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Large Audience Display Systems, LLC v. Tennman Productions

May 15, 2012

LARGE AUDIENCE DISPLAY SYSTEMS, LLC PLAINTIFF,
v.
TENNMAN PRODUCTIONS, LLC, JUSTIN TIMBERLAKE, LOS ANGELES LAKERS, INC., BRITNEY TOURING, INC., BRITNEY SPEARS, STEVE DIXON AND MUSIC TOUR MANAGEMENT, INC., DEFENDANTS.



[PROPOSED] PROTECTIVE ORDER

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

BASED UPON THE STIPULATION OF THE PARTIES, AND GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that any person or party subject to this Order -- including without limitation the parties to this action, their representatives, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order -- shall adhere to the following terms:

1. Overview: Any person or party subject to this Order who receives from any other person or party any information of any kind provided in the course of discovery in the action (hereinafter "Discovery Material") that is designated as "Confidential" and/or "Highly Confidential/Attorneys' Eyes Only" pursuant to the terms of this Order (hereinafter, the "Confidential Information" or "Confidential Discovery Material") shall not disclose such Confidential Information to anyone else except as expressly permitted hereunder.

2. Material Designated As "Confidential"

(a) The person or party disclosing or producing any given Discovery Material may designate as "Confidential" such portion of such material as the person or party in good faith believes includes information that is not available to the public and is confidential, proprietary, commercially sensitive, or constitutes a trade secret and is contained within one of the following categories:

(1) Confidential Financial Information: Information, maintained by the producing party in confidence, and relating to: amounts spent on research, development, marketing, promotion, and advertising; sales and revenues; profits and losses; employee salaries and bonuses;

(2) Confidential Research and Development: Information, maintained by the producing party in confidence, and relating to: conception, research, and development of brands, products, tour components, set designs, goods and/or services; or

(3) Confidential Commercial / Trade Secret Information: Information, maintained by the producing party in confidence, and relating to: customer lists; customers, licensors, or other third parties with whom the producing party has contracted in connection with its intellectual property, products, goods and/or services; the manufacture and distribution of the producing party's products, goods and/or services; advertising, marketing, and/or promotional plans associated with the producing party's intellectual property, products, goods and/or services.

(b) The parties, or some of them, request protection of such information on the grounds that if disclosed it could be harmful to the parties, or any of them, and that said information, if disclosed, could be helpful to the competitors of the parties, or any of them, and that said information therefore requires special protection from disclosure pursuant to F.R.C.P. 26(c).

(c) Good Cause Statement: Good cause exists for protecting the confidential financial, research and development, and commercial / trade secret information described above. The information described has been maintained in confidence by the producing party and its disclosure would result in prejudice or harm to that party. Specifically, good cause exists for protecting the information described above based on the following:

(1) Confidential Financial Information: The Confidential Financial Information includes information protected by third parties' rights of privacy under the Constitutions of the United States and the State of California and its disclosure could subject the producing party to civil liability. Further, disclosure of Confidential Financial Information, except pursuant to the Protective Order signed by all Parties receiving the Confidential Information, would cause substantial harm to the competitive position of the producing party by revealing areas of financial strength and weakness of the producing party, as well as that party's strategic decision-making regarding, inter alia, personnel, employment of outside consultants, expenditures on research and development, and expenditures on marketing and advertising;

(2) Confidential Research and Development Information: The producing party has expended valuable time and resources developing their respective brands, products, goods and/or services. Disclosure of information relating to those efforts, except pursuant to the Protective Order signed by all Parties receiving the Confidential Information, would cause substantial harm to the competitive position of the producing party by allowing their competitors to utilize the fruits of the parties efforts, without incurring any of the costs associated therewith; and

(3) Confidential Commercial / Trade Secret Information: The producing party has expended valuable time and resources developing a customer base, as well as developing relationships with customers, manufacturers, and distributors for its products, goods and/or services. Disclosure of information relating to those efforts, except pursuant to the Protective Order signed by all Parties receiving the Confidential Information, would cause substantial harm to the competitive position of the producing party by allowing its competitors to benefit from the producing party's efforts without incurring any of costs associated therewith.

3. Disclosure Of "Confidential" Materials: No person or party subject to the Order other than the producing person or party shall disclose any of the Discovery Material designated by the producing person or party as "Confidential" to any other person whomsoever, except to:

(a) the parties to this action and Protective Order, including their employees and former employees;

(b) in-house (or corporate) legal counsel, and outside attorneys retained specifically for this action, and fellow employees of each such attorneys' law firms to whom it is reasonably necessary ...


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