I electronically filed the foregoing with the Clerk of the Court for the United States Court of Appeals
for the Federal Circuit by using the CM/ECF system on October _, 2019. 
 I certify that all participants in the case are
registered CM/ECF users and that service will be accomplished by the CM/ECF system. 
  
  

 

			
	 Dated: October _, 2019
	  	 /s/

		  	  

		  	 [NAME]














  
  

EXHIBIT K 












 Nos. 19-2378,
20-1003 
  

 
 IN THE UNITED
STATES COURT OF APPEALS 
 FOR THE FEDERAL CIRCUIT 

 
  

FAIRCHILD SEMICONDUCTOR CORPORATION 

and FAIRCHILD (TAIWAN) CORPORATION, 

Plaintiffs-Appellants,                   

 v. 
 POWER
INTEGRATIONS, INC., 
 Defendant-Cross-Appellant.         

 
  

 
 JOINT MOTION TO
DISMISS APPEALS 
  
  

 

Appellants Fairchild Semiconductor Corporation and Fairchild (Taiwan) Corporation and cross-appellant Power Integrations, Inc.
respectfully request under Federal Rule of Appellate Procedure 42(b) that the Court dismiss these appeals. The parties have agreed that each side will bear its own costs associated with the appeals. 

Neither Party is waiving any argument or position (now or in the future) that any order, ruling, or judgment that is currently
the subject of the present appeal and cross-appeal was in error. 













			
	 Dated: October _, 2019
	  	 Respectfully submitted,

		
	 s/
	  	 s/

	MICHAEL HAWES	  	FRANK SCHERKENBACH
	ROGER FULGHUM	  	 FISH & RICHARDSON, PC

	 BAKER BOTTS, LLP
	  	 One Marina Park Drive

	 910 Louisiana Street
	  	 Boston, MA 02210

	 One Shell Plaza
	  	 Telephone: (617) 542-5070

	 Houston, TX 77002
	  	
	 Telephone: (713) 229-1750
	  	MICHAEL R. HEADLEY
		  	HOWARD G. POLLACK
	JEFFREY TA-HWA HAN	  	FISH & RICHARDSON, PC
	BAKER BOTTS, LLP	  	 500 Arguello Street

	 Suite 1500
	  	 Redwood City, CA 94063

	 98 San Jacinto Boulevard
	  	 Telephone: (650) 839-5070

	 Austin, TX 78746-7568
	  	
	 Telephone: (512) 322-2629
	  	JOHN WINSTON THORNBURGH
		  	FISH & RICHARDSON, PC
		  	 12390 El Camino Real

		  	 San Diego, CA 921303

		  	 Telephone: (858) 678-5070

		
	Counsel for Plaintiffs-Appellants Fairchild Semiconductor Corporation, and Fairchild (Taiwan) Corporation	  	 Counsel for Defendant-Cross-Appellant

Power Integrations, Inc.


  

  
 2 













 CERTIFICATE OF INTEREST 

Counsel for plaintiffs-appellants Fairchild Semiconductor Corporation and Fairchild (Taiwan Corporation) certify the following: 

1.        The full name of every party or amicus represented by me is: 

Fairchild Semiconductor Corp.; Fairchild (Taiwan) Corporation 

2.        The name of the Real Party in interest (Please only include any real party in interest NOT
identified in Question 3) represented by me is: 
 None 

3.        All parent corporations and any publicly held companies that own 10% or more of the stock of
the party or amicus curiae represented by me are: 
 Fairchild Semiconductor Corporation and Fairchild (Taiwan) Corporation are wholly-owned
subsidiaries of Fairchild Semiconductor International, Inc. Fairchild Semiconductor International, Inc. is a wholly-owned subsidiary of Semiconductor Components Industries, LLC. Semiconductor Components Industries, LLC is a wholly-owned subsidiary
of ON Semiconductor Corporation. There is no parent corporation or publicly held company that owns 10% or more of the stock in ON Semiconductor Corporation. 

4.        The names of all law firms and the partners or associates that appeared for the party or amicus now
represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

John G. Day, Andrew Mayo, Lauren E. Maguire - Ashby & Geddes; Rose Whelan - Cooley; Scott F. Llewellyn, Collette Reiner Mayer, Pieter S. de Ganon,
Ryan J. Gatzemeyer - Morrison & Foerster LLP; Blair Jacobs, Christina Ondrick, Yar Chaikovsky, Robert Walters, Patrick Stafford, Charles Hawkins - Paul Hastings; Jennifer Nall - Baker Botts LLP; Joshua Engel - ON Semiconductor; Jeremiah
Armstrong, Alexander Ott, Leigh Martinson, Michael Martin, Terrence McMahon - McDermott, Will & Emery 

5.        The title and number of any case known to counsel to be pending in this or any other court or agency that
will directly affect or be directly affected by this court’s decision in the pending appeal: 












 CAFC 2019-2377 Power Integrations Inc. v. Fairchild Semiconductor Corporation; ON
Semiconductor Corporation, et al. v. Power Integrations, Inc., 1:17-0247 - LPS (D. Del.); Power Integrations, Inc. v. ON Semiconductor Corporation, et al., 5:16-06371
(N.D. Cal.) 
  

			
	 Dated: October _, 2019
	  	 /s/ Michael
Hawes                            

		  	 Michael Hawes














 CERTIFICATE OF INTEREST 

Counsel for defendant-cross-appellant Power Integrations, Inc. certify the following: 

1.        The full name of every party or amicus represented by me is: 

Power Integrations, Inc. 

2.        The name of the Real Party in interest (Please only include any real party in interest NOT
identified in Question 3) represented by me is: 
 None 

3.        All parent corporations and any publicly held companies that own 10% or more of the stock of
the party or amicus curiae represented by me are: 
 BlackRock, Inc. 

4.        The names of all law firms and the partners or associates that appeared for the party or
amicus now represented by me in the trial court or agency or are expected to appear in this court (and who have not or will not enter an appearance in this case) are: 

FISH & RICHARDSON P.C.: Frank E. Scherkenbach, Howard G. Pollack, Michael R. Headley, Neil Warren, John Thornburgh,
Warren K. Mabey, Jr., Douglas E. Mccann, Joseph Warden, James Huguenin-Love, William Marsden*, Limin Zheng* 
 *No longer with the firm 

5.        The title and number of any case known to counsel to be pending in this or any other court or agency that
will directly affect or be directly affected by this court’s decision in the pending appeal: 
 CAFC Appeal No. 18-1851 
  

			
	 Dated: October _, 2019
	  	 /s/        

		  	 [NAME]














 CERTIFICATE OF COMPLIANCE 

This motion complies with the type-volume limitations in Federal Rules of Appellate Procedure 27 and 32 because it contains __
words. 
  

			
	 Dated: October _, 2019
	  	  /s/

		  	  [NAME]














 CERTIFICATE OF SERVICE 

I hereby certify that I electronically filed the foregoing with the Clerk of the Court for the United States Court of Appeals
for the Federal Circuit by using the CM/ECF system on October _, 2019. 
 I certify that all participants in the case are
registered CM/ECF users and that service will be accomplished by the CM/ECF system. 
  

			
	 Dated: October _, 2019
	  	 /s/

		  	  [NAME]














  
 EXHIBIT L













 IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF DELAWARE 
  

			
	 	
	FAIRCHILD SEMICONDUCTOR CORPORATION and FAIRCHILD (TAIWAN) CORPORATION,	  	
	 	
	        Plaintiffs,	  	    C.A. No. 12-540-LPS
	 	
	 v.
	  	
	 	
	POWER INTEGRATIONS, INC.	  	
	 	
	
        Defendant.

 
	  	

  
 JOINT MOTION AND [PROPOSED] ORDER FOR

 VOLUNTARY DIMISSAL WITH PREJUDICE [F.R.C.P. RULE 41(a)(2)] 

Pursuant to Federal Rule of Civil Procedure 41(a)(2) and a settlement agreement, the parties jointly move that this Court dismiss this action
with prejudice, with each party to bear its own costs and attorneys’ fees. 
 Neither Party is waiving any argument or position (now or
in the future) that any order, ruling, or judgment was in error in any of the parties’ cases that is being dismissed with or without prejudice in connection with the parties’ settlement agreement, including any arguments that were the
subject of any appeal dismissed pursuant to the parties’ settlement agreement. 













					
	 ASHBY & GEDDES
	 		  	 FISH & RICHARDSON P.C.

			
	 /s/
	 	     
	  	 /s/

	 John G. Day (#2403)
	 		  	 Douglas E. McCann (#3852)

	 Andrew C. Mayo (#5207)
	 		  	 Joseph B. Warden (#5401)

	 500 Delaware Avenue, 8th Floor
	 		  	 222 Delaware Ave, 17th Floor

	 P.O. Box 1150
	 		  	 Wilmington, DE 19801

	 Wilmington, DE 19899
	 		  	 (302) 652-5070

	 (302) 654-1888
	 		  	 DMcCann@fr.com

	 jday@ashbygeddes.com
	 		  	 Warden@fr.com

	 amayo@ashbygeddes.com
	 		  	
			
	 Attorneys for Plaintiffs
	 		  	 Attorneys for Defendant

			
	 Dated: October __, 2019
	 		  	

 SO ORDERED this ____ day of _______________, 2019. 

 

	
	  
 Chief
Judge




  
 2