New Pacer--STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR
PUBLIC FILING OF TPL’S DOCUMENTS PENDING RULING ON TPL’S
ADMINISTRATIVE MOTION TO MAINTAIN DOCUMENTS UNDER SEAL (Not Signed By Judge)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
BARCO N.V., a Belgian corporation,
Plaintiff,
v.
TECHNOLOGY PROPERTIES LTD.,
PATRIOT SCIENTIFIC CORP.,
ALLIACENSE LTD.,
Defendants.

STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINE FOR
PUBLIC FILING OF TPL’S DOCUMENTS PENDING RULING ON TPL’S
ADMINISTRATIVE MOTION TO MAINTAIN DOCUMENTS UNDER SEAL

Pursuant to Northern District of California Civil Local Rules 6-2 and 7-12,
DEFENDANTS TECHNOLOGY PROPERTIES LIMITED and ALLIACENSE LIMITED
(collectively, “TPL”) and PLAINTIFF BARCO N.V, hereby stipulate and request that the Court
extend the deadline set forth in Magistrate Lloyd’s Administrative Order of September 12, 2011
(Docket 214) (“September 12 Order”) by when Barco should file in the public record copies of
TPL’s Product Reports submitted in connection with a discovery dispute, until such time as the
Court has resolved TPL’s September 13, 2011 Administrative Motion For A Sealing Order to
(Docket 216, “Pending Administrative Motion”.).
WHEREAS, on July 19, 2011 Barco filed an Administrative Motion to File Documents
Under Seal in connection with discovery Joint Report #2 before Magistrate Lloyd (Dockets 208
and 209);
WHEREAS, those documents contain TPL’s Product Reports which TPL alleges include
confidential matter;
WHEREAS, TPL’s counsel inadvertently failed to file the necessary declaration attesting
to confidentiality prior to the required date under Civil Local Rule 79-5 for the filing of the
confidential documents connected with Joint Report #2;
WHEREAS, TPL first became aware of the need to file such a declaration upon receiving
the September 12 order and the next day filed the Pending Administrative Motion and
accompanying declarations (Dockets 216-218) in order to seek relief from that order and request
those documents be sealed, see Pending Administrative Motion;
WHEREAS, under the September 12 Order, Barco is required to file in the public record
the documents that are the subject of the Pending Administrative Motion on Friday, September
16, 2011, prior to which date the parties do not expect to receive an order on the Pending
Administrative Motion;
WHEREAS, TPL alleges that Barco’s filing of the documents in the public record under
the September 12 Order would effectively deprive TPL of the relief it is seeking in the Pending
Administrative Motion;
WHEREAS, Barco intends to oppose the Pending Administrative Motion and Barco will
not be unduly prejudiced by waiting until Judge Ware issues a decision on the Pending
Administrative Motion;
ACCORDINGLY, it is hereby stipulated by and among the parties that the time for Barco
to fulfill the filing requirement of the September 12 Order is extended and stayed until such time
as the Pending Administrative Motion has been decided. Barco shall abstain from filing the
documents that are the subject of the Pending Administrative Motion in the public record until a
ruling on the Pending Administrative Motion.
Respectfully Submitted,
Dated: September 15, 2011 FARELLA BRAUN & MARTEL LLP
By: /s/ John L. Cooper
John L. Cooper
Attorneys for Defendants
TECHNOLOGY PROPERTIES LIMITED and ALLIACENSE LIMITED
Dated: September 15, 2011 BAKER & McKENZIE LLP
By: /s/ Edward K. Runyan
Edward K. Runyan
Attorneys for Plaintiffs
BARCO N.V.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: September ___, 2010
UNITED STATES DISTRICT COURT