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Hsiu Pen Yang, and Sonar Autoparts Co., Ltd v. Winjet Automotive

September 12, 2011

HSIU PEN YANG, AND SONAR AUTOPARTS CO., LTD., PLAINTIFFS,
v.
WINJET AUTOMOTIVE, INC., K2 MOTOR CORP. D.B.A. SPEC-D TUNING, AND DOES 1-19 DEFENDANTS.



The opinion of the court was delivered by: Suzanne H. Segal United States Magistrate Judge

[Discovery Document: Referred to Magistrate Judge Suzanne H. Segal].

(REVISED) STIPULATED PROTECTIVE ORDER

WHEREAS, discovery in this action will involve production of confidential, proprietary and private information for which special protection from public disclosure may be warranted;

WHEREAS, plaintiffs Hsiu Pen Yang and Sonar Autoparts Co., Ltd. ("Plaintiffs") and defendant Winjet Automotive, Inc. ("Defendant") (collectively, the "Parties") have negotiated the terms of a protective order, and respectfully request that the Court approve of such terms between the Parties;

WHEREAS, the Parties agree that the protection afforded by this order be extended to additional parties that have or will be appearing in this case, including defendant K2 Motor Corp. d.b.a. SPEC-D TUNING, which was served and is expected to file its responsive pleading on or before September 15, 2011;

WHEREAS, the Parties have revised this protective order pursuant to the conditions and requirements set forth in the Court's July 26, 2011 Order (denying the originally submitted protective order by the Parties);

NOW, THEREFORE, the Parties stipulate to the entry of the following protective order, subject to the approval of the Court.

GOOD CAUSE STATEMENT. The Parties respectfully submit that good cause exists for entry of this stipulated protective order. In order to determine its alleged/claimed damages, Plaintiffs have sought from Defendant information relating to its sale of certain products that Plaintiffs have accused Defendant of infringing or otherwise violating its intellectual property rights; such information includes without limitation invoices, purchase orders, and balance sheets reflecting net profits, each of which Defendant maintains cannot be made accessible to the public without harming its business. In addition, given the nature of Plaintiffs' claims, the Parties anticipate that as discovery proceeds, they may be asked to produce additional information or documents that consist of or contain sensitive financial information or trade secrets. The Parties respectfully submit that this stipulated protective order will facilitate the efficient exchange of relevant information and documents, without improperly undermining public access to non-confidential information.

IT IS HEREBY STIPULATED AND AGREED:

Charles R. Sutton Law Offices of Roger C. Hsu 201 S. Lake Ave, Suite 600 Pasadena, CA 91101 (626) 792-7936 arttorney@hotmail.com Charles C.H. Wu (SBN 166756) Mark H. Cheung (SBN 150690) Vikram M. Reddy (SBN 228515) Law Offices Of Wu & Cheung, LLP 98 Discovery Irvine, California 92618-3105 Telephone: (949) 251-0111 Email: info@wclawyers.com

PROTECTIVE ORDER

WHEREAS, the Court, having considered the above stipulation and the protective order set forth herein, and having determined that "good cause" has been shown;

IT IS HEREBY ORDERED THAT:

1. "Confidential Information" as used herein means confidential financial information or information consisting of or containing trade secrets, as that term is defined in Section 3426.1 of California Civil Code. Use of Confidential information during the litigation of this case, Hsiu Pen Yang, et al. v. Winjet Automotive, Inc., et al., Case No. CV 10-6197 JHN (CSSx) (hereinafter, the "Litigation") shall be governed by this Protective Order.

2. In the case of documents, interrogatory answers, and answers to requests for admissions, the Parties shall designate Confidential Information as such by stamping the Confidential Information as "CONFIDENTIAL."

3. Deposition Testimony.

(a) Depositions that counsel, in good faith, believes contains Confidential Information shall be designated as Confidential by counsel making a statement for inclusion in the deposition transcript or, within ten (10) calendar days after receipt of the transcript, by counsel designating by page and line, the Confidential Information contained in the deposition transcript by means of a "CONFIDENTIAL" stamp or legend.

(b) At the request of counsel for any Party, all persons other than those to whom disclosure of Confidential Information is permitted under the terms of this Protective Order shall be excluded from a deposition whenever Confidential Information is to be disclosed or discussed.

4. Use of Confidential Information at Hearings or Trial.

(a) At any proceeding before the Court in connection with this Litigation, counsel for the Parties may, subject to the rules of evidence, disclose or refer to Confidential Information in accordance with the terms of ...


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