UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ------------------------------------ MICROSYSTEMS SOFTWARE, INC., a Massachusetts corporation, and MATTEL, INC., a Delaware corporation, Plaintiffs, vs. SCANDINAVIA ONLINE AB, a Swedish corporation; ISLANDNET.COM, a Canadian corporation; EDDY L. O. JANSSON, a Swedish citizen; and MATTHEW SKALA, a Canadian citizen, Defendants. ------------------------------------ X : : : : : : : : : X CIVIL NO. [PROPOSED] ORDER ON MOTION FOR TEMPORARY RESTRAINING ORDER, EXPEDITED DISCOVERY AND FOR HEARING DATE ON PRELIMINARY INJUNCTION MOTION Upon the Verified Complaint, the Memorandum in Support of Ex Parte Motion for Expedited Discovery, Affidavit of Irwin B. Schwartz and for good cause shown, it is hereby ORDERED that: 1. Plaintiffs shall serve as rapidly as possible the Summons, Verified Complaint, and the discovery attached hereto as Exhibit A, and that defendants shall deliver all documents responsive to the document requests to the office of plaintiffs' counsel no later than twenty-four hours after service upon them. 2. A Temporary Restraining Order immediately shall issue, and the defendants, their officers, agents, servants, employees, attorneys, and those persons in active concert or participation with them, shall discontinue publishing defendants' Cyber Patrol bypass source code and binaries (known as "CP4break.zip" or "cphack.exe" or any derivative thereof). 3. In addition, all defendants shall preserve inviolate the software and information that makes up all such Web sites, source or object code and documents relating to Cyber Patrol as well as all records which reflect the identity or number of persons who downloaded "CP4break.zip" or "cphack.exe" from the Web sites; and 4. the hearing on Plaintiffs' Motion For Preliminary Injunction shall be held on March ___, 2000 at ____ o'clock. Dated: March , 2000 SO ORDERED, ___________________________ , J.