wa wee SUPERIOR COURT, STATE OF CALIFORNIA COUNTY OF SANTA CLARA YAHOO! INC., a Delaware Corporation Plain, v. CECILE LAL, an individual Defendant, SReeTaE Santa Clara| —a- CASE NO. 115CV280271 g, aver OTSC1Va STIPULATION AND FPROPOS a “$435, 0 PERMANENT INJUNCTION}AND $435.00 JUDGMENT PURSUANT TO%G: layig H. Yapasaki BI Hees RRS Dei ASG E-2AG2TL {Awe un WHEREAS, on or about May 6, 2015, Yahoo! Ine. (“Yahoo”) filed a complaint against Defendant Cecile Lal (“Lal”) in the above-titled matter in the Superior Court of California, Santa Clara County, alleging that Ms. Lal disclosed certain “Confidential Information” of Yahoo, as defined by Ms. Lal’s Employee Confidentiality and Assignment of Inventions Agreement and the Yahoo! Code of Ethics (“Yahoo Confidential Information”) to a reporter (Nicholas Carlson) in violation of her employment agreement with Yahoo and various Yahoo policies governing her employment (hereinafter the “Complaint”); WHEREAS, Ms. Lal admits that she disclosed certain confidential Yahoo information to Mr. Carlson in violation of her employment agreement with Yahoo and various Yahoo policies governing her employment; WHEREAS, Ms. Lal (1) has offered and agreed to cooperate with Yahoo in its investigation related to the above-titled matter; and (2) has voluntarily agreed to stipulate to a permanent injunction to avoid the need for further proceedings in this matter; WHEREAS, each Party wishes to resolve the above-titled matter and all claims asserted therein without farther litigation and subject to the terms and conditions of this Stipulation and [Proposed] Judgment; WHEREAS, this Stipulation and [Proposed] Judgment, including the confidentiality, return, and non-use restrictions on Lal, is the product of a reasonable compromise of this action under the circumstances; NOW THEREFORE, PURSUANT TO THE STIPULATION OF THE PARTIES HERETO AND THEIR COUNSEL OF RECORD, THIS MATTER IS HEREBY ORDERED, ADJUDGED AND DECREED AS FOLLOWS: All defined terms set for above are adopted for purposes of this judgment, and the parties shall abide by the following terms: if Payment by Lal to Yahoo. Lal shall pay Yahoo a confidential sum for damages incurred by Yahoo as a result of her breach of her employment agreement and the Yahoo Code of Ethics. Lal shal! bear her own fees and costs 2. Permanent Injunction Against Lal. The parties agree that the Court shall enter, 2 STIPULATION & [PROPOSEBT PERMANENT INJUNCTION & JUDGMENT : CASE NO. 1 15CV280271 j | | |aw we aa this document shall constitute, and Lal shall abide by, this permanent injunction directing Lat to immediately: a. return to Yahoo all Yahoo Confidential Information in her possession, custody, or control; and b, cease further access to, disclosure, or use of any Yahoo Confidential Information. 3. Jurisdiction. The Parties agree and stipulate that this Court retains jurisdiction over this matter pursuant to California Civil Procedure Code § 664.6. It is therefore ordered that this Court shall retain jurisdiction of this matter pursuant to that provision. 4. Judgment. Judgment shall be entered against Lal and in favor of Yahoo on all causes of action in the above-titled action. ‘This document constitutes the Judgment in this action, Pursuant to this Judgment, this matter is complete and terminated. Respectfully submitted, DATED: JuneZ 42015 GIBSON, DUNN & CRUTCHER LLP By: Gurl ae eg asec AK Seott A. Edelman Attomeys for Plaintiff Yahoo! Inc. DATED: June __, 2015 WILLOUGHBY, STUART, BENING & COOK By: Ronald J. Cook Attomeys for Defendant Cecile Lal STIPULATION & [PI SED] PERMANENT INJUNCTION & JUDGMENT CASE NO. 115CV280271Awa this document shall constitute, and Lal shall abide by, this permanent injunction directing Lal to immediately: 8, return to Yahoo all Yahoo Confidential Information in her possession, custody, or control; and b. cease further access to, disclosure, or use of any Yahoo Confidential Information, 3. Jurisdiction. The Parties agree and stipulate that this Court retains jurisdiction over this matter pursuant to California Civil Procedure Code § 664.6. It is therefore ordered that this Courtsshalll retain jurisdiction of this matter pursuant to that provision, 4. Judgment, Judgment shall be entered against Lal and in favor of Yahoo on all causes of action in the above-titled action. This document constitutes the Judgment in this action. Pursuant to this Judgment, this matter is complete and terminated. Respectfully submitted, DATED: June __, 2015 GIBSON, DUNN & CRUTCHER LLP By: Scott A. Edelman Attomeys for Plaintiff Yahoo! Ine. DATED: Juned$2015 STIPULATION & [PROPOSED] PERMANENT INJUNCTION & JUDGMENT CASE NO. 115CV280271ee Le ~{PROPOSED] JUDGMENT Itis SO ORDERED that Judgment shall be entered in the above-titled matter pursuant to the terms outlined above. DATED: June, 2015 WELLIAM ELPYING 4 ‘STIPULATION & [PR@POSED] PERMANENT INJUNCTION & JUDGMENT CASE NO, 115CV28027t |