WRITTEN REQUEST FOR ARBITRATION

REQUEST FOR ARBITRATION(*1)


To:The Japan Commercial Arbitration Association

Claimant:(*2) A Co., Ltd.
[Address], Tokyo
Representative: Mr. B
Representative Director
Attorney for the Claimant:(*3)
Mr. C, Attorney-at-law
Law office of D
[Address], Tokyo
[telephone number]
[facsimile number]
[email address]
Respondent:(*2) E Corporation
-------------------------, San Francisco
California, United States of America
Representative: Mr. F
President


The Claimant hereby makes a claim as follows:

I Relief or remedy sought:

The Claimant asks that the following arbitral award be rendered:

  1. the Respondent shall pay to the Claimant the sum in the amount of U.S.$1,000,000 together with interest thereon at the rate of 6% per annum from --------------, 20 ---- until the date of full payment thereof; and

  2. the arbitration fee, arbitrator's remuneration and any other necessary expenses incurred during the arbitral proceedings shall be borne by the Respondent.
II Summary of the dispute and the basis for the claim:

(omitted)

III Reference to the arbitration agreement that is invoked:

The Claimant and the Respondent have entered into a patent license agreement as of ----------------, 20----, Article 28 of which stipulates that all disputes which may arise out of or in connection with such Agreement shall be finally settled by arbitration in Tokyo, Japan in accordance with the Commercial Arbitration Rules of the Japan Commercial Arbitration Association.

IV Manner or method of proof:

Relevant evidence shall be submitted in the future during the course of the proceedings.

EXHIBIT:

(1) a power of attorney(*4)
----------------, 20----

(signature)

Attorney-at-law
Attorney for the Claimant


NOTES:
(*1): The number of copies of documents to be submitted shall be equal to the number of arbitrator(s) (three (3) if not yet determined) and the other party or parties plus one (1).
(*2): The addresses and the names of the parties should be entered. If a party is a corporation, enter the title and the name of the representative.
(*3): Enter the name of the attorney-at-law, the address, telephone number, facsimile number and email address of the law office to which he/she belongs.
(*4): Attach one (1) copy of the power of attorney of the attorney-at-law.



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