William Alsup

James F. Basile (SBN 228965)

Mark E. McKane (SBN 230552)

KIRKLAND & ELLIS LLP

Attorneys for Defendants

TEXTRON INC., BELL HELICOPTER

TEXTRON INC., and TEXTRON INNOVATIONS, INC.

Additional counsel listed on signature block

Hon. William Alsup

STIPULATED [PROPOSED] ORDER EXTENDING DEADLINES

Complaint Filed: Jan. 6, 2012

WHEREAS, on January 6, 2012, Electronic Arts Inc. ("EA") filed the Complaint against Textron Inc. ("Textron"), Bell Helicopter Textron Inc. ("Bell"), and Textron Innovations Inc. ("Textron Innovations") currently before this Court;

WHEREAS, on January 30, 2012, the parties in this action agreed to extend the Defendants' time to respond to EA's complaint until February 29, 2012;

WHEREAS, on February 23, 2012 this Court entered an order approving the withdrawal of Jones Day and the substitution of Kirkland & Ellis LLP as counsel for Defendants;

WHEREAS, on February 24, 2012, Textron Innovations and Bell filed a complaint in the Northern District of Texas alleging trademark, trade dress, and certain other claims against EA ("Texas Action");

WHEREAS, on February 29, 2012, Defendants in this action file a Motion to Dismiss or, in the Alternative, Stay or Transfer this action to the Northern District of Texas ("Defendants' Forum Motion"), a hearing for Defendants' Forum Motion has been noticed for April 26, 2012, and EA intends to oppose Defendants' Forum Motion;

WHEREAS, on or before March 19, 2012, EA intends to file in the Northern District of Texas a motion to transfer the Texas Action to this Court ("EA's Forum Motion");

WHEREAS, the Initial Case Management Conference in this matter is currently scheduled for April 5, 2012; the joint case management statement is due on March 29, 2012; and the parties' Rule 26 meet-and-confer and ADR obligations are due on March 13, 2012 pursuant to this Court's January 6, 2012 Order;

WHEREAS, the parties agree that resolution of the venue and forum issues raised in Defendants' Forum Motion and EA's Forum Motion prior to substantive litigation in either forum will best promote efficiency and conserve judicial resources, and the parties intend to file a similar timing stipulation in the Northern District of Texas;

WHEREAS, the parties believe that the stipulated time changes below will not affect the current schedule aside from revised deadlines reflected below;

IT IS HEREBY STIPULATED THAT:

1. The deadline for Defendants to respond to EA's Complaint by answer or Rule 12(b) motion shall be 10 days from the entry of any order denying Defendants' Forum Motion;

2. The deadline for the parties to satisfy their Rule 26 meet-and-confer and ADR obligations referenced in this Court's January 6, 2012 Order shall be 20 days from the entry of any order denying Defendants' Forum Motion;

3. The Initial Case Management Conference shall be rescheduled for 45 days from the entry of any order denying Defendants' Forum Motion, or at such later time as is convenient for the Court;

4. The parties' joint case management statement shall be due at least 7 days prior to the rescheduled Initial Case Management Conference.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

KIRKLAND & ELLIS LLP

___________

Mark E. McKane

James F. Basile (SBN 228965)

Mark E. McKane (SBN 230552)

KIRKLAND & ELLIS LLP

Attorneys for Defendants

TEXTRON INC., BELL HELICOPTER TEXTRON INC., and TEXTRON INNOVATIONS INC.

KEKER & VAN NEST LLP

____________

R. James Slaughter

R. James Slaughter (SBN 192813)

R. Adam Lauridsen (SBN 243780)

KEKER & VAN NEST LLP

Attorneys for Plaintiff

ELECTRONIC ARTS INC.

The case management is continued to May 10, 2012, at 11:00 a.m. A joint case management statement is due at least seven days prior. All initial deadlines are extended accordingly.

_____________

Judge William Alsup

ATTESTATION PURSUANT TO GENERAL ORDER 45

I, Mark E. McKane, attest that concurrence in the filing of this document has been obtained from the signatories. I declare under penalty of perjury that the foregoing is true and correct.

KIRKLAND & ELLIS LLP

_____________

Mark E. McKane

Mark E. McKane (SBN 230552)

KIRKLAND & ELLIS LLP

CERTIFICATE OF SERVICE

I hereby certify that the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the e-mail addresses registered for service, and I hereby certify that I caused the foregoing documents to be mailed via the United States Postal Service to the non-CM/ECF participants indicated on the Manual Notice List.

_____________

Mark E. McKane