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Cullan and Cullan LLC v. M-Qube, Inc.

United States District Court, District of Nebraska

January 9, 2015

CULLAN AND CULLAN LLC, Plaintiff,
v.
M-QUBE, INC., MOBILE MESSENGER AMERICAS, INC., CF ENTERPRISES PTY., LTD., and JOHN DOES 1-200, Defendants.

PROTECTIVE ORDER

Thomas D. Thalken, United States Magistrate Judge

This matter is before the court on the parties’ Stipulated Protective Order (Filing No. 141). Upon good cause shown, the stipulation is adopted as follows.

1. PURPOSES AND LIMITATIONS

Good cause exists to enter this Stipulated Protective Order because discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and request the Court to enter this following Stipulated Protective Order. This agreement does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under restricted access.

2. “CONFIDENTIAL” MATERIAL

“Confidential material” means information designated as “Confidential” by the producing party that falls within one or more of the following categories: (a) information prohibited from disclosure by statute; (b) personally identifiable information (“PII”); (c) Defendants’ contracts with customers, such as content providers, who use Defendants’ services; (d) information that reveals trade secrets; (e) research, technical, commercial, or financial information that the party has maintained as confidential; and (f) medical information concerning any individual. Information or documents that are available to the public may not be designated as Confidential.

3. SCOPE

The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material. However, the protections conferred by this agreement do not cover information in the public domain or becomes part of the public domain through trial or otherwise.

4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the Court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party’s counsel in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney’s Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the Court, Court personnel, and Court reporters and their staff
(e) those persons specifically engaged for the limited purpose of making copies of documents or organizing and processing documents, including outside vendors hired to process electronically stored documents
(f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the designating party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to depositions that reveal confidential material must be separately bound by ...

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