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Inteum Co., LLC v. National University of Singapore

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

September 25, 2017

INTEUM COMPANY, LLC, Plaintiff,
v.
NATIONAL UNIVERSITY OF SINGAPORE, Defendant.

          Ulrike B. Connelly, WSBA No. 42478 Ian D. Rogers, WSBA No. 46584 Perkins Coie LLP Attorneys for Defendant National University of Singapore

          Nicholas Ryan-Lang, WSBA No. 45826 Byrnes Keller Cromwell LLP Attorneys for Plaintiff Inteum Company, LLC

          STIPULATED PROTECTIVE ORDER

          HONORABLE JOHN C. COUGHENOUR, JUDGE.

         Pursuant to the parties' Stipulated Motion for Protective Order (Dkt. No. 14), the Court ORDERS as follows:

         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. The parties to this action stipulate that the following Protective Order applies to documents and information produced or disclosed in this case.

         2.CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

(a) Trade secret or otherwise proprietary material, including but not limited to software and source code;
(b) Other confidential information regarding the parties' intellectual property, or that of third parties, including but not limited to reports that summarize such intellectual property and management of the same;
(c) Sensitive financial information that is not otherwise publicly available;
(d) Confidential personal information for current and former employees of the parties, or of third parties;
(e) Confidential and sensitive investigative files;
(f) Accounting or audit information, including but not limited to any financial account number, access code, or password;
(g) Documents that otherwise describe, contain or disclose internal company or organizational information, including student, faculty, or customer information, internal policy discussions, competitive or strategic initiatives, business plans and other business-related information; where such information is not readily ascertainable and with respect to which the party asserting confidentiality has taken reasonable steps to maintain its confidentiality; and
(h) Any other information that a party in good faith believes constitutes or includes sensitive business or organizational information, or personal information or information furnished in confidence by any third party, which information is not known or freely accessible to the general public.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material. However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving ...


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