Unicolors, Inc. v. H & M Hennes & Mauritz, L.P. et al

Filing 29

STIPULATED PROTECTIVE ORDER by Magistrate Judge Steve Kim. In re: re Stipulation for Protective Order 28 . (SEE ORDER FOR DETAILS). (mkr)

Download PDF
1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 9 10 11 UNICOLORS, INC., a California corporation, Plaintiff, 12 13 vs. 14 H&M HENNES & MAURITZ LP, et al., 15 Defendants. 16 Case No.: 2:16-cv-02322-AB-SK [PROPOSED] STIPULATED PROTECTIVE ORDER Trial Date: Not Yet Set 17 18 STIPULATED PROTECTIVE ORDER 19 20 1. INTRODUCTION 21 1.1 PURPOSES AND LIMITATIONS 22 Discovery in this action is likely to involve production of confidential 23 proprietary or private information for which special protection from public 24 disclosure and from use for any purpose other than prosecuting this litigation may 25 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 26 enter the following Stipulated Protective Order. The parties acknowledge that this 27 Order does not confer blanket protections on all disclosures or responses to 28 CASE NO. 16-cv-02322-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 discovery and that the protection it affords from public disclosure and use extends 2 only to the limited information or items that are entitled to confidential treatment 3 under the applicable legal principles. The parties further acknowledge, as set forth 4 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 5 file confidential information under seal; Civil Local Rule 79-5 sets forth the 6 procedures that must be followed and the standards that will be applied when a party 7 seeks permission from the court to file material under seal. 8 1.2 GOOD CAUSE STATEMENT 9 This lawsuit involves, inter alia, a copyright claim wherein Plaintiff 10 Unicolors, Inc. alleges that the defendants copied a fabric design and sold allegedly 11 infringing products (the “accused products”) to the public. 12 The parties anticipate that discovery in this matter will seek confidential and 13 proprietary information, including, but not limited to, relative to the production and 14 sale of the accused products as follows: 15 ● revenues generated from the sale of the accused products; 16 ● cost of goods associated with the accused products; 17 ● pricing points for the manufacture and sale of the accused products; 18 ● transactional documents associated with the import and sale of the 19 accused products; 20 ● licensing agreements; 21 ● gross revenues associated with the sale of the accused products; 22 ● profits margins associated with the sale of the accused products; 23 ● general financial information for the parties; 24 ● expenses for the manufacture, purchase and sale of goods; 25 ● marketing channels; 26 ● purchase price for the accused products; and 27 ● markdown money and other discounting information. 2 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 The parties are all involved in the fashion industry. This financial 2 information is not intended for public disclosure. The parties, in the past, have 3 routinely sought and agreed to prevent sensitive financial information from entering 4 into the public domain. Further, public disclosure of sensitive financial information 5 will cause harm to the parties as competitors could use this information to gain an 6 advantage in the fashion industry. 7 8 2. DEFINITIONS 9 2.1 Action: The pending federal lawsuit, entitled Unicolors, Inc. v. 10 H&M Hennes & Mauritz L.P., et al., Case No. 2:16-cv-02322 AB(SKx), which 11 involves claims of copyright infringement. 12 2.2 Challenging Party: a Party or Non-Party that challenges the 13 designation of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 17 the Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure of Discovery Material: all items or information, 24 regardless of the medium or manner in which it is generated, stored, or maintained 25 (including, among other things, testimony, transcripts, and tangible things), that are 26 produced or generated in disclosures or responses to discovery in this matter. 27 2.7 28 Expert: a person with specialized knowledge or experience in a 3 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 matter pertinent to the litigation who has been retained by a Party or its counsel to 2 serve as an expert witness or as a consultant in this Action. 3 2.8 House Counsel: attorneys who are employees of a party to this 4 Action. House Counsel does not include Outside Counsel of Record or any other 5 outside counsel. 6 2.9 Non-Party: any natural person, partnership, corporation, association, 7 or other legal entity not named as a Party to this action. 8 2.10 Outside Counsel of Record: attorneys who are not employees of a 9 party to this Action but are retained to represent or advise a party to this Action and 10 have appeared in this Action on behalf of that party or are affiliated with a law firm 11 which has appeared on behalf of that party, and includes support staff. 12 2.11 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, retained experts, and Outside Counsel of Record (and their 14 support staffs). 15 2.12 Producing Party: a Party or Non-Party that produces Disclosures or 16 Discovery Material in this Action. 17 2.13 Professional Vendors: persons or entities that provide litigation 18 support services (e.g. photocopying, videotaping, translating, preparing exhibits or 19 demonstrations, and organizing, storing, or retrieving data in any form or medium) 20 and their employees and subcontractors. 21 2.14 Protected Material:any Disclosure or Discovery Material that is 22 designated as “CONFIDENTIAL.” 23 2.15 Receiving Party: a Party that receives Disclosures or Discovery 24 material from a Producing Party. 25 26 3. SCOPE 27 The protections conferred by this Stipulation and Order cover not only 4 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 Protected Materials (as defined above), but also (1) any information copied or 2 extracted from Protected Material; (2) all copies, excerpts, summaries, or 3 compilations of Protected Material; and (3) any testimony, conversations, or 4 presentations by Parties or their Counsel that might reveal Protected Material. 5 Any use of Protected Material at trial shall be governed by the orders of the 6 trial judge. This Order does not govern the use of Protected Material at trial. 7 8 4. DURATION 9 Even after final disposition of this litigation, the confidentiality obligations 10 imposed by this Order shall remain in effect until a Designating Party agrees 11 otherwise in writing or a court order otherwise directs. Final disposition shall be 12 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 13 or without prejudice; and (2) final judgment herein after the completion and 14 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 15 including the time limits for filing any motions or applications for extension of time 16 pursuant to applicable law. 17 18 5. DESIGNATING PROTECTED MATERIAL 19 5.1 Exercise of Restraint and Care in Designating Material for Protection: 20 Each Party or Non-Party that designates information or items for protection under 21 this Order must take care to limit any such designation to specific material that 22 qualifies under the appropriate standards. The Designating Party must designate for 23 protection only those parts of material, documents, items, or oral or written 24 communications that qualify so that other portions of the material, documents, 25 items, or communications for which protection is not warranted are not swept 26 unjustifiably within the ambit of this Order. 27 28 Mass, indiscriminate, or routinized designations are prohibited. Designations 5 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 that are shown to be clearly unjustified or that have been made for an improper 2 purpose (e.g., to unnecessarily encumber the case development process or to impose 3 unnecessary expenses and burdens on other parties) may expose the Designating 4 Party to sanctions. 5 If it comes to a Designating Party’s attention that information or items that it 6 designated for protection do not qualify for protection, that Designating Party must 7 promptly notify all other Parties that it is withdrawing the inapplicable designation. 8 5.2 Manner and Timing of Designations: Except as otherwise provided in 9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 11 under this Order must be clearly so designated before the material is disclosed or 12 produced. 13 Designation in conformity with this Order requires: 14 (a) for information in documentary form (e.g., paper or electronic 15 documents, but excluding transcripts of depositions or other pretrial or trial 16 proceedings), that the Producing Party affix at a minimum, the legend 17 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 18 contains protected material. If only a portion or portions of the material on a page 19 qualifies for protection, the Producing party also must clearly identify the protected 20 portions(s) (e.g., by making appropriate markings in the margins). 21 A party or Non-Party that makes original documents available for inspection 22 need not designate them for protection until after the inspecting Party has indicated 23 which documents it would like copied and produced. During the inspection and 24 before the designation, all of the material made available for inspection shall be 25 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 26 documents it wants copied and produced, the Producing Party must determine which 27 documents, or portions thereof, qualify for protection under this Order. Then, 6 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 before producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL legend” to each page that contains Protected Material. If only a 3 portion or portions of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 5 markings in the margins). 6 (b) for testimony given in depositions that the Designating Party identifies 7 the Disclosure of Discovery Material on record, before the close of the deposition all 8 protected testimony. 9 (c) for information produced in some form other than documentary and for 10 any other tangible items, that the Producing Party affix in a prominent place on the 11 exterior of the container or containers in which the information is stored the legend 12 “CONFIDENTIAL.” If only a portion or portions of the information warrants 13 protection, the Producing Party, to the extent practicable, shall identify the protected 14 portion(s). 15 5.3 Inadvertent Failures to Designate: If timely corrected an 16 inadvertent failure to designate qualified information or items does not, standing 17 alone, waive the Designating Party’s right to secure protection under this Order for 18 such material. Upon timely correction of a designation, the Receiving Party must 19 make reasonable efforts to assure that the material is treated in accordance with the 20 provisions of this Order. 21 22 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 23 6.1 Timing of Challenges: Any Party or Non-Party may challenge a 24 designation of confidentiality at any time that is consistent with the Court’s 25 Scheduling Order. 26 6.2 Meet and Confer: The Challenging Party shall initiate the dispute 27 resolution process (and, if necessary, file a discovery motion under Local Rule 37.1 7 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 et seq. 2 6.3 The burden of persuasion in any such challenge proceeding shall be on 3 the Designating Party. Frivolous challenges, and those made for an improper 4 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 5 parties) may expose the Challenging Party to sanctions. Unless the Designating 6 Party has waived or withdrawn the confidentiality designation, all parties shall 7 continue to afford the material in question the level of protection to which it is 8 entitled under the Producing Party’s designation until the Court rules on the 9 challenge. 10 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 Basic Principles: A Receiving Party may use Protected Material that 13 is disclosed or produced by another Party or by a Non-Party in connection with this 14 Action only for prosecuting, defending, or attempting to settle this Action. Such 15 Protected Material may be disclosed only to the categories or persons and under the 16 conditions described in this Order. When the Action has been terminated, a 17 Receiving Party must comply with the provisions of section 13 below (FINAL 18 DISPOSITION). 19 Protected Material must be stored and maintained by a Receiving Party at a 20 location and in a secure manner that ensures that access is limited to the persons 21 authorized under this Order. 22 7.2 Disclosure of “CONFIDENTIAL” Information or Items: Unless 23 otherwise ordered by the court or permitted in writing by the Designating Party, a 24 Receiving Party may disclose any information or items designated 25 “CONFIDENTIAL” only to: 26 (a) the Receiving Party’s Outside Counsel of Record in this Action, 27 as well as employees of said Outside Counsel of Record to whom it is reasonably 8 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 necessary to disclose the information for this Action; 2 (b) the officers, directors, and employees (including House Counsel) 3 of the Receiving party to whom disclosure is reasonably necessary for this Action; 4 (c) Experts (as defined in this Order) of the Receiving Party to 5 whom disclosure is reasonably necessary for this Action and who have signed the 6 “Acknowledgement and Agreement to Be Bound” (Exhibit A); 7 (d) the Court and its personnel; 8 (e) court reporters and their staff; 9 (f) professional jury or trial consultants, mock jurors, and 10 Professional Vendors to whom disclosure is reasonably necessary for this Action 11 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 12 A): 13 (g) the author or recipient of a document containing the information 14 or a custodian or other person who otherwise possessed or knew the information; 15 (h) during their depositions, witnesses, and attorneys for witnesses, 16 in the Action to whom disclosure is reasonably necessary provided: (1) deposing 17 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 18 they will not be permitted to keep any confidential information unless they sign the 19 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 20 agreed by the Designating Party or ordered by the court. Pages of transcribed 21 deposition testimony or exhibits to depositions that reveal Protected Material may 22 be separately bound by the court reporter and may not be disclosed to anyone except 23 as permitted under this Stipulated Protective Order; and 24 (i) any mediator or settlement officer, and their supporting 25 personnel, mutually agreed upon by any of the parties engaged in settlement 26 discussions. 27 8. 28 PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 9 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 IN OTHER LITIGATION 2 If a Party is served with a subpoena or a court order issued in other litigation 3 that compels disclosure of any information or items designated in this Action as 4 “CONFIDENTIAL,” that Party must: 5 (a) promptly notify in writing the Designating Party. Such 6 notification shall include a copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the subpoena or 8 order to issue in the other litigation that some or all of the material covered by the 9 subpoena or order is subject to this Protective Order. Such notification shall include 10 a copy of this Stipulated Protective Order; and 11 (c) cooperate with respect to all reasonable procedures sought to be 12 pursued by the Designating Party whose Protected Material may be affected. 13 If the Designating Party timely seeks a protective order, the Party served with 14 the subpoena or court order shall not produce any information designated in this 15 action as “CONFIDENTIAL” before a determination by the court from which the 16 subpoena or order issued, unless the Party has obtained the Designating Party’s 17 permission. The Designating Party shall bear the burden and expense of seeking 18 protection in that court of its confidential material and nothing in these provisions 19 should be construed as authorizing or encouraging a Receiving Party in this Action 20 to disobey a lawful directive from another court. 21 22 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 23 PRODUCED IN THIS LITIGATION 24 (a) The terms of this Order are applicable to information produced 25 by a Non-Party in this Action and designated as “CONFIDENTIAL.” Such 26 information produced by Non-Parties in connection with this litigation is protected 27 by the remedies and relief provided by this Order. Nothing in these provisions 10 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 should be construed as prohibiting a Non-Party from seeking additional protections. 2 (b) In the event that a Party is required, by a valid discovery request, 3 to produce a Non-Party’s confidential information in its possession, and the Party is 4 subject to an agreement with the Non-Party not to produce the Non-Party’s 5 confidential information, then the Party shall: 6 (1) promptly notify in writing the Requesting Party and Non- 7 Party that some or all of the information requested is subject to a confidentiality 8 agreement with a Non-Party; 9 (2) promptly provide the Non-Party with a copy of the 10 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 11 reasonably specific description of the information requested; and 12 (3) make the information requested available for inspection by 13 the Non-Party, if requested. 14 (c) If the Non-Party fails to seek a protective order from this court 15 within 14 days of receiving the notice and accompanying information, the Receiving 16 Party may produce the Non-Party’s confidential information responsive to the 17 discovery request. If the Non-Party timely seeks a protective order, the Receiving 18 Party shall not produce any information in its possession or control that is subject to 19 the confidentiality agreement with the Non-Party before a determination by the 20 court. Absent a court order to the contrary, the Non-Party shall bear the burden and 21 expense of seeking protection in this court of its Protected Material. 22 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 25 Protected Material to any person or in any circumstances not authorized under this 26 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 27 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 11 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 to retrieve all unauthorized copies of Protected Material, (c) inform the person or 2 persons to whom unauthorized disclosures were made of all the terms of this Order, 3 and (d) request such person or persons to execute the “Acknowledgment and 4 Agreement to Be Bound” that is attached hereto as Exhibit A. 5 6 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 7 PROTECTED MATERIAL 8 When a Producing Party gives notice to Receiving Parties that certain 9 inadvertently produced material is subject to a claim of privilege or other protection, 10 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 11 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 12 procedure may be established in an e-discovery order that provides for production 13 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 14 (e), insofar as the parties reach an agreement on the effect of disclosure of a 15 communication or information covered by the attorney-client privilege or work 16 product protection, the parties may incorporate their agreement in the stipulated 17 protective order submitted to the court. 18 19 12. MISCELLANEOUS 20 12.1 Waiver of Authenticity Challenges: Any party that marks one of its 21 documents as “CONFIDENTIAL” as set forth in this order waives any right to later 22 challenge the authenticity of the document so marked (though the right to challenge 23 admissibility is reserved). 24 12.2 Right to Further Relief: Nothing in this Order abridges the right of 25 any person to seek its modification by the Court in the future. 26 12.3 Right to Assert Other Objections: By stipulating to the entry of this 27 Protective Order, no Party waives any right it otherwise would have to object to 12 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 disclosing or producing any information or item on any ground not addressed in this 2 Stipulated Protective Order. Similarly, no Party waives any right to object on any 3 ground to use in evidence of any of the material covered by this Protective Order. 4 12.4 Filing Protected Material: A party that seeks to file under seal any 5 Protected Material must comply with Civil Local Rule 79-5. Protected Material 6 may only be filed under seal pursuant to a court order authorizing the sealing of the 7 specific Protected Material at issue. If a Party’s request to file Protected Material 8 under seal is denied by the court, then the Receiving Party may file the information 9 in the public record unless otherwise instructed by the court. 10 11 13. FINAL DISPOSITION 12 After the final disposition of this Action, as defined in paragraph 4, within 60 13 days of a written request by the Designating Party, each Receiving Party must return 14 all Protected Material to the Producing Party or destroy such material. As used in 15 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 16 summaries, and any other format reproducing or capturing any of the Protected 17 Material. Whether the Protected Material is returned or destroyed, the Receiving 18 Party must submit a written certification to the Producing Party (and, if not the same 19 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 20 (by category, where appropriate) all the Protected Material that was returned or 21 destroyed and (2) affirms that the Receiving Party has not retained any copies, 22 abstracts, compilations, summaries or any other format reproducing or capturing any 23 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 24 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 25 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 26 reports, attorney work product, and consultant and expert work product, even if such 27 material contains Protected Material. Any such archival copies that contain or 13 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 constitute Protected Material remain subject to this Protective Order as set forth in 2 Section 4. 3 4 14. Any willful violation of this Order may be punished by civil or criminal 5 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 6 authorities, or other appropriate action at the discretion of the Court. 7 // 8 // 9 // 10 // 11 // 12 // 13 // 14 //// 15 // 16 // 17 // 18 // 19 // 20 // 21 //// 22 // 23 // 24 // 25 // 26 // 27 14 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 2 3 DATED: September 15, 2016 Respectfully submitted, JEONG & LIKENS, L.C. 4 By: /s/ C. Yong Jeong C. Yong Jeong Attorneys for Plaintiff UNICOLORS, INC. 5 6 7 8 DATED: September 15, 2016 NIXON PEABODY LLP 9 10 By: /s/ Jessica N. Walker Staci Jennifer Riordan Jessica N. Walker Attorneys for Defendant H&M HENNES & MAURITZ L.P. 11 12 13 14 15 16 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED: 17 18 DATED: September 16, 2016 HON. Steve Kim United States Magistrate Judge 19 20 21 22 23 24 25 26 27 15 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, ____________________________[full name], of ________________ [full 5 address], declare under penalty that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Central District of California on _____[date] in the case of Unicolors, Inc. v. 8 H&M Hennes & Mauritz L.P., et al., Case No. 2:16-cv-02322-AB-SK. I agree to 9 comply with and to be bound by all the terms of this Stipulated Protective Order and 10 I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint ____________________________ [full 19 name] of ___________________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ____________________________________ 24 City and State where signed: ___________________________________________ 25 Printed name: ___________________________________ 26 27 Signature: ___________________________________________ 16 28 CASE NO. 2:16-cv-023220-AB-SK STIPULATED PROTECTIVE ORDER 4833-0833-4902.1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?