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Viacom International Inc. v. MGA Entertainment, Inc.

United States District Court, C.D. California, Western Division

April 13, 2017

VIACOM INTERNATIONAL INC., a Delaware corporation, Plaintiff,
v.
MGA ENTERTAINMENT, INC., a California corporation, Defendant.

          KELLER/ANDERLE LLP, JENNIFER L. KELLER, STEVEN J. AARONOFF, THOMAS H. KAO, Attorneys for Defendant MGA Entertainment, Inc.

          KENDALL BRILL & KELLY LLP Richard B. Kendall, Randall L. Jackson, Attorneys for Plaintiff Viacom International Inc.

          PROTECTIVE ORDER

          Hon. Manuel L. Real, United States District Judge

         Plaintiff Viacom International Inc. and Defendant MGA Entertainment, Inc. have consented to the entry of a protective order in this litigation, as evidenced by the signatures of their counsel on the Stipulation To Enter Protective Order that was filed with the Court on April 11, 2017.

         For good cause shown, pursuant to Federal Rule of Civil Procedure 26(c), IT IS HEREBY ORDERED that this Protective Order (“Order”) will govern the production and exchange of confidential information in the above-captioned case on the terms as set forth therein.

         TERMS OF THE STIPULATED PROTECTIVE ORDER 1. PURPOSES, LIMITATIONS, AND GOOD CAUSE STATEMENT

         Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Such confidential and proprietary materials and information consist of, among other things, confidential business or financial information, information regarding confidential business practices, or other confidential research, development, or commercial information (including information implicating privacy rights of third parties), information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or common law.

         In order to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of the litigation, and to serve the ends of justice, a protective order for such information is justified in this matter. Accordingly, the parties hereby stipulate to and petition the Court to enter the Order.

         The parties acknowledge that the Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles.

         2. DEFINITIONS

         2.1. Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         2.2. “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that a party believes, in good faith, includes personal information or confidential, trade secret, commercial, or proprietary business information or non-public financial data.

         2.3. “CONFIDENTIAL ATTORNEYS' EYES ONLY” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that a party believes, in good faith, includes highly sensitive personal information or confidential, trade secret, commercial, or proprietary business information or non-public financial data, the disclosure of which is likely to cause significant harm to an individual or to the business or competitive position of the Designating Party.

         2.4. Counsel: attorneys who are not employees of a Party to this action but are retained to represent or advise a Party to this action and have appeared in this action on behalf of that Party or are affiliated with a law firm which has appeared on behalf of that Party (as well as their employees and support staff).

         2.5. Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS' EYES ONLY.” 2.6. Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

         2.7. Expert: a person who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.

         2.8. Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         2.9. Party: any party to this action, including all of its officers, directors, and employees.

         2.10. Privileged Material: all items or information that are protected from disclosure by the attorney-client privilege, the work product doctrine, or any other applicable privilege or doctrine.

         2.11. Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.

         2.12. Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

         2.13. Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL” or “CONFIDENTIAL ATTORNEYS' EYES ONLY.” 2.14. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

         3. ...


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