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Shotwell v. Zillow Group, Inc.

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

November 7, 2019

JAMES SHOTWELL, et al., Plaintiff,
v.
ZILLOW GROUP INC., et al., Defendant.

          Colin M. George ARDENT LAW GROUP, PLLC Local Counsel for Lead Plaintiffs

          Laurence M. Rosen Jonathan Stern THE ROSEN LAW FIRM, P.A. Lead Counsel for Lead Plaintiffs

          Sean C. Knowles, WSBA No. 39893 PERKINS COIE LLP Matthew D. Ingber (pro hac vice) Joseph De Simone (pro hac vice) MAYER BROWN LLP Kelly Kramer (pro hac vice) Stephanie C. Robinson (pro hac vice) MAYER BROWN LLP Counsel for Defendants

          ORDER

          JOHN C. COUGHENOUR, JUDGE

         Pursuant to the parties' stipulation and proposed order (Dkt. No. 72), the Court ENTERS the following protective order:

         1. PURPOSES AND LIMITATIONS

         a. Disclosure and discovery activity in this action may involve production of confidential information under Fed.R.Civ.P. 26(c)(1)(G). Accordingly, the parties stipulate to and jointly request that the Court enter the following Stipulated Protective Order governing the handling of documents, deposition testimony, deposition exhibits, interrogatory responses, responses to requests for admission, responses to requests for production, and other written, recorded, graphic, or electronic matter or information produced, filed with, or submitted to the Court or given or exchanged by and among the parties (collectively, “discovery material”) including discovery material produced by non-parties to the litigation. 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.

         b. All discovery material received by any party, including discovery material designated as “confidential” or “highly confidential, ” or information summarizing, referencing, or incorporating confidential discovery material and/or highly confidential discovery material, must be used solely for purposes of the litigation, including any appeal or retrial, and must not be used for any business, commercial, or other purpose, or for other litigation.

         c. When used in this Protective Order, the word “document” has the same meaning as in Rule 34 of the Federal Rules of Civil Procedure, and includes, without limitation, all original written, recorded, electronic, or graphic materials, and all copies, duplicates, or abstracts of these materials, including, but not limited to, notes on these materials.

         d. In this Protective Order, a person or entity that produces or discloses discovery material in the litigation is referred to as the “producing party, ” and the recipient of any discovery material in the litigation is referred to as the “receiving party.” e. This Protective Order does not address the use of protected material (as defined herein) at trial. The parties agree to meet and confer regarding the use of protected material at trial and to raise the issue with the Court at an appropriate time.

         f. Entering into this stipulated Protective Order and producing or receiving protected material or otherwise complying with the Protective Order does not:

1. operate as an admission by any party that any particular materials designated as “confidential” or “highly confidential” contain or reflect trade secrets or any other type of protected material;
2. prejudice in any way the rights of parties to object to the production of documents they consider not properly subject to discovery, or operate as an admission by any party that the restrictions and procedures in this Protective Order constitute adequate protection for any particular information deemed by any party to be protected material;
3. prejudice in any way the rights of any party to object on confidentiality, relevancy, or any other grounds to the production of any discovery material;
4. prejudice in any way the rights of a party to obtain a determination by the Court whether any discovery material is, should, or should not continue to be subject to this Protective Order;
5. prejudice in any way the rights of a party to petition the Court for a further protective order relating to any discovery material; or
6. prevent the parties, subject to Court approval from agreeing to alter or waive the provisions of this Protective Order with respect to any particular discovery material.

         g. Subject to the receiving party's right to object or raise arguments regarding waiver, this Protective Order has no effect upon, and does not apply to, each party's use of its own protected material (as defined below) for any purpose.

         2. PROTECTED MATERIAL-“CONFIDENTIAL” AND “HIGHLY CONFIDENTIAL”

         a. “Protected material” includes both “confidential discovery material” and “highly confidential discovery material.”

         b. “Confidential material” includes the following discovery material containing:

1. Personally identifying information of the producing party or the producing party's employees or customers;
2. Data regarding compensation earned by or paid to employees;
3. Data reflecting sales of products and services;
4. Customer account information, such as names, telephone numbers, contracts, account numbers, or balances;
5. Information about the producing party's computer information systems (including but not limited to systems and applications used in managing commission and compensation functions), general hardware and software specifications, and related instructions and training information;
6. Employee trainings, internal policies, and evaluation ...

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