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Fish, LLC v. Harbor Marine Maintenance & Supply, Inc.

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

March 14, 2018

FISH, LLC, et al., Plaintiffs,
v.
HARBOR MARINE MAINTENANCE & SUPPLY, INC., Defendant.

          STIPULATED PROTECTIVE ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE

         Come now the parties by and through their undersigned counsel of record and submit the following Stipulated Protective Order.

         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 Local Rule 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:

(a) transfer pricing documentation, distribution agreements, agency agreements, management services agreements, and other business contracts, agreements and memoranda;
(b) invoices;
(c) financial statements;
(d) tax returns and filings, including supporting documentation;
(e) customer names, sales volume and pricing information;
(f) business plans and budgets;
(g) pending patent application, filings and supporting documents, R&D studies and results, product development information;
(h) any other business records containing financial, proprietary or otherwise confidential business information.

         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 ...


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