UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
September 15, 2011
IMPLICIT NETWORKS, INC.,
JUNIPER NETWORKS, INC.,
The opinion of the court was delivered by: Hon. Susan Illston United States District Court Judge
Action filed: September 20, 2010
AGREED STIPULATION REGARDING PATENT LOCAL RULE 2-2 INTERIM MODEL PROTECTIVE ORDER
WHEREAS Patent Local Rule 2-2 provides that the Northern District Interim Model Protective Order ("Model Protective Order") governs this case and will continue to govern unless 3 the parties agree otherwise;
WHEREAS, paragraph 8 of the Model Protective Order imposes a prosecution bar applicable to "the subject matter of the invention and of highly confidential technical information to be produced";
WHEREAS, for the avoidance of doubt, the parties wish to memorialize their agreement regarding the subject matter of the prosecution bar in this case;
THEREFORE, the parties hereby stipulate that "the subject matter of the invention and of 10 highly confidential technical information to be produced," for purposes of the Model Protective
Order in this case (including paragraph 8) is "data demultiplexing, or network routers, switches, 12 and security products, including the operating system and software used to control network 13 routers, switches, or security products." Moreover, the parties are agreed and hereby stipulate that 14 this definition of the subject matter of the prosecution bar shall apply in this case retroactively and 15 going forward as if inserted in full as appropriate into paragraph 8 of the Model Protective Order, 16 and shall be enforceable as if fully set forth therein.
DATED: September 13, 2011 HOSIE RICE LLP
By: /s/ George F. Bishop George F. Bishop Attorneys for Plaintiff Implicit Networks, Inc. IRELL & MANELLA LLP By: /s/ Nima Hefazi____ Nima Hefazi Attorney for Defendant Juniper Networks, Inc.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
© 1992-2011 VersusLaw Inc.