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Sandisk Corporation v. Round Rock Research LLC

May 14, 2012

SANDISK CORPORATION,
PLAINTIFF AND COUNTERCLAIM DEFENDANT,
v.
ROUND ROCK RESEARCH LLC,
DEFENDANT AND COUNTERCLAIM PLAINTIFF.



The opinion of the court was delivered by: Honorable Richard Seeborg United States District Judge

[PROPOSED] STIPULATED PROTECTIVE ORDER

confidential, proprietary, or private information for which special protection from public disclosure 28 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly,

1. PURPOSES AND LIMITATIONS.

Disclosure and discovery activity in this action are likely to involve production of SanDisk Corporation and Round Rock Research LLC hereby stipulate to and petition the court to 2 enter the following Stipulated Protective Order. The parties acknowledge that this Order does not 3 confer blanket protections on all disclosures or responses to discovery and that the protection it 4 affords from public disclosure and use extends only to the limited information or items that are 5 entitled to confidential treatment under the applicable legal principles. The parties further 6 acknowledge, as set forth in Section 14.4 below, that this Stipulated Protective Order does not entitle 7 them to file confidential information under seal; Civil Local Rule 79-5 and General Order 62 set 8 forth the procedures that must be followed and the standards that will be applied when a party seeks 9 permission from the court to file material under seal. 10

information or items under this Order. 13

generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 15

2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff).

2. DEFINITIONS.

2.1 Challenging Party: a Party or Non-Party that challenges the designation of

2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is Civil Procedure 26(c).

2.4 Designated House Counsel: House Counsel who seek access to "HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY" information in this matter. 20 21 produces in disclosures or in responses to discovery as "CONFIDENTIAL," "HIGHLY 22 CODE." 24

25 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 26 transcripts, and tangible things), that are produced or generated in disclosures or responses to 27 discovery in this matter. 28

2.5 Designating Party: a Party or Non-Party that designates information or items that it

CONFIDENTIAL -- ATTORNEYS' EYES ONLY," or "HIGHLY CONFIDENTIAL -- SOURCE 23

2.6 Disclosure or Discovery Material: all items or information, regardless of the medium 2 the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a 3 consultant in this action, and (2) at the time of retention, is not anticipated to become an employee of 4 a Party or of a Party's competitor. 5

2.8 "HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY" Information or Items:

6 sensitive "Confidential Information or Items," disclosure of which to another Party or Non-Party 7 would create a substantial risk of serious harm that could not be avoided by less restrictive means.

2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to

2.9 "HIGHLY CONFIDENTIAL -- SOURCE CODE" Information or Items: sensitive

"Confidential Information or Items" representing computer code and associated comments and 10 revision histories, formulas, engineering specifications, or schematics that define or otherwise 11 describe in detail the algorithms or structure of software or hardware designs, disclosure of which to 12 another Party or Non-Party would create a substantial risk of serious harm that could not be avoided 13 by less restrictive means. 14

15

2.10 House Counsel: attorneys who are employees of a party to this action. House

Counsel does not include Outside Counsel of Record or any other outside counsel. 16

entity not named as a Party to this action. 18

19 of a party to this action but are retained to represent or advise a party to this action and have 20 appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on 21 behalf of that party. 22

23 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 24

2.11 Non-Party: any natural person, partnership, corporation, association, or other legal

2.12 Outside Counsel of Record: attorneys who are not employees, partners or principals

2.13 Party: any party to this action, including all of its officers, directors, employees,

2.14 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

Material in this action. 26

2.15 Professional Vendors: persons or entities that provide litigation support services

(e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 28 storing, or retrieving data in any form or medium) and their employees and subcontractors.

CONFIDENTIAL -- SOURCE CODE." 4

2.16 Protected Material: any Disclosure or Discovery Material that is designated as

"CONFIDENTIAL," "HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY," or "HIGHLY 3

2.17 Receiving Party: a Party that receives Disclosure or Discovery Material from a

Producing Party. 6

8 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 9 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 10 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 11

However, the protections conferred by this Stipulation and Order do not cover the following 12 information: (a) any information that is in the public domain at the time of disclosure to a Receiving 13

Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 14 publication not involving a violation of this Order, including becoming part of the public record 15 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 16 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 17 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 18

Protected Material at trial shall be governed by a separate agreement or order. 19

3. SCOPE.

The protections conferred by this Stipulation and Order cover not only Protected Material (as

4. DURATION.

Even after final disposition of this litigation, the confidentiality ...


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