UNITED STATES OF AMERICA,                       Plaintiff,                   v. GENERAL ELECTRIC COMPANY                      and INSTRUMENTARIUM OYJ                   Defendant.

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Civil Action No.: 1:03CV01923 Filed: September 16, 2003

By this stipulated Motion, plaintiff and defendants move this Court pursuant to Local Court Rule 5.1(j) and Fed. R. Civ. P. 26(c) for an Order permitting the United States to file under seal Exhibit 1 to the plaintiff's proposed Final Judgment, which is also attached as Exhibit A (Part 2) to the parties' Hold Separate Stipulation and Order.

Exhibit 1 to the plaintiff's proposed Final Judgment is the entire text of Schedule 1, including Annexes 1-4, of the Commitments entered into by defendants with the European Commission regarding the divestiture of Spacelabs, which were approved by the European Commission on September 2, 2003. Exhibit 2 of the plaintiff's proposed Final Judgment, which is also attached as Exhibit A (Part 3) to the parties' Hold Separate Stipulation and Order, provides a nonconfidential version of Schedule 1.

Exhibit 1 provides a detailed description of the Spacelabs business, which defendants are ordered by the proposed Final Judgment to divest. Exhibit 1 includes highly confidential information such as customer lists and supply agreements. Revealing these details about the Spacelabs business is not necessary for public comment on the Final Judgment, nor for the Court's assessment as to whether the proposed Final Judgment is in the public interest pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16. Exhibit 2 of the proposed Final Judgment, which provides a nonconfidential version of Schedule 1, is not filed under seal. Therefore, the parties move for an Order in the form attached hereto permitting Exhibit 1 to the proposed Final Judgment, also attached as Exhibit A (Part 2) of the Hold Separate Stipulation and Order, to be filed and maintained under seal.

Respectfully submitted,

FOR PLAINTIFF UNITED STATES OF AMERICA: _______________/s/________________ Joan Hogan, D.C. Bar No. 451240 Michael Dashefskey, D.C. Bar No. 477868 Matthew Bester, DC Bar No. 465374 Jill Beaird Gregg Malawer, DC Bar No. 481685 Leigh Lani Brown Attorneys U.S. Department of Justice Antitrust Division Litigation III Section 325 Seventh Street, N.W., Suite 300 Washington, D.C. 20530 Tel: (202) 616-5937 Fax: (202) 307-9952 Dated: September 16, 2003.

FOR DEFENDANT GENERAL ELECTRIC COMPANY: _______________/s/________________ Deborah L. Feinstein Arnold & Porter 555 Twelfth Street, NW Washington, D.C 20004 Tel: (202) 942-5015 Fax: (202) 942-5999 FOR DEFENDANT INSTRUMENTARIUM OYJ: _______________/s/________________ Wayne Dale Collins Shearman & Sterling LLP 599 Lexington Avenue New York, NY 10022 Tel: (202) 848-4000 Fax: (212) 849-7179

UNITED STATES OF AMERICA,                       Plaintiff,                   v. GENERAL ELECTRIC COMPANY                      and INSTRUMENTARIUM OYJ                   Defendant.

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Civil Action No.: Filed:

Good cause having been shown and pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and Local Rule 106(j), the Court ORDERS as follows:

The documents filed as Exhibit 1 to the proposed Final Judgment, also attached as Exhibit A (Part 2) to the Hold Separate Stipulation and Order, in this matter shall be placed under seal by the Clerk of the Court, and shall not be made part of the public record for any purposes.

It is SO ORDERED this ___ day of September 2003.

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United States District Judge