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In re Application of Lufthansa Technik AG

United States District Court, C.D. California

September 23, 2019

In the Matter of the Application of LUFTHANSA TECHNIK AG, Petitioner, for an Order Pursuant to 28 U.S.C. § 1782 to Take Discovery, Pursuant to the Federal Rules of Civil Procedure, of Respondent Thales, Avionics, Inc., for Use in Foreign Proceedings.

          [PROPOSED] REVISED PROTECTIVE ORDER

          Hon. Karen E. Scott, United States Magistrate Judge.

         WHEREAS the disputes between these parties arise in a highly competitive industry in which constant innovation and research are necessary, that disclosure of material relating to innovation and research could cause decided competitive harm or unfair competitive advantage, and that therefore good cause exists for entry of a protective order regarding confidentiality of trade secret or nonpublic technical, commercial, financial, personal, or business information that is expected to be produced or provided in the course of discovery;

         WHEREAS the applicant in this action, Lufthansa Technik AG ("Lufthansa"), recognizes that in response to its requests for discovery under 28 U.S.C. § 1782, Respondent, Thales Avionics, Inc. ("Thales"), may be required to disclose such confidential or sensitive business information;

         WHEREAS such sensitive information should be treated as confidential, but not restricted in such a way as would impede Lufthansa's ability to use the discovered information to aid of the aforementioned German proceeding or Contemplated Proceedings;

         NOW, THEREFORE, it is hereby ordered as follows:

         Definitions

         As used in this Protective Order, the following definitions apply.

         1. The terms "Thales" and "Respondent" refer to Thales Avionics, Inc.

         2. The terms "Lufthansa" and "Petitioner" refer to Lufthansa Technik AG.

         3. The terms "AES" refer to Astronics Advanced Electronic Systems Corp.

         4. The term "German Proceedings" refers to Civil Law Proceeding No. 7 O 289/10, before the Mannheim Regional Court, and any appeals therefrom.

         5. The term "Contemplated Proceedings" refers to contemplated or pending proceedings relating to the rights of Lufthansa arising out of any parts or foreign counterparts of European Patent No. EP 881145 that have been or are being considered for filing in Germany, France, Spain, the United Kingdom and/or Japan other than the German Proceedings.

         6. The term "Action" refers to Lufthansa's § 1782 Petition to this Court.

         7. The term "Confidential Information" refers to information produced by Thales and designated by Thales as "ATTORNEYS EYES ONLY" under the terms of this Protective Order.

         8. The term "Privileged Information" refers to information protected by the attorney-client privilege, the work product doctrine, or any other applicable privilege or immunity.

         Method of Designating Confidential Information

         9. Designation of Confidential Information should be made by stamping, placing, or affixing on the document in a manner which will not interfere with its legibility the phrase "ATTORNEY'S EYES ONLY."

         10. Information should only be designated as Confidential Information when Thales in good faith believes that the information contains trade secrets or nonpublic technical, ...


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