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LLC v. Teknon Corp.

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

October 4, 2017

E2 OPTICS, LLC, Plaintiff,
v.
TEKNON CORPORATION, NEAL STOBAUGH, AND JOSHUA CHILDS, Defendants.

         Noted for consideration: October 3, 2017

          RICH & HENDERSON PC. By Peter C. Hersey, admitted pro hac vice Attorneys for Plaintiff

          DAVIS WRIGHT TREMAINE LLP By Ambika K. Doran, WSBA #38237 Attorneys for Defendants

          MODEL STIPULATED PROTECTIVE ORDER

          MARSHA J. PECHMAN UNITED STATES DISTRICT JUDGE

         Plaintiff E2 Optics, LLC and Defendants Teknon Corporation, Neal Stobaugh, and Joshua Childs stipulate and agree to this protective order in the interest of efficiency and judicial economy, particularly in the interest of avoiding ancillary litigation of discovery issues relating to confidential commercial and/or proprietary information, and the procedures set forth herein for designating and protecting confidential commercial and/or proprietary information. Plaintiff and, Defendants stipulate to the following terms. All departures from the model Protective Order are shown in track changes:

         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 information may be designated "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY."

         "CONFIDENTIAL" material shall include the following documents and tangible things produced or otherwise exchanged: non-public marketing, sales, and financial information (including, but not limited to documents reflecting revenue, income, debt, lines of credit, tax returns, and documents identifying corporate expenditures, and bidding or pricing models or formulas); sensitive information concerning trade secrets or other confidential research and development information; personal and/or private identifying information (e.g., birthdate); agreements that contain confidentiality obligations; information that identifies customers and nonpublic projects; and information about non-public company policies, rules, and regulations.

         "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" material shall include the following documents and tangible things produced or otherwise exchanged: extremely sensitive CONFIDENTIAL information, the disclosure of which to another party or non-party would create a substantial risk of serious harm that could not be avoided by less restrictive means.

         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 party may disclose any confidential material only to:

         (a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation, including, but not limited to, contract review attorneys, law clerks, paralegals, legal secretaries, and graphics or design services professionals or firms retained by counsel;

         (b) the officers, directors, managers, and employees (including in house counsel) of the receiving party to whom disclosure is ...


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