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Terry J. Fanning and Tatiana Jabbar, Each Individually and On Behalf of All Others Similarly Situated v. Hsbc Card Services Inc. and Hsbc Technology & Services (Usa) Inc

April 15, 2013

TERRY J. FANNING AND TATIANA JABBAR, EACH INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
HSBC CARD SERVICES INC. AND HSBC TECHNOLOGY & SERVICES (USA) INC., DEFENDANTS.



The opinion of the court was delivered by: Hon. James V. Selna

[Assigned to the Hon. James V. Selna]

[PROPOSED] PROTECTIVE ORDER GOVERNING USE AND DISSEMINATION OF CONFIDENTIAL DOCUMENTS AND MATERIALS Action Filed: June 4, 2012

[Stipulation Re Protective Order Governing Use and Dissemination of Confidential Documents and Materials filed concurrently]

RECITALS

A. The parties in the above-captioned action may seek discovery that the responding parties assert may contain certain highly sensitive, confidential, trade secret information and documents.

B. The protective order sought herein ("Protective Order") is warranted under the circumstances and is sufficiently tailored to avoid unduly hindering the public's access to the Court's records and files in this matter.

CONFIDENTIALITY ORDER

Upon stipulation of the parties, and good cause appearing for the entry of this Protective Order,

IT IS HEREBY ORDERED that:

I.DEFINITIONS

1. As used in this Protective Order:

a. "Action" means the above-captioned action presently pending in the United States District Court for the Central District of California.

b. "Confidential Material" means Material designated as Confidential in this Action in accordance with the terms of this Protective Order.

c. "Discovering Counsel" means counsel for a Discovering Party in this Action.

d. "Discovering Party" means the Party or Parties to whom Material is being provided, produced, or made available for inspection by a Producing Party or Producing Person in this Action.

e. "Material" means any document or part of a document, testimony or information in any form or medium whatsoever, including, without limitation, any written or printed matter provided, produced or made available for inspection through discovery in this Action by any Party or Person before or after the date of this Protective Order.

f. "Trade Secret," as used in this Protective Order means information, including a formula, pattern, compilation, program, design, device, method, technique or process that:

(1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and

(2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

g. "Party" or "Parties" means Plaintiffs, Defendants HSBC Card Services Inc., and HSBC Technology & Services (USA) Inc. (collectively, "Defendants"), and any future parties in this Action.

h. "Person" means any individual, corporation, partnership, unincorporated association, governmental agency, or other business or governmental entity, whether a party or not, including non-Parties, from whom discovery is sought in this Action.

i. "Producing Party" means any Party who provides, produces, or makes available for inspection Material during the course of this Action. "Producing Person" means any person who provides, produces, or makes available ...


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