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Tile Tech Inc. v. Appian Way Sales Inc.

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

March 21, 2018

TILE TECH, INC, a California Corporation, Plaintiff,
v.
APPIAN WAY SALES, INC., a Washington Corporation, and PUGET LITE-PAVERS, INC., a Washington Corporation, Defendants. and APPIAN WAY SALES, INC, a Washington Corporation, APPIAN WAY, LLC, a Washington Limited Liability Company, and PUGET LITE-PAVERS, INC., a Washington Corporation, Coimterelaimants.
v.
TILE TECH, INC., a California Corporation, Counter-Defendant

          Kelly W. Cunningham (pro hac vice), C. Wook Pak (pro hac vice), CISLO & THOMAS LLP, Marc C. Levy, WSBA No. 19203, Thomas A. Shewmake, WSBA No. 50765 SEED IP LAW GROUP LLP, Attorneys for Tile Tech, Inc.

          Jeff E. Schwartz, Esq. (admitted pro hac vice) Austen C. Endersby, Esq. (admitted pro hac vice;, licensed in DE only) FOX ROTHSCHILD LLP, James E. Doroshow, Esq. (admitted pro hac vice), FOX ROTHSCHILD LLP, Gavin W. Skok, WSBA No. 29766 FOX ROTHSCHILD LLP, Attorneys for Appian Way Sales, Inc., Appian Way, LLC, and Puget Lite-Pavers, Inc.

          STIPULATED PROTECTIVE ORDER

          Hon. James L. Robart, United State s District Court 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 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" and "HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY" MATERIAL

         2.1 "Confidential" material means information, documents, and things the designating party believes in good faith constitutes confidential research, development, or commercial information that is maintained in confidence by the designating party and not generally known to others. Confidential material shall include the following documents and tangible things produced or otherwise exchanged:

a) Information, about the producing party's policies or practices;
b) Information regarding the producing party's product development, design or specifications for past or present commercial products;
c) Any information which the producing party is obligated by contract or state or federal law to keep confidential;
d) Any financial documents not designated as Highly Confidential -Attorneys' Eyes Only.

         2.2 "Highly Confidential - Attorneys' Eyes Only" material: 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 "Highly Confidential - Attorneys' Eyes Only" information. Highly Confidential - Attorneys' Eyes Only 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. Highly Confidential - Attorneys' Eyes Only information shall include the following documents and tangible things produced or otherwise exchanged:

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

         3. SCOPE

         The protections conferred by this Stipulated Protective Order cover not only Confidential material and Highly Confidential - Attorneys' Eyes Only material (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 which, after its disclosure to a receiving party, is published to the general public by a party having the right to publish such information; or (iii) information that the receiving party can show by written record was independently developed ...


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