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United Command International, Ltd. v. Microfun Inc.

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

October 3, 2019

UNITED COMMAND INTERNATIONAL, LTD, a UK Private Limited Company, Plaintiff,
v.
MICROFUN INC., a Washington corporation, and BEIJING MICROFUN CO. LTD, a corporation of the People's Republic of China, Defendants.

          Robert J. Carlson, #18455 Lee & Hayes, P.C. Attorneys for Plaintiff United Command International, Ltd.

          J. Michael Keyes, #29215 Erin Kolter, # 53365 Dorsey & Whitney LLP Attorneys for Defendants Microfun Inc., and Beijing Microfun Co. Ltd.

          (PROPOSED) STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK, UNITED STATES DISTRICT JUDGE.

         1. PURPOSE 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 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. DESIGNATED MATERIALS

         2.1 Categories of Confidential Information.

         A party or non-party responding to a discovery request made pursuant to the Federal Rules of Civil Procedure (a "Producing Party") shall have the right to designate documents and information it produces as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" pursuant to this Order and materials designated as such will be referred to as "Designated Material" or "Designated Materials."

         2.1.1 CONFIDENTIAL. "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged:

a. Documents that could disclose to competitors confidential information concerning the prices charged to potential customers, business plans and strategy of a Producing Party or of the person from whom the Producing Party obtained the document;
b. Confidential internal documents relating to finances of a Producing Party or of the person from whom the Producing Party obtained the document, including internal financial reports and analyses;
c. Agreements or documents containing confidential information of a Producing Party or of the person from whom the Producing Party obtained the document that could disclose to competitors confidential information concerning specific financial terms;
d. Confidential internal documents of a Producing Party or of the person from whom the Producing Party obtained the document related to financial and sales data, peer group analyses and franchisee sales and performance comparison data; a party or non-parties' personal financial information; financial or personal information (including but not limited to, private personal information (PPI), social security numbers, driver's license numbers, bank and credit card numbers, tax information, disability information, and other intimate information not publicly available); information and documents that a party is legally or contractually required to keep confidential; documents and information that are in good faith believed to constitute or contain proprietary business information of a Producing Party or of the person from whom the Producing Party obtained the document.

         2.1.2 HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY. "Highly Confidential - Attorneys' Eyes Only" materials shall comprise the following documents and tangible things produced or otherwise exchanged, which are highly confidential to the proprietary and/or commercial rights of the Producing Party or of the person from whom the Producing Party obtained the document:

a. Documents and information demonstrating marketing strategy, development, and/or research of a Producing Party or of the person from whom the Producing Party obtained the document;
b. Documents and information demonstrating business methodology, processes, and procedures for commercializing products on behalf of customers (e.g., trade secrets) of a Producing Party or of the person from whom the Producing Party obtained the document;
c. Internal financial information of a Producing Party or of the person from whom the Producing Party obtained the document, including but not limited to, revenues, expenses, profits and other details regarding financial performance.

         2.2 SCOPE

         The protections conferred by this agreement cover not only Designated Material (as defined above), but also (1) any information copied or extracted from Designated Material; (2) all copies, excerpts, summaries, or compilations of Designated Material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Designated 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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