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TYLT, Inc. v. Wireless Advocates, LLC

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

September 25, 2019

TYLT, INC. Plaintiff,

          HARRIGAN LEYH FARMER & THOMSEN KARR TUTTLE CAMPBELL LLP, Farhad Novian, Andrew B. Goodman, Attorneys for Tylt, Inc.

          KARR TUTTLE CAMPBELL, Nuthan T. Paine, Michael M. Feinberg, Michael M. Feinberg, Attorneys For Wireless Advocayes LLC and Car Toys, inc.




         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.


         "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged: "Confidential" materials may include documents and tangible things that contain (1) non-public business information (i.e. trade secrets) 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; (2) documents, such as contracts with third parties, that contain a confidentiality provision; (3) communications with employees or third parties where the producing party has a good faith basis to believe that said employee or third party had a reasonable expectation of confidentiality at the time the communication was sent or received; (4) commercially sensitive and/or non-public contractual terms with customers, vendors, advertising platforms, and other parties; (5) commercially sensitive pricing, financial, and/or profit information; (6) commercially sensitive information regarding suppliers and supplier lists; (7) commercially sensitive information regarding customers, customer lists, customer usage, and customer technical requirements; (8) commercially sensitive product development information and information relating to new products and programs; (9) commercially sensitive marketing plans, business plans, forecasts, and business strategies; (10) commercially sensitive communications and information relating to products and services, including, but not limited to, marketing data, which in the hands of competitors would be valuable; (11) sensitive internal financial reporting; or (12) private/personally identifiable information protected by federal, state, or local law, including a person's date of birth, Social Security Number, home address, home phone number, medical information, or other sensitive personal data. Some examples of documents and things that contain such information are: financial plans, financial statements and related documents (including but not limited to balance sheets, cash receipts and disbursements, budgets and budget reconciliations, and income statements), pricing information, sales information, documentation used to create bids, profit and loss information, costs information, tax information, bank records, investor information and communications with investors, member information and communications with members, technical practices, technical methods, technical plans and designs, trade secrets and other sensitive trade and pricing information, minutes of confidential meetings, communications with insurers, employment reviews, personnel records, and medical records.

         "Highly Confidential" material means any Confidential material which the producing party reasonably believes to be so competitively sensitive that it is entitled to additional protection via an "Attorneys' Eyes Only" or "Outside Counsel Only" designation.

         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.


         4.1 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 ...

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