Uniloc 2017 LLC et al v. Microsoft Corporation

Filing 36

STIPULATED PROTECTIVE ORDER by Magistrate Judge Autumn D. Spaeth re Stipulation for Protective Order 35 . (kh)

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M. ELIZABETH DAY (SBN
177125)
[e-mail]
DAVID ALBERTI (SBN 220265)
[e-mail]
SAL LIM (SBN 211836)
[e-mail]
MARC BELLOLI (SBN
244290)
[e-mail]
FEINBERG DAY ALBERTI LIM
& BELLOLI LLP
1600 El Camino Real, Suite 280
Menlo Park, CA 94025
Tel: [phone]
Fax: [phone]
Attorneys for Uniloc 2017 LLC,
Uniloc Licensing USA LLC and
Uniloc USA, Inc.

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UNILOC 2017 LLC, UNILOC
LICENSING USA LLC and
UNILOC USA, INC.,

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Jesse Ashler Gessin (CA Bar No.
263889)
E-mail: [e-mail]
Keller Anderle LLP
18300 Von Karman Ave., Suite 930
Irvine, California 92612
Attorneys for Defendant
MICROSOFT CORPORATION

CENTRAL DISTRICT OF CALIFORNIA

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Indranil Mukerji (Admitted Pro Hac
Vice)
E-mail: [e-mail]
Fish & Richardson P.C.
1000 Maine Ave SW Suite 1000
Washington DC 20024
Telephone: [phone]
Facsimile: [phone]

UNITED STATES DISTRICT COURT

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Juanita R. Brooks (CA Bar No.75934)
E-mail: [e-mail]
Fish & Richardson P.C.
12390 El Camino Real
San Diego CA 92130
Telephone: [phone]
Facsimile: [phone]

CASE NO. 8:18-CV-01320-AG-ADS
STIPULATED PROTECTIVE
ORDER

Plaintiffs,
v.
MICROSOFT CORPORATION,
Defendant.

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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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1.

PURPOSES AND LIMITS OF THIS ORDER
Discovery in this action is likely to involve confidential, proprietary, or

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private information requiring special protection from public disclosure and from

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use for any purpose other than this litigation. Thus, the Court enters this Protective

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Order. This Order does not confer blanket protections on all disclosures or

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responses to discovery, and the protection it gives from public disclosure and use

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extends only to the specific material entitled to confidential treatment under the

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applicable legal principles. This Order does not automatically authorize the filing

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under seal of material designated under this Order. Instead, the parties must comply

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with L.R. 79-5.1 if they seek to file anything under seal. This Order does not

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govern the use at trial of material designated under this Order.

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2.

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DESIGNATING PROTECTED MATERIAL
2.1 Over-Designation Prohibited. Any party or non-party who designates

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information or items for protection under this Order as “PROTECTED DATA,”

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“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY,”

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or “HIGHLY CONFIDENTIAL – SOURCE CODE” (a “designator”) must only

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designate specific material that qualifies under the appropriate standards. To the

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extent practicable, only those parts of documents, items, or oral or written

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communications that require protection shall be designated. Designations with a

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higher confidentiality level when a lower level would suffice are prohibited. Mass,

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indiscriminate, or routinized designations are prohibited. Unjustified designations

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expose the designator to sanctions, including the Court’s striking all confidentiality

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designations made by that designator. Designation under this Order is allowed only

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if the designation is necessary to protect material that, if disclosed to persons not

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authorized to view it, would cause competitive or other recognized harm. Material

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may not be designated if it has been made public, or if designation is otherwise

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unnecessary to protect a secrecy interest. If a designator learns that information or

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items that it designated for protection do not qualify for protection at all or do not
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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qualify for the level of protection initially asserted, that designator must promptly

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notify all parties that it is withdrawing the mistaken designation.

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2.2 Manner and Timing of Designations. Designation under this Order

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requires the designator to affix the applicable legend (“PROTECTED DATA”,

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“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY,”

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or “HIGHLY CONFIDENTIAL – SOURCE CODE”) to each page that contains

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protected material. For testimony given in deposition or other proceeding, the

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designator shall specify all protected testimony and the level of protection being

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asserted. It may make that designation during the deposition or proceeding, or may

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invoke, on the record or by written notice to all parties on or before the next

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business day, a right to have up to 21 days from the deposition or proceeding to

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make its designation.

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2.2.1 A party or non-party that makes original documents or materials

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available for inspection need not designate them for protection until after the

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inspecting party has identified which material it would like copied and produced.

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During the inspection and before the designation, all material shall be treated as

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HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY. After the inspecting

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party has identified the documents it wants copied and produced, the producing

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party must designate the documents, or portions thereof, that qualify for protection

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under this Order.

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2.2.2 Parties shall give advance notice if they expect a deposition or other

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proceeding to include designated material so that the other parties can ensure that

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only authorized individuals are present at those proceedings when such material is

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disclosed or used. The use of a document as an exhibit at a deposition shall not in

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any way affect its designation. Transcripts containing designated material shall

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have a legend on the title page noting the presence of designated material, and the

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title page shall be followed by a list of all pages (including line numbers as

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appropriate) that have been designated, and the level of protection being asserted.
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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The designator shall inform the court reporter of these requirements. Any transcript

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that is prepared before the expiration of the 21-day period for designation shall be

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treated during that period as if it had been designated HIGHLY CONFIDENTIAL –

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ATTORNEY EYES ONLY unless otherwise agreed. After the expiration of the 21-

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day period, the transcript shall be treated only as actually designated.
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Inadvertent Failures to Designate. An inadvertent failure to

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designate does not, standing alone, waive protection under this Order. Upon timely

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assertion or correction of a designation, all recipients must make reasonable efforts

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to ensure that the material is treated according to this Order.

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3.

CHALLENGING CONFIDENTIALITY DESIGNATIONS
All challenges to confidentiality designations shall proceed under L.R. 37-1

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through L.R. 37-4.

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4.

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ACCESS TO DESIGNATED MATERIAL
4.1

Basic Principles. A receiving party may use designated material only

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for this litigation. Designated material may be disclosed only to the categories of

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persons and under the conditions described in this Order. Designated material must

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be stored and maintained by a receiving party at a location in the United States and

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in a secure manner that ensures that access is limited to the persons authorized

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under this Order. Designated material must not be transported by any recipient to

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any location outside the United States.

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4.2

Disclosure of CONFIDENTIAL Material Without Further

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Approval. Unless otherwise ordered by the Court or permitted in writing by the

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designator, a receiving party may disclose any material designated

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CONFIDENTIAL only to citizens or permanent residents of the United States that

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are one of the following:

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4.2.1 The receiving party’s outside counsel of record in this action

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and employees of outside counsel of record to whom disclosure is reasonably

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necessary;
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

4.2.2 Three (3) officers, directors, and employees of the receiving

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party to whom disclosure is reasonably necessary, and who have signed the

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Agreement to Be Bound (Exhibit A);
4.2.3 Experts retained by the receiving party’s outside counsel of

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record to whom disclosure is reasonably necessary, and who have signed the

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Agreement to Be Bound (Exhibit A);

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4.2.4 The Court and its personnel;

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4.2.5 Outside court reporters and their staff, professional jury or trial

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consultants (as well as independent mock jurors during the course of a mock

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jury exercise), and professional vendors to whom disclosure is reasonably

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necessary, and who have signed the Agreement to Be Bound (Exhibit A);

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4.2.6 During their depositions, witnesses in the action to whom

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disclosure is reasonably necessary and who have signed the Agreement to Be

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Bound (Exhibit A); and
4.2.7 The author or recipient of a document containing the material, or

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a custodian or other person who otherwise possessed or knew the

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information.

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4.3

Disclosure of HIGHLY CONFIDENTIAL – ATTORNEY EYES

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ONLY and HIGHLY CONFIDENTIAL – SOURCE CODE Material Without

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Further Approval. Unless permitted in writing by the designator, a receiving party

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may disclose material designated HIGHLY CONFIDENTIAL – ATTORNEY

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EYES ONLY or HIGHLY CONFIDENTIAL – SOURCE CODE without further

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approval only to citizens or permanent residents of the United States that are one of

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the following:

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4.3.1 The receiving party’s outside counsel of record in this action

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and employees of outside counsel of record to whom it is reasonably

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necessary to disclose the information;

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4.3.2 The Court and its personnel;
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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4.3.3 Outside court reporters and their staff, professional jury or trial

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consultants (as well as independent mock jurors during the course of a mock

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jury exercise), and professional vendors to whom disclosure is reasonably

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necessary, and who have signed the Agreement to Be Bound (Exhibit A); and

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4.3.4 The author or recipient of a document containing the material, or

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a custodian or other person who otherwise possessed or knew the

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information.

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4.4

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Procedures for Approving or Objecting to Disclosure of HIGHLY

CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY

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CONFIDENTIAL – SOURCE CODE Material to In-House Counsel or

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Experts. Unless agreed to in writing by the designator:

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4.4.1 A party seeking to disclose to an expert retained by outside

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counsel of record any information or item that has been designated HIGHLY

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CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY

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CONFIDENTIAL – SOURCE CODE must first make a written request to

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the designator that (1) identifies the general categories of HIGHLY

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CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY

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CONFIDENTIAL – SOURCE CODE information that the receiving party

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seeks permission to disclose to the expert, (2) sets forth the full name of the

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expert and the city and state of his or her primary residence, (3) attaches a

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copy of the expert’s current resume, (4) identifies the expert’s current

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employer(s), (5) identifies each person or entity from whom the expert has

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received compensation or funding for work in his or her areas of expertise

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(including in connection with litigation) in the past five years, (6) identifies

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(by name and number of the case, filing date, and location of court) any

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litigation where the expert has offered expert testimony, including by

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declaration, report, or testimony at deposition or trial, in the past five years;

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and (7) identifies the general subject matter of all unpublished patent
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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applications naming that individual as an inventor. If the expert believes any

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of this information at (4) - (7) is subject to a confidentiality obligation to a

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third party, then the expert should provide whatever information the expert

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believes can be disclosed without violating any confidentiality agreements,

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and the party seeking to disclose the information to the expert shall be

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available to meet and confer with the designator regarding any such

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confidentiality obligations.

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4.4.2 A party that makes a request and provides the information

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specified in paragraph 4.4.1 may disclose the designated material to the

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identified in-house counsel or expert unless, within seven days of delivering

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the request, the party receives a written objection from the designator

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providing detailed grounds for the objection.
4.4.3 All challenges to objections from the designator shall proceed

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under L.R. 37-1 through L.R. 37-4.

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5.

SOURCE CODE

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5.1 Designation of Source Code. If production of source code is necessary,

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a party may designate it as HIGHLY CONFIDENTIAL – SOURCE CODE if it is,

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or includes, confidential, proprietary, or trade secret source code.

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5.2 Location and Supervision of Inspection. Any HIGHLY

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CONFIDENTIAL – SOURCE CODE produced in discovery shall be made

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available for inspection, in a format allowing it to be reasonably reviewed and

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searched, during normal business hours or at other mutually agreeable times, at an

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office of the designating party’s counsel or another mutually agreeable location.

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Once a designating party makes available its Source Code, the inspecting party

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shall provide notice of its intent to review that Source Code at least seven (7)

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business days in advance of the initial inspection, and three (3) business days in

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advance of any subsequent inspection. The source code shall be made available for

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inspection on a secured, “stand-alone” computer (a computer that is not linked to
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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any network, including a local area network “LAN”, an intranet, or the Internet) in

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a secured room, and the inspecting party shall not copy, remove, or otherwise

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transfer any portion of the source code onto any recordable media or recordable

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device. No recordable media, recordable devices, computers, cell phones, or other

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electronic devices may be brought into the secured room, but handwritten notes

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may be taken in the secured room, so long as those handwritten notes do not copy

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verbatim any lines of the Source Code. The designator may visually monitor the

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activities of the inspecting party’s representatives during any source code review,

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but only to ensure that there is no unauthorized recording, copying, or transmission

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of the source code. The inspecting party shall make reasonable efforts to restrict its

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requests for such access to the stand-alone computer(s) to normal business hours,

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which for purposes of this paragraph shall be 9:00 a.m. through 6:00 p.m. local

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time. All persons who will review source code on behalf of a receiving party,

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including members of the receiving party’s law firm, shall be identified in writing

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to the producing party at least 48 hours in advance of the first time that such person

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reviews such source code. Such identification shall be in addition to any other

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disclosure required under this Order.

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5.3 Paper Copies of Source Code Excerpts. The inspecting party may

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request paper copies of limited portions of source code not to exceed 250 pages for

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any one accused product, and with no contiguous block greater than 35 pages, that

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are reasonably necessary for the preparation of court filings, pleadings, expert

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reports, other papers, or for deposition or trial. The receiving party may request to

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print additional pages beyond the aforementioned limits; the parties will meet and

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confer in good faith within three (3) business days regarding such a request, and

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such a request will not be unreasonably denied. If the producing party does not

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agree to the request of the receiving party, the producing party will not object to the

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receiving party’s request for expedited briefing regarding the producing party’s

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denial of the request. The designator shall provide all such source code in paper
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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form, including Bates numbers and the label “HIGHLY CONFIDENTIAL –

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SOURCE CODE.” The inspecting party shall maintain a log of all paper copies of

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the source code including the names of the custodian(s) or location(s) where the

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paper copies are store when not in use. No more than a total of (5) individuals

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identified by the receiving party shall have access to the printed portions of source

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code (except insofar as such code appears in any court filing or expert report). The

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inspecting party shall provide a copy of this log to the producing party within seven

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(7) days of any request by the producing party.
5.4 Access Record. The inspecting party shall maintain a record of any

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individual who has inspected any portion of the source code in electronic or paper

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form, and shall maintain all paper copies of any printed portions of the source code

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in a secured, locked area. The inspecting party shall not convert any of the

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information contained in the paper copies into any electronic format other than for

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the preparation of a pleading, exhibit, expert report, discovery document, deposition

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transcript, or other Court document. Any paper copies used during a deposition

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shall be retrieved at the end of each day and must not be left with a court reporter or

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any other unauthorized individual.
5.5 Transfer of Source Code. A producing party’s source code paper copies

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may only be transported by the receiving party on paper via secure and reliable

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hand carry. Source code paper copies may not be transported or transmitted

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electronically over a network of any kind or the Internet.

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6.

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HANDLING OF PROTECTED DATA
6.1 Protected Data. “Protected Data”: refers to any information that a party

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or non-party reasonably believes to be subject to federal, state or foreign Data

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Protection Laws or other privacy obligations. Protected Data constitutes highly

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sensitive materials requiring special protection. Examples of such Data Protection

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Laws include, without limitation, The Gramm-Leach-Biley Act, 15 U.S.C. § 6801

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et seq. (financial information); The Health Insurance Portability and Accountability
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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Act (“HIPAA”) and the regulations thereunder, 45 CFR Part 160 and Subparts A

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and E of Part 164 (medical information); Regulation (EU) 2016/679 Of the

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European Parliament and of the Council of 27 April 2016 on the Protection of

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Natural Persons with Regard to the Processing of Personal Data and on the Free

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Movement of Such Data, also known as the General Data Protection Regulation

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(“GDPR”).
6.2 Disclosure of Protected Data. Unless otherwise ordered by the court or

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permitted in writing by the designating party, a receiving party may disclose any

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information or item designated “PROTECTED DATA” only to certain groups of

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individuals that can receive HIGHLY CONFIDENTIAL – ATTORNEY EYES

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ONLY materials, as indicated in Section 4.3 herein.
6.3 The parties agree that productions of Protected Data Information may

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require additional safeguards pursuant to Federal, State or foreign statutes,

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regulations or privacy obligations and will meet and confer to implement these

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safeguards if and when needed.

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7.

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PROSECUTION BAR
Absent written consent from the designator, any individual who receives

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access to HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or HIGHLY

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CONFIDENTIAL – SOURCE CODE information shall not be involved in the

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prosecution of patents or patent applications concerning the field of the invention of

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the patents-in-suit for the receiving party or its acquirer, successor, predecessor, or

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other affiliate during the pendency of this action and for one year after its

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conclusion, including any appeals. “Prosecution” means drafting, amending,

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advising on the content of, or otherwise affecting the scope or content of patent

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claims or specifications. These prohibitions shall not preclude counsel from

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participating in reexamination or inter partes review proceedings to challenge or

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defend the validity of any patent, but counsel may not participate in the formulation

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or drafting of amended claims in any such proceedings.
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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8.

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PRODUCED IN OTHER LITIGATION

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PROTECTED MATERIAL SUBPOENAED OR ORDERED
8.1 Subpoenas and Court Orders. This Order in no way excuses non-

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compliance with a lawful subpoena or court order. The purpose of the duties

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described in this section is to alert the interested parties to the existence of this

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Order and to give the designator an opportunity to protect its confidentiality

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interests in the court where the subpoena or order issued.

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8.2 Notification Requirement. If a party is served with a subpoena or a
court order issued in other litigation that compels disclosure of any information or

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items designated in this action as PROTECTED DATA, CONFIDENTIAL,

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HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY, or HIGHLY

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CONFIDENTIAL – SOURCE CODE, that party must:

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8.2.1 Promptly notify the designator in writing. Such notification shall
include a copy of the subpoena or court order;
8.2.2 Promptly notify in writing the party who caused the subpoena or

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order to issue in the other litigation that some or all of the material covered

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by the subpoena or order is subject to this Order. Such notification shall

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include a copy of this Order; and

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8.2.3 Cooperate with all reasonable procedures sought by the

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designator whose material may be affected.

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8.3 Wait For Resolution of Protective Order. If the designator timely

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seeks a protective order, the party served with the subpoena or court order shall not

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produce any information designated in this action as PROTECTED DATA,

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CONFIDENTIAL, HIGHLY CONFIDENTIAL – ATTORNEY EYES ONLY or

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HIGHLY CONFIDENTIAL – SOURCE CODE before a determination by the court

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where the subpoena or order issued, unless the party has obtained the designator’s

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permission. The designator shall bear the burden and expense of seeking protection

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of its confidential material in that court.
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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9.

UNAUTHORIZED DISCLOSURE OF DESIGNATED MATERIAL

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If a receiving party learns that, by inadvertence or otherwise, it has disclosed

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designated material to any person or in any circumstance not authorized under this

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Order, it must immediately (1) notify in writing the designator of the unauthorized

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disclosures, (2) use its best efforts to retrieve all unauthorized copies of the

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designated material, (3) inform the person or persons to whom unauthorized

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disclosures were made of all the terms of this Order, and (4) use reasonable efforts

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to have such person or persons execute the Agreement to Be Bound (Exhibit A).

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10.

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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

PROTECTED MATERIAL

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Nothing in this Order shall require the production of documents, information

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or other material that a Party contends is protected from disclosure by the attorney-

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client privilege, the work product doctrine, or other privilege, doctrine or immunity.

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When a producing party gives notice that certain inadvertently produced material is

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subject to a claim of privilege or other protection, the obligations of the receiving

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parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This

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provision is not intended to modify whatever procedure may be established in an e-

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discovery order that provides for production without prior privilege review pursuant

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to Federal Rule of Evidence 502(d) and (e).

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11.

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FILING UNDER SEAL
Without written permission from the designator or a Court order, a party may

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not file in the public record in this action any designated material. A party seeking

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to file under seal any designated material must comply with L.R. 79-5.1. Filings

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may be made under seal only pursuant to a court order authorizing the sealing of the

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specific material at issue. The fact that a document has been designated under this

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Order is insufficient to justify filing under seal. Instead, parties must explain the

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basis for confidentiality of each document sought to be filed under seal. Because a

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party other than the designator will often be seeking to file designated material,
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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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cooperation between the parties in preparing, and in reducing the number and extent

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of, requests for under seal filing is essential. If a receiving party’s request to file

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designated material under seal pursuant to L.R. 79-5.1 is denied by the Court, then

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the receiving party may file the material in the public record unless (1) the

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designator seeks reconsideration within four days of the denial, or (2) as otherwise

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instructed by the Court.

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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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12.

FINAL DISPOSITION
Within 30 days after the final disposition of this action, each party shall

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return all designated material to the designator or destroy such material, including

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all copies, abstracts, compilations, summaries, and any other format reproducing or

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capturing any designated material. The receiving party must submit a written

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certification to the designator by the 30-day deadline that (1) identifies (by

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category, where appropriate) all the designated material that was returned or

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destroyed, and (2) affirms that the receiving party has not retained any copies,

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abstracts, compilations, summaries, or any other format reproducing or capturing

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any of the designated material. This provision shall not prevent outside counsel

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from retaining an archival copy of all pleadings, motion papers, trial, deposition,

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and hearing transcripts, legal memoranda, correspondence, deposition and trial

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exhibits, expert reports, undisclosed attorney work product, and undisclosed

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consultant and expert work product, even if such materials contain designated

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material. Any such archival copies remain subject to this Order.

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Dated: November 20, 2018

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Attorneys for Plaintiffs

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/s/ M. Elizabeth Day
M. Elizabeth Day

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/s/ Amir Kazi
Amir Kazi

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Attorneys for Defendants

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Dated: November 20, 2018

IT IS SO ORDERED.

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DATED: November 21, 2018

/s/ Autumn D. Spaeth
__________________________________
HON. AUTUMN D. SPAETH
UNITED STATES MAGISTRATE JUDGE

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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS

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EXHIBIT A

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AGREEMENT TO BE BOUND

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I, _____________________________ [print or type full name], of

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_________________ [print or type full address], declare under penalty of perjury

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that I have read in its entirety and understand the Protective Order that was issued

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by the United States District Court for the Central District of California on _______

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[date] in the case of ___________ [insert formal name of the case and the number

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and initials assigned to it by the court]. I agree to comply with and to be bound by

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all the terms of this Protective Order, and I understand and acknowledge that failure

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to so comply could expose me to sanctions and punishment for contempt. I

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solemnly promise that I will not disclose in any manner any information or item

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that is subject to this Protective Order to any person or entity except in strict

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compliance with this Order.

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I further agree to submit to the jurisdiction of the United States District Court

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for the Central District of California for the purpose of enforcing this Order, even if

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such enforcement proceedings occur after termination of this action.

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I hereby appoint __________________________ [print or type full name] of

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_______________________________________ [print or type full address and

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telephone number] as my California agent for service of process in connection with

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this action or any proceedings related to enforcement of this Order.

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Date: ___________________________

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City and State where sworn and signed: _________________________________

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Printed name: ____________________
[printed name]
Signature: _______________________
[signature]

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STIPULATED PROTECTIVE ORDER – CASE NO. 8:18-CV-01320-AG-ADS