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Microsoft Corporation, A Washington Corporation v. Laptops Discounters Inc.

October 24, 2012

MICROSOFT CORPORATION, A WASHINGTON CORPORATION, PLAINTIFF,
v.
LAPTOPS DISCOUNTERS INC., A CALIFORNIA CORPORATION DOING BUSINESS AS NOTEBOOK AVENUE; AND AFTAB AHMAD, AN INDIVIDUAL, DEFENDANTS.



The opinion of the court was delivered by: The Honorable Jean P. Rosenbluth United States Magistrate Judge

*Note changes made by the Court to page 5*

DISCOVERY MATTER STIPULATED PROTECTIVE ORDER

Having received and considered the parties' Stipulation for Entry of Protective Order, and good cause appearing,

THE PARTIES ARE HEREBY ORDERED to abide by the terms and conditions agreed upon in the Stipulation as follows:

1. This Stipulated Protective Order shall be applicable to and govern all depositions, documents produced in response to requests for production of documents, answers to interrogatories, responses to requests for admissions, and all other discovery taken pursuant to the Federal Rules of Civil Procedure, as well as all documents produced by either party in response to informal discovery requests, (collectively, "RECORDS") which the disclosing party designates as "CONFIDENTIAL MATERIAL" or "RESTRICTED MATERIAL" hereafter furnished, directly or indirectly, by or on behalf of any party in connection with this action.

2. In designating RECORDS as "CONFIDENTIAL MATERIAL" or "RESTRICTED MATERIAL," a party shall make such a designation of CONFIDENTIAL MATERIAL or RESTRICTED MATERIAL only for RECORDS which that party in good faith believes contain information which is not public, such as trade secret or other confidential, competitive or proprietary business information used by it in, or pertaining to, its business which the party takes appropriate efforts to keep confidential or which the party is otherwise required to keep confidential by agreement or law. "CONFIDENTIAL MATERIAL" includes but is not limited to information which, if disclosed, would be adverse to either party's respective business advantages against their competitors, such as, but not limited to,undermining the investigation of the making or distribution of infringing copies of Microsoft software or disclosed confidential financial information regarding sales and profits. For a designation of RECORDS as "RESTRICTED MATERIAL," the party must additionally believe in good faith that the RECORDS must be protected from disclosure to the parties themselves in this litigation and must be subject to the restricted disclosure provided for below because such RECORDS are comprised of and/or contain highly sensitive competitive business information. Such information includes, but is not limited to, the security features of the party's property (e.g., software programs), which if disclosed would facilitate the creation, manufacture, duplication, and/or distribution of infringing copies of that party's property by the other party. CONFIDENTIAL MATERIAL and RESTRICTED MATERIAL shall be used solely for the purpose of conducting this litigation.

3. RECORDS designated as CONFIDENTIAL MATERIAL may be disclosed only to the following persons:

a. the attorneys working on this action on behalf of any party, including in-house attorneys;

b. any paralegal assistants, stenographic and clerical employees working under the direct supervision of such counsel;

c. any parties to this action who are individuals, and the employees, directors or officers of parties to this action who are corporations or partnerships, to the extent necessary to further the interest of the parties in this litigation;

d. any person not employed by a party who is expressly retained or sought to be retained by any attorney described in paragraph 3(a) to assist in preparation of this action for trial, with disclosure only to the extent necessary to perform such work;

e. any witnesses who appear for deposition in this matter, and their counsel of record, during the course of their testimony, upon the witness being advised of the need and agreeing to keep the RECORDS confidential; and

f. the Court. 4. RECORDS designated as "RESTRICTED MATERIAL" may be disclosed only to ...


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