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Intellicheck Mobilisa, Inc. v. Honeywell International Inc.

United States District Court, W.D. Washington

December 6, 2017

INTELLICHECK MOBILISA, INC., Plaintiff,
v.
HONEYWELL INTERNATIONAL INC, Defendant.

          Amber N. Davis Attorneys for Plaintiff.

          David R. Yohannan Attorneys for Defendant.

          STIPULATED PROTECTIVE ORDER

          James L. Robart Judge.

         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 Stipulated Protective Order is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery. The protection this Stipulated Protective Order 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". "ATTORNEYS EYES ONLY" AND "SOURCE CODE" INFORMATION

         2.1 "Confidential Information" shall include the following documents and tangible things produced or otherwise exchanged:

a) Information about the producing party's policies or practices;
b) Requests for proposals and responses thereto;
c) Information regarding the producing party's product development, design or specifications;
d) Any information which the producing party is obligated by contract or state or federal law to keep confidential;
e) Employee training and evaluation materials;
f) Medical records or other personal information of any employee, customer or other person; or
g) Information about the producing party's information technology (IT) systems

         2.2 "Attorneys Eyes Only Information": The Parties acknowledge that there may be information produced in discovery for which a higher level of protection is required; such information may be designated as "Attorneys Eyes Only Information". Attorneys Eyes Only Information designations should be used only for sensitive technical, financial, competitive, or personnel information, which is not generally known by third parties and that the Producing Party would not normally reveal to third parties or would cause third parties to maintain in confidence either by agreements, policies, or procedures. Attorneys Eyes Only Information materials shall include the following documents and tangible things produced or otherwise exchanged:

a) Design files, design drawings, design specifications, manufacturing techniques, laboratory notebooks, prototypes and information related thereto;
b) The financial books and records of the producing party and financial information pertaining to the financial books and records;
c) Information about the revenues, costs, expenses, profits and losses of the producing party;
d) Pricing information;
e) Accounting information that is not made publicly available;
f) Information about the volume and types of sales, sales leads or sales incentives or sales goals;
g) Business and marketing plans or analyses, surveys, customer communications;
h) Short and long-term business plans;
i) Marketing strategies and plans;
j) Information regarding the producing party's customers and competitors;
k) Contracts that the producing party has with customers, drafts thereof, and communications concerning such drafts and contracts;
l) Licensing agreements;
m) Contracts that the producing party has with suppliers, vendors, contractors, or subcontractors, drafts thereof, and communications concerning such drafts and contracts;
n) Materials submitted to regulatory agencies for which heightened Attorneys' Eyes Only protection is necessary.

         2.3 "Highly Confidential Source Code Information" means computer source code and/or live data information (that is, data as it exists residing in a database or databases) and information related to source code and/or live data information, which is to be protected in the same manner as Attorneys' Eyes Only Information, subject to additional protections provided below.

         3. SCOPE

         The protections conferred by this Stipulated Protective Order cover not only Confidential Information, Attorneys' Eyes Only Information and Highly Confidential Source Code Information (collectively, "Protected Information")(as defined above), but also (1) any information copied or extracted from Protected Information; (2) all copies, excerpts, summaries, or compilations of Protected Information; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Protected Information. However, the protections conferred by this Stipulated Protective Order do not cover (i) information that is in the public domain or becomes part of the public domain through trial or otherwise; (ii) information that the receiving party can show was obtained (without being derived from, benefiting from, or using Protected Information) from a third party having the right to disclose such information to the receiving party without restriction or obligation of confidentiality; (iii) information which, after its disclosure to a receiving party, is published to the general public by ...


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