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G.G. v. Valve Corp.

United States District Court, W.D. Washington, Seattle

January 24, 2017

G.G., A.L., and B.S., individually and on behalf of all others similarly situated, Plaintiffs,
v.
VALVE CORPORATION, Defendant.

          TOUSLEY BRAIN STEPHENS PLLC Kim D. Stephens, WSBA #11984 Jason T. Dennett, WSBA #30686 And JONES WARD PLC Jasper D. Ward IV (admitted pro hac vice) Alex C. Davis (admitted pro hac vice) Patrick Walsh (admitted pro hac vice) Attorneys for Plaintiffs

          RIDDELL WILLIAMS P.S. Gavin W. Skok, WSBA #29766 Sarah E. Joye, WSBA #44357 James H. Wendell, WSBA #46489 And MONTGOMERY MCCRACKEN WALKER & RHOADS, LLP Charles B. Casper (admitted pro hac vice) Attorneys for Defendant Valve Corporation

          STIPULATED PROTECTIVE ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE

         This matter comes before the Court on the parties' stipulated proposed protective order (Dkt. No. 20). The Court hereby ORDERS the following:

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2.CONFIDENTIAL” MATERIAL

         “Confidential Material” shall mean information, recorded, stored, or maintained for any reason in any medium, including but not limited to print, electronic, or digital, that the party, including any third-party, designating the information as confidential (the “designating party”) reasonably believes to fall within the following definition:

         1. Non-public financial, product use or business plan information, including research and development and product use data; proprietary product development or use information; confidential financial, sales or profitability data; confidential financial or sales metrics; or confidential financial or sales projections.

         2. Proprietary, commercial, or client information, which is defined as:

a. Research, development, or commercial information that is of a highly competitively sensitive nature and that a reasonably prudent business person in the applicable field would not release to or share with the public in the ordinary course of business, and the release of which would likely cause proprietary, competitive, or economic harm; or
b. “Trade secret, ” as set forth in the Washington Trade Secrets Act, Wash. Rev. Code § 19.108.010, meaning information, including a formula, pattern, compilation, program, device, method, technique, or process that:
(i) Derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use; and
(ii) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

         3. Personal information where the producing party reasonably believes that disclosure of that information could violate that person's privacy. A “person” shall include any natural person and, where relevant, a corporation, joint stock association, or an unincorporated association. The standard for determining whether a person's privacy could be violated shall be based on the standard set forth in the Washington Public Disclosure Act, Wash. Rev. Code § 42.17.255, as follows:

A person's “right to privacy, ” “right of privacy, ” “privacy, ” or “personal privacy, ” is invaded or violated if disclosure of information about the person: (1) would be highly offensive to a reasonable person, and (2) is not of legitimate concern to the public.

         Notwithstanding any other provision in this Protective Order, it shall not apply to information that is publicly available. Confidential Material shall be used and disclosed only in the above-captioned case. No person afforded access to Confidential Material shall use or disclose Confidential Material for the purpose of business or competition or for any purpose other than this litigation.

         3. ...


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