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City of Seattle v. ZyLAB North America, LLC

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

October 13, 2017

CITY OF SEATTLE, Plaintiff,
v.
ZYLAB NORTH AMERICA, LLC, Defendant.

          FOSTER PEPPER PLLC Jack Cullen, JEFFER MANGELS BUTLER & MITCHELL LLP Joseph N. Demko Matthew S. Kenefick Admitted pro hac vice Attorneys for ZyLAB North America, LLC.

          PETER S. HOLMES Seattle City Attorney John L. Groh, Assistant City Attorney K&L GATES LLP Martha Rodriguez Lopez, Raina V. Wagner, K&L Gates LLP Attorneys for The City of Seattle.

          PROTECTIVE ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE

         This matter comes before the Court on the parties' stipulated motion for protective order (Dkt. No. 47). Having thoroughly considered the stipulation, the Court 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 include the following documents and tangible things produced or otherwise exchanged in the above-captioned matter which include any of the following information: ZyLAB customer identities; ZyLAB pricing terms, lists and structures; ZyLAB technology processes, techniques, and specifications; ZyLAB methodologies, procedures and practices; and ZyLAB contractual terms, conditions and covenants. “Confidential” material shall also include documents and tangible things produced or otherwise exchanged in the above-captioned matter which include any of the following information, as referenced in RCW 42.56.070, RCW 42.56.420 and WAC 44-14-06002: City personal information in agency employee files, to the extent that disclosure would violate the employee's right to privacy; preliminary drafts, notes, recommendations, and intra-agency memorandums that demonstrate the City's deliberative process; security information related to public safety, national security, emergency plans, emergency preparedness plans, escape response plans, safe school plans, computer and telecommunications network infrastructure, and the personal security information of private cloud servers; and sensitive proprietary information of businesses regulated by the City.

         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;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced ...

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