2nd Pacer today--NOTICE OF AMENDED STIPULATION BETWEEN PLAINTIFFS AND DEFENDANTS REGARDING PRODUCTION OF DOCUMENTS PREVIOUSLY PRODUCED DURING INVNTORSHIP LITIGATION


UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
Technology Properties Limited and Patriot
Scientific Corporation,
Plaintiffs,
v.
Matsushita Electric Industrial Co., Ltd.,
Panasonic Corporation of Nort America, NC
Americas Corporation, NEC Electronics
America, Inc., Toshiba Corporation, Toshiba
America, Inc., Toshiba America Electronic
Components, Inc., Toshiba America
Information Systems, Inc. and Toshiba America
Consumer Products, LLC,
Defendants.
JURY DEMANDED
NOTICE OF AMENDED STIPULATION BETWEEN PLAINTIFFS AND
DEFENDANTS REGARDING PRODUCTION OF DOCUMENTS PREVIOUSLY
PRODUCED DURING INVNTORSHIP LITIGATION
Pursuant to an agreement between Plaintiffs and Defendants, IT is HEREBY STIPULATED AND AGREED, that Plaintiff Technology Properties Limited ("TPL") shall produce to Defendants patent prosecution related fies and other documents in its possession that were previously produced to TPL by Plaintiff Patrot Scientific Corporation, Russell Fish II, Wilis E. Higgins or the law firm of Cooley Godward Kronish LLP in the matter of Patriot Scientifc Corp. v. Charles Moore, et at., Case no. CV-04-618-JF/HRL (the "Inv'entorship Litigation"). This production will include those documents from TPL's privilege log that were produced in the Inventorship Litigation and that therefore have a bates number from that litigation associated with them, as well as the additional patent prosecution fies in TPL's possession that were produced to TPL in the Inventorship Litigation but that have not been produced to Defendants or identified on TPL' s privilege log. Defendants, and each of them, agree not to use the fact of this production of documents from the Inventorship Litigation to Defendants made pursuant to this agreement to argue or otherwise assert that there has been a waiver of attorney-client privilege as it relates to the subject matter of the documents or otherwise. This agreement extends to all documents produced by TPL to Defendants pursuant to this agreement that contain bates-numbers from the inventorship Litigation. . Defendants reserve their right to rely on any other waivers of privilege not specifically addressed in this agreement.
By: TOWNSEND and TOWNSEND and CREW LLP
Roger L. Cook, CA State Bar No. 55208
Lead Counsel
rlcook~townsend.com
Eric P. Jacobs, CA State Bar No. 88413
epjaco bs~townsend. com
Two Embarcadero Center, 8th Floor
San Francisco, CA 94111
Telephone: (415) 576-0200
Facsimile: (415) 576-0300