The opinion of the court was delivered by: Magistrate Judge Jay C. Gandhi
STIPULATED PROTECTIVE ORDER
Discovery Document - Referred to
The Court hereby ORDERS that, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, any person subject to this Order-including without limitation the parties to this action, their representatives, agents, experts and consultants, and all persons acting in concert or participation with them-shall adhere to the following terms:
1. Any person subject to this Order who receives from any other person any "Confidential Information" shall not disclose such Confidential Information to anyone else except as expressly permitted hereunder.
2. "Confidential Information" is defined as "Litigation Materials" that would disclose: (a) information that a party is obligated to treat as confidential pursuant to an agreement with a non-party; (b) "trade secrets" of a party; or (c) confidential research, development, or commercial information of a party. Confidential Information includes original information having a confidentiality designation, and any copy, derivative or abstract, as well as any notes, briefs, or references for which that information is the source.
3. "Litigation Materials" is defined as information of any kind that becomes part of the record of these proceedings, is provided by any party in the course of discovery, or is otherwise disclosed in these proceedings pursuant to the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the Central District of California, or a Court order, and which can include documents, things, or testimony.
4. A "trade secret" is defined as information that:
a. derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable via proper means by, other persons who can obtain economic value from its disclosure or use; and
b. is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.
5. Examples of "trade secrets" include:
a. marketing, financial, service and strategic plans, including proposed or draft advertising or packaging, marketing budgets and proposals, proposed or suggested price changes, and anticipated or projected production volumes and sales;
b. market analyses and projections, including product focus group studies;
c. financial information, including manufacturing costs and profits;
d. customer and distributor information, including customer and distributor lists, and customer and ...