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Tiger, LLC v. Twentieth Century Fox Film Corporation; Chernin Entertainment

September 5, 2012

TIGER, LLC, PLAINTIFF,
v.
TWENTIETH CENTURY FOX FILM CORPORATION; CHERNIN ENTERTAINMENT, LLC; AND DOES 1 THROUGH 10, DEFENDANTS.



The opinion of the court was delivered by: Hon. Andrew J. Wistrich Magistrate Judge, United States Judge

PROTECTIVE ORDER [Joint Stipulation Regarding Protective Order Filed Concurrently]

Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, this Protective Order is between plaintiff Tiger LLC ("Plaintiff") and defendants Twentieth Century Fox Film Corporation and Chernin Entertainment ("Defendants"). (Plaintiffs and Defendants are collectively referred to herein as the "Parties"). The purpose of this Protective Order is to preserve the confidentiality of certain documents and information that will be produced by the Parties during discovery. Among other information, the Parties have requested and/or will request contracts, agreements and other documents containing non-public terms, financial information and other private information which one or more of the Parties claim to be confidential. In order to preserve the confidentiality of documents and information that will be produced, the Parties have requested that the Court issue a Protective Order on the terms set forth herein.

I INFORMATION SUBJECT TO THIS ORDER

1. This Protective Order shall apply to all information, documents, testimony, or other things subject to discovery in this action that contains proprietary, confidential, trade secret, or commercially sensitive information, as well as any copies, excerpts, summaries, derivations or compilations of any of the foregoing contained in any pleadings, reports, discovery responses, correspondence, documents or things (collectively, "Discovery Material")-namely, any information, documents, testimony, or other things designated "CONFIDENTIAL" and/or "ATTORNEYS' EYES ONLY" under this Protective Order. As used herein, "Producing Party" shall refer to any party, including the parties to this action and non-parties, who disclose and/or produce any Discovery Material in this action. "Receiving Party" shall refer to the parties to this action who receive Discovery Material from a Producing Party.

2. Any party or non-party from whom discovery is sought in this action, and who is producing or disclosing Discovery Material, may designate it as set forth herein as: (a) CONFIDENTIAL, or (b) ATTORNEYS' EYES ONLY subject to this Protective Order if it contains confidential, proprietary, and/or trade secret information.

3. In the absence of written permission from the Producing Party, Discovery Material designated as CONFIDENTIAL or ATTORNEYS' EYES ONLY:

(a) shall be protected from disclosure as specified herein, unless (i) the Producing Party states otherwise in writing, or (ii) a party obtains an order of the Court declaring that all or certain portions of such Discovery Material are not, in fact, protected or should be subject to an alternative designation; and

(b) shall be used only for purposes of this litigation, and not for any other purpose whatsoever, including but not limited to any business, competitive, or governmental purpose or function or for any other litigation.

4. The Producing Party may designate documents or other tangible Discovery Materials by placing the following legend or similar legend on the document or thing: "CONFIDENTIAL" or "ATTORNEYS' EYES ONLY." Notwithstanding anything to the contrary in this Protective Order, when the Producing Party is a non-party, any party to this action may designate (as appropriate under the provisions of this Protective Order) any and all Discovery Materials produced by the non-party by sending a letter to all parties and the producing non-party notifying them of the party's designations, as well as a copy of the designated pages marked "CONFIDENTIAL" or "ATTORNEYS' EYES ONLY" on each page that contains Confidential Material.

(a) Written discovery may be designated by placing a legend on every page of the written material prior to production stating one of the following: "CONFIDENTIAL" or "ATTORNEYS' EYES ONLY."

(b) Parties or testifying persons may designate depositions and other testimony as CONFIDENTIAL or ATTORNEYS' EYES ONLY by indicating on the record at the time the testimony is given or by sending written notice that the testimony is designated within thirty (30) days of receipt of the hard copy transcript of the testimony.

5. A Producing Party may designate Discovery Material as CONFIDENTIAL if it comprises, includes or reflects non-public, confidential, proprietary, and/or commercially sensitive information. Examples of CONFIDENTIAL material include: (i) non-public financial information; (ii) non-public business and/or marketing plans (iii) non-public financial and/or accounting information; or (iv) other similar material that the Producing Party in good faith considers confidential and not publicly available. Discovery Material designated as CONFIDENTIAL may be disclosed only to the following:

(a) Outside litigation counsel of record and supporting personnel employed in the law firm(s) of outside litigation counsel of record, such as attorneys, paralegals, clerks, secretaries, and clerical personnel;

(b) Internal counsel, and paralegal or support personnel working with those counsel, associated with a party who either have responsibility for making decisions dealing directly with the litigation of this action or who are assisting outside counsel in preparation for proceedings in this action;

(c) Officers, directors or employees of a party, and paralegal or support personnel working with those officers, directors or employees, who either have responsibility for making decisions dealing directly with the litigation of this action or who are ...


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