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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA



UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

COMPUTER ASSOCIATES
INTERNATIONAL, INC. and
PLATINUM TECHNOLOGY
INTERNATIONAL, INC.,

                  Defendants.


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Civil Action No. 1:99CV01318

JUDGE: Gladys Kessler

DECK TYPE: Antitrust

DATE STAMP: 05/25/99


STIPULATED MOTION OF THE PARTIES TO PLACE
EXHIBIT ONE TO FINAL JUDGMENT UNDER SEAL

By this stipulated Motion, Plaintiff and Defendants move this Court pursuant to Local Court Rule 106(j) and Fed. R. Civ. P. 26(c) for an order permitting the United States to file under seal Exhibit 1 to the proposed Final Judgment.

Exhibit 1 is a list of a small number of individuals who Defendants may continue to subject to employment-related non-competition clauses as they relate to the Divested Products (as defined by the Final Judgment). Enforcement of these individuals' non-competition clauses are an express exception to Section V.D of the proposed Final Judgment, which otherwise prohibits Defendants from enforcing such clauses as to any employee hired by the Acquirer (as defined by the Final Judgment) of the Divested Products. The individuals named in Exhibit 1 are subject to confidential employment agreements, and revealing the terms of such agreements or the identities of such individuals may disclose Defendants' confidential commercial information. The parties agree that public disclosure of the identity of the individuals named in Exhibit 1 is not necessary to the Court's evaluation whether the proposed Final Judgment is in the public interest pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16.

Therefore, the parties move for an Order in the form attached hereto permitting Exhibit 1 to the proposed Final Judgment to be filed and maintained under seal.

Respectfully submitted,

FOR PLAINTIFF
UNITED STATES OF AMERICA:

______________________________
Kent R. Brown
Attorney
Antitrust Division
Computers & Finance Section
U.S. Department of Justice
600 E. Street, N.W., Suite 9500
Washington, D.C. 20530
(202) 307-6200

FOR DEFENDANTS
Computer Associates International, Inc. and
PLATINUM technology International, inc.:

______________________________
Richard L. Rosen
DC Bar # 307231
Arnold & Porter
555 Twelfth Street, N.W.
Washington, D.C. 20004-1202
(202) 942-5000

Dated:__________________________


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA,    

                  Plaintiff,

                  v.

COMPUTER ASSOCIATES
INTERNATIONAL, INC. and
PLATINUM TECHNOLOGY
INTERNATIONAL, INC.,

                  Defendants.


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Civil Action No. _______________

Filed: May ___, 1999

ORDER TO PLACE
EXHIBIT ONE TO FINAL JUDGMENT UNDER SEAL

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 document filed as Exhibit 1 to the proposed Final Judgment 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.


_______________________________
UNITED STATES DISTRICT JUDGE

Dated: