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SRC Labs, LLC v. Amazon Web Services, Inc

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

June 7, 2018

SRC LABS, LLC & SAINT REGIS MOHAWK TRIBE, Plaintiffs,
v.
AMAZON WEB SERVICES, INC., AMAZON.COM, INC., & VADATA INC., Defendants.

          Carmen E. Bremer, WSBA 47, 565 Michael W. Shore (admitted; pro hac vice) Alfonso G. Chan (admitted pro hoc vice) Christopher Evans (admitted pro hac vice) Andrew Howard (admittedpro hac vie) SHORE CHAN DEPUMPO LLP Attorneys for Plaintiffs SRC Labs, LLC

          FENWICK & WEST LLP J. David Hadden (admitted pro hac vice) Saina S. Shamilov (admitted pro hac vice) Ravi Ranganath (admittedpro hac vice) Clay Venetis (admitted pro hac vice) Todd R. Gregorian (admitted pro hac vice) Dargaye Churnet (admitted pro hac vice) Shannon Turner (admitted pro hac vice) Jessica M. Kaempf, WSBA No. 51666 Attorneys for Defendants Amazon Web Services, Inc., Amazon.com, Inc., & Vadata, Inc.

          PROTECTIVE ORDER JURY TRIAL DEMANDED

          Honorable J imes L. Robart United States District Court Judge

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for winch special protection may be warranted. 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.

         2. CONFIDENTIAL MATERIAL

         Confidential materials may be designated "CONFIDENTIAL, " "HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY/' or "CONFIDENTIAL SOURCE CODE."

         2.1. CONFIDENTIAL materials may include documents and tangible things that contain non-public business information that is treated confidentially by the producing party in the ordinary course of business and whose disclosure may cause the producing party to be commercially disadvantaged or prejudiced. Some examples of CONFIDENTIAL materials are; trade secrets, technical information, technical practices, technical methods, know-how, product research, product design, product formulas, product testing, product development, product manufacturing, minutes of confidential board meetings, minutes of confidential officer meetings, minutes of confidential employee meetings, pricing, finances, taxes, sales, profits, costs, licensing agreements, licensing negotiations, customers, customer lists, market projections, market forecasts, strategic plans, and marketing strategies.

         2.2. HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY materials are limited to materials that qualify as CONFIDENTIAL materials and whose disclosure to another party or non-party would create a substantial risk of serious harm that could not be avoided by less restrictive means.

         2.3 CONFIDENTIAL SOURCE CODE materials are limited to materials that qualify as HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY materials that contain human-readable programming language text that defines software, firmware, or electronic hardware descriptions, 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. Examples include, but are not limited to, files containing source code written in "C, " "C, " assembler, VHDL, Verilog, and digital signal processor ("DSP") programming languages, as well as ".include" files, "make" files, link files, and other human-readable text files used in the generation and/or building of software directly "executed on a microprocessor, micro-controller, or DS"FrSource code does not include"binary executable files and object code files, nor does it include tools such as compilers or linkers.

         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 other than as a result of a disclosure by the receiving party in violation of this Order, including through, trial. The protections afforded by this Order also cover and will continue to cover information disclosed in breach of the provisions of this order.

         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, when not in the custody of the receiving party's counsel of record, must be stored and maintained by a receiving party at a location in the United States (or at a mutually agreed 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) no more than three of the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgement and Agreement to, Be Bound" (Exhibit A), unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;

         (c) experts and consultants to whom disclosure is reasonably necessary for this litigation and with regard to whom the procedures set forth in Section 4.4 below have been followed;

         (d) the court, court personnel, and court reporters and their staff;

         (e) professional vendors, professional jury or trial consultants, and mock jurors to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A);

         (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed by the designating party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal confidential material must be separately bound by ...


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