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Sure-Fire, LLC v. Advanced Armament Corp.

August 25, 2009

SURE-FIRE, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY, PLAINTIFF,
v.
ADVANCED ARMAMENT CORP., A GEORGIA CORPORATION, DEFENDANT.



The opinion of the court was delivered by: Hon. Robert N. Block Magistrate Judge, United States District Court

Assigned to Hon. David O. Carter

[PROPOSED] STIPULATED PROTECTIVE ORDER

Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and the stipulation of the parties hereto, the Court hereby enters the following Protective Order:

1. This Protective Order shall apply to all documents, information, or other things subject to discovery in this action ("Discovery Material") that contain proprietary, confidential or commercially sensitive information not known to the general public, comprising or containing trade secrets or other confidential research and development, know-how, financial results or that a Producing Party is under an obligation to a third party to maintain as confidential, as well as deposition testimony and other information designated as either "CONFIDENTIAL" or "CONFIDENTIAL OUTSIDE COUNSEL ONLY." As used herein, "Producing Party" shall refer to the Parties to this action or Third Parties who disclose information in this action. "Receiving Party" shall refer to the Parties to this action who receive Discovery Material from a Producing Party.

2. Any party or other person producing or disclosing Discovery Material may designate it as set forth herein as (a) "CONFIDENTIAL" or (b) "CONFIDENTIAL OUTSIDE COUNSEL ONLY" subject to this Protective Order if it contains confidential, proprietary or commercially sensitive information, market-sensitive information and/or trade secrets.

3. In the absence of written permission from the Producing Party, Discovery Material designated as either "CONFIDENTIAL" or "CONFIDENTIAL OUTSIDE COUNSEL ONLY":

(a) Shall be protected from disclosure as specified herein, unless the Producing Party so states in writing, or a party obtains an Order of the Court declaring that all or certain portions of such Discovery Material are not, in fact, protected or should be subject to an alternative designation.

(b) Shall be used only for purposes of this litigation. (c) Shall not be used in connection with the prosecution of any patent application (whether original, continuation, or reissue) by a Receiving Party, nor shall it be used in connection with any other proceeding before the U.S. Patent and Trademark Office ("PTO") except by further order of the Court or the written consent of the Producing Party in a signed writing. Should the disclosure of discovery material trigger a duty to disclose information to the PTO under 37 C.F.R. § 1.56, written consent of the Producing Party shall not be unreasonably withheld.

4. The Producing Party may designate documents or other tangible Discovery Materials by placing the following legend or similar legend on the document or thing: "CONFIDENTIAL" or "CONFIDENTIAL OUTSIDE COUNSEL ONLY":

(a) In the event that original documents are produced for inspection, the Producing Party may designate such documents by placing the appropriate legend on the documents in the copying process;

(b) Written discovery may be designated by placing the following legend on every page of any such document prior to production: "CONFIDENTIAL" or "CONFIDENTIAL OUTSIDE COUNSEL ONLY."

(c) All information disclosed during a deposition shall be deemed CONFIDENTIAL OUTSIDE COUNSEL ONLY on a provisional basis until the time within which it may be designated as CONFIDENTIAL or CONFIDENTIAL OUTSIDE COUNSEL ONLY has passed. Any party or third party may designate any specific passages of the transcript as CONFIDENTIAL or CONFIDENTIAL OUTSIDE COUNSEL ONLY in writing within ten days after receipt of the final version of the transcript. Any testimony not so designated within ten days after receipt of the final version of the transcript may be treated as non-confidential. No party or third party can preserve confidentiality of the deposition by a blanket designation of confidentiality that does not differentiate between confidential and non-confidential portions of the transcript.

5. A Producing Party may designate material as CONFIDENTIAL if the material is proprietary or commercially sensitive information. Discovery Material designated as "CONFIDENTIAL" may be disclosed to:

(a) The outside attorneys working on this action on behalf of any party, including paralegals, and clerical employees working under the direct supervision of such counsel;

(b) Any person not employed by or affiliated with a party who is expressly retained or sought to be retained by any attorney described in paragraph 5(a) to assist in preparation of this action for trial as a consultant or testimonial expert, with disclosure only to the extent necessary to perform such work;

(c) The following party representatives, two per side, and their respective secretarial, clerical and paralegal personnel, but only after compliance with the provisions of paragraph 7 below:

SureFire, LLC:

1. Barry Dueck

2. Loreen Collins Advanced Armament Corp.:

1. Kevin Brittingham

2. Robert ...


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