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J2 Global Communications, Inc., and Advanced Messaging Technologies, Inc. v. Ringcentral

November 2, 2012

J2 GLOBAL COMMUNICATIONS, INC., AND ADVANCED MESSAGING TECHNOLOGIES, INC. PLAINTIFFS,
v.
RINGCENTRAL, INC., DEFENDANT.



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

AND RELATED CROSS-ACTION

STIPULATED PROTECTIVE ORDER

The parties to this action stipulate to, and seek entry of, the following Protective Order:

1. "Confidential" information is information that, ingood faith, a party believes to contain (a) proprietary or commercially sensitive information which is not publicly known and which its owner would not reveal to others except in confidence; (b) personal information; or (c) information that should otherwise be subject to confidential treatment under the Federal Rules of Civil Procedure. If a person producing information under this Order (the "Producing Person") designates information as "Confidential," the designated information shall be treated as Confidential unless successfully challenged under ¶ 11. When producing documents, the Producing Person shall, where practical, mark each page containing Confidential information as "Confidential." Thus, for example, documents produced in native format may be marked as Confidential by placing such a designation in the title of the document.

2. "Restricted Confidential" information shall be limited to information that, in good faith, a party believes to contain (a) current and past (to the extent they reflect on current) business planning and financial information; (b) trade secrets; (c) past or current company personnel or employee information; (d) source code; and (e) information concerning a party's sales or the design, structure or workings of a party's products or systems which could, if it became known to other parties, harm the competitive position of its owner. If a Producing Person designates information as Restricted Confidential under this Order, the designated information shall be treated as Restricted Confidential unless successfully challenged under ¶ 11. When producing documents, the Producing Person shall mark each page containing Restricted Confidential information as "Restricted Confidential."

3. Any Producing Person, whether or not a party to this action, may designate information as Confidential or Restricted Confidential under this Order.

4. When a document is designated as Confidential or Restricted Confidential, the designation includes not only the document so designated, but also any information derived from that document, and any copies, excerpts, summaries, or compilations thereof.

5. A person or entity receiving information under this Order (the "Receiving Person") shall use Confidential or Restricted Confidential information (together, "Protected Information") only to conduct this litigation and related proceedings before the FCC and for no other purpose..

6. By receiving information under this Order, all Receiving Persons agree to be subject to the jurisdiction of this Court concerning their use of Protected Information. All receiving persons other than attorneys, their staff, and independent companies engaged by outside litigation counsel to perform litigation support service, shall sign an acknowledgment in the form attached hereto as Exhibit A, indicating that they have read and understood the terms of this Order and agree to submit to the jurisdiction of the Central District of California for enforcement of this Order. Counsel for each party shall maintain all original acknowledgments, and will produce the same to the opposing party when so ordered by the Court.

7. A Receiving Person may disclose Restricted Confidential information only to the following:

a. outside litigation counsel retained by a party in this action or a related matter before the FCC., including attorneys, their staff, and independent companies engaged by outside litigation counsel to perform litigation support services (such as document and graphics vendors);

b. independent experts or consultants retained by outside litigation

counsel,

c. Participants in juror focus groups, provided they sign a confidentiality agreement not to use or disclose any such material and that they are not allowed to retain any notes or other written ...


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