Protective Order

AuthorKenneth L. Dorsney
Pages795-803
Protective Order
IN THE UNITED STATES DISTRICT COURT
[Name of District]
[DISTRICT COURT CAPTION]
STIPULATED DISCOVERY CONFIDENTIALITY ORDER
Plaintiff [Name of Plaintiff] and defendants [Name of Defendant], [Name of
Defendant 2], and [Name of Defendant 3] (referred to as “Defendant,” “Defendant 2,”
“Defendant 3” or collectively as “Defendants”), by and through their undersigned
counsel, hereby stipulate and agree that the following Discovery Confidentiality Order
shall govern the use, disclosure, and dissemination of documents, things, and other
information obtained through discovery in the above-captioned case, entitled ______, and
any subsequent cases involving the same parties and U.S. Patent No. 1 and/or U.S. Patent
No. 2. Plaintiffs and Defendants (collectively referred to as “the Parties”) further request
that the Court enter this Stipulated Discovery Confidentiality Order as follows:
IT IS HEREBY AGREED AND ORDERED:
1. Designation of Confidential Information
Pursuant to the guidelines set forth in this Order and in accordance with Fed. R.
Civ. P. 26(c)(7), any person or entity (“Producing Party”) producing documents, things,
information or other materials in this action (“Produced Materials”) may designate such
materials as “Confidential Information.” All such designated material, all copies,
excerpts and summaries thereof, and all information contained therein or derived
therefrom shall hereinafter be referred to as “Confidential Information.”
2. Labeling of Confidential Information
a. Documents and other material designated as “Confidential
Information” shall be visibly marked with the designation “CONFIDENTIAL —
SUBJECT TO DISCOVERY CONFIDENTIALITY ORDER.” Confidential Information
shall include, without limitation, all information used in or pertaining to business, which
matter is not generally known to the public, which would not normally be revealed to
another or would be revealed to another only in confidence, or which is required by law
to be confidential and which may cause competitive harm if disclosed. Examples of such
information include but are not limited to financial information, customer identification,
business plans, research and development work, patent applications and prosecution
related thereto (to the extent not publicly available), projected sales, trade secrets, and
other sensitive or proprietary business or technical documents. All documents produced
by any party in this litigation prior to entry of this Stipulated Discovery Confidentiality
Order shall be treated in accordance with the terms of this Order.
795
A-23
dor54588_24_app_663–914.indd 795 5/5/16 5:05 PM

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