Wu v. Stitt et al

Filing 138

STIPULATED PROTECTIVE ORDER re 135 (MODIFIED BY THE COURT). Signed by Magistrate Judge Howard R. Lloyd on 6/9/2010. (hrllc2, COURT STAFF) (Filed on 6/9/2010)

*E-FILED 06-09-2010* 1 ROBBINS GELLER RUDMAN & DOWD LLP 2 SHAWN A. WILLIAMS (213113) CHRISTOPHER M. WOOD (254908) 3 100 Pine Street, Suite 2600 San Francisco, CA 94111 4 Telephone: [phone] (fax) 5 [e-mail] [e-mail] 6 Lead Counsel for Plaintiffs 7 [Additional counsel appear on signature page.] 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11
12 In re EXTREME NETWORKS, INC. SHAREHOLDER DERIVATIVE 13 LITIGATION 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 This Document Relates To: ALL ACTIONS. ) ) ) ) ) ) ) ) ) ) No. C-07-02268-RMW STIPULATION AND [PROPOSED] XXXXXXXX PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF DOCUMENTS

(MODIFIED BY THE COURT)

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PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are likely to involve production of

3 confidential, proprietary or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 5 the parties hereby stipulate to and petition the Court to enter the following Stipulation and Protective 6 Order Regarding Confidentiality of Documents ("Stipulated Protective Order"). The parties 7 acknowledge that this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends only to the limited 9 information or items that are entitled to confidential treatment under the applicable legal principles. 10 The parties further acknowledge, as set forth in Section 8, below, that this Stipulated Protective 11 Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets 12 forth the procedures that must be followed and the standards that will be applied when a party seeks 13 permission from the Court to file material under seal. 14 15 2. 2.1 DEFINITIONS Challenging Party: a Party or Non-Party that challenges the designation of

16 information or items under this Order. 17 2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is

18 generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 19 Civil Procedure 26(c). 20 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well

21 as their support staff). 22 2.4 Designating Party: a Party or Non-Party that designates information or items that it

23 produces in disclosures or in responses to discovery as "CONFIDENTIAL." 24 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium

25 or manner in which it is generated, stored, or maintained (including, among other things, testimony, 26 transcripts, and tangible things), that are produced or generated in disclosures or responses to 27 discovery in this matter. 28
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2.6

Expert: a person with specialized knowledge or experience in a matter pertinent to the

2 litigation who has been retained by a Party or its counsel to serve as an expert witness or as a 3 consultant in this action. 4 2.7 House Counsel: attorneys who are employees of a party to this action. House

5 Counsel does not include Outside Counsel of Record or any other outside counsel. 6 2.8 Non-Party: any natural person, partnership, corporation, association, or other legal

7 entity not named as a Party to this action. 8 2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action

9 but are retained to represent or advise a party to this action and have appeared in this action on 10 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 11 2.10 Party: any party to this action, including all of its officers, directors, employees,

12 consultants, retained experts, and Outside Counsel of Record (and their support staffs). 13 2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material

14 in this action. 15 2.12 Professional Vendors: persons or entities that provide litigation support services (e.g.,

16 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 17 storing, or retrieving data in any form or medium) and their employees and subcontractors. 18 2.13 Protected Material: any Disclosure or Discovery Material that is designated as

19 "CONFIDENTIAL." 20 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a

21 Producing Party. 22 23 3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material (as

24 defined above), but also (1) any information copied or extracted from Protected Material; (2) all 25 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, 26 conversations, or presentations by Parties or their Counsel that might reveal Protected Material. 27 However, the protections conferred by this Stipulation and Order do not cover the following 28 information: (a) any information that is in the public domain at the time of disclosure to a Receiving
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1 Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 2 publication not involving a violation of this Order, including becoming part of the public record 3 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 4 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 5 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of 6 Protected Material at trial shall be governed by a separate agreement or order. 7 8 4. DURATION

Even after final disposition of this litigation, the confidentiality obligations imposed by this

9 Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 10 otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and 11 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 12 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the 13 time limits for filing any motions or applications for extension of time pursuant to applicable law. For a period of six months after the final disposition of this action, this court will retain 14 5. DESIGNATING PROTECTED MATERIAL jurisdiction to enforce the terms of this order. 15 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or 16 Non-Party that designates information or items for protection under this Order must take care to limit 17 any such designation to specific material that qualifies under the appropriate standards. The 18 Designating Party must designate for protection only those parts of material, documents, items, or 19 oral or written communications that qualify ­ so that other portions of the material, documents, 20 items, or communications for which protection is not warranted are not swept unjustifiably within 21 the ambit of this Order. 22 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown

23 to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 24 encumber or retard the case development process or to impose unnecessary expenses and burdens on 25 other parties) expose the Designating Party to sanctions. 26 If it comes to a Designating Party's attention that information or items that it designated for

27 protection do not qualify for protection, that Designating Party must promptly notify all other Parties 28 that it is withdrawing the mistaken designation.
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5.2

Manner and Timing of Designations. Except as otherwise provided in this Order (see,

2 e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or 3 Discovery Material that qualifies for protection under this Order must be clearly so designated 4 before the material is disclosed or produced. 5 6 Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, but

7 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 8 affix the legend "CONFIDENTIAL" to each page that contains protected material. If only a portion 9 or portions of the material on a page qualifies for protection, the Producing Party also must clearly 10 identify the protected portion(s) (e.g., by making appropriate markings in the margins). 11 A Party or Non-Party that makes original documents or materials available for inspection

12 need not designate them for protection until after the inspecting Party has indicated which material it 13 would like copied and produced. During the inspection and before the designation, all of the 14 material made available for inspection shall be deemed "CONFIDENTIAL." After the inspecting 15 Party has identified the documents it wants copied and produced, the Producing Party must 16 determine which documents, or portions thereof, qualify for protection under this Order. Then, 17 before producing the specified documents, the Producing Party must affix the "CONFIDENTIAL" 18 legend to each page that contains Protected Material. If only a portion or portions of the material on 19 a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) 20 (e.g., by making appropriate markings in the margins). 21 (b) for testimony given in deposition or in other pretrial or trial proceedings, that

22 the Designating Party identify on the record, before the close of the deposition, hearing, or other 23 proceeding, all protected testimony. 24 (c) for information produced in some form other than documentary and for any

25 other tangible items, that the Producing Party affix in a prominent place on the exterior of the 26 container or containers in which the information or item is stored the legend "CONFIDENTIAL." If 27 only a portion or portions of the information or item warrant protection, the Producing Party, to the 28 extent practicable, shall identify the protected portion(s).
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5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to

2 designate qualified information or items does not, standing alone, waive the Designating Party's 3 right to secure protection under this Order for such material. Upon timely correction of a 4 designation, the Receiving Party must make reasonable efforts to assure that the material is treated in 5 accordance with the provisions of this Order. 6 7 6. 6.1 CHALLENGING CONFIDENTIALITY DESIGNATIONS Timing of Challenges. Any Party or Non-Party may challenge a designation of

8 confidentiality at any time. Unless a prompt challenge to a Designating Party's confidentiality 9 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, 10 or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a 11 confidentiality designation by electing not to mount a challenge promptly after the original 12 designation is disclosed. 13 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process

14 by providing written notice of each designation it is challenging and describing the basis for each 15 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 16 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 17 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 18 begin the process by conferring directly (in voice to voice dialogue; other forms of communication 19 are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging 20 Party must explain the basis for its belief that the confidentiality designation was not proper and 21 must give the Designating Party an opportunity to review the designated material, to reconsider the 22 circumstances, and, if no change in designation is offered, to explain the basis for the chosen 23 designation. A Challenging Party may proceed to the next stage of the challenge process only if it 24 has engaged in this meet and confer process first or establishes that the Designating Party is 25 unwilling to participate in the meet and confer process in a timely manner. 26 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court

27 intervention, the Designating Party shall file and serve a motion to retain confidentiality under Civil 28 Local Rule 7 (and in compliance with Civil Local Rule 79-5, if applicable) within 21 days of the
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1 initial notice of challenge or within 14 days of the parties agreeing that the meet and confer process 2 will not resolve their dispute, whichever is earlier. Each such motion must be accompanied by a 3 competent declaration affirming that the movant has complied with the meet and confer 4 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a 5 motion including the required declaration within 21 days (or 14 days, if applicable) shall 6 automatically waive the confidentiality designation for each challenged designation. In addition, the 7 Challenging Party may file a motion challenging a confidentiality designation at any time if there is 8 good cause for doing so, including a challenge to the designation of a deposition transcript or any 9 portions thereof. Any motion brought pursuant to this provision must be accompanied by a 10 competent declaration affirming that the movant has complied with the meet and confer 11 requirements imposed by the preceding paragraph. 12 The burden of persuasion in any such challenge proceeding shall be on the Designating Party.

13 Frivolous challenges, and those made for an improper purpose (e.g., to harass or impose unnecessary 14 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 15 Designating Party has waived the confidentiality designation by failing to file a motion to retain 16 confidentiality as described above, all parties shall continue to afford the material in question the 17 level of protection to which it is entitled under the Producing Party's designation until the Court 18 rules on the challenge. 19 20 7. 7.1 ACCESS TO AND USE OF PROTECTED MATERIAL Basic Principles. A Receiving Party may use Protected Material that is disclosed or

21 produced by another Party or by a Non-Party in connection with this case only for prosecuting, 22 defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to 23 the categories of persons and under the conditions described in this Order. When the litigation has 24 been terminated, a Receiving Party must comply with the provisions of section 13 below (FINAL 25 DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a location and in a

27 secure manner that ensures that access is limited to the persons authorized under this Order. 28
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7.2

Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise ordered

2 by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any 3 information or item designated "CONFIDENTIAL" only to: 4 (a) the Receiving Party's Outside Counsel of Record in this action, as well as

5 employees of said Outside Counsel of Record to whom it is reasonably necessary to disclose the 6 information for this litigation and who have signed the "Acknowledgment and Agreement to Be 7 Bound" that is attached hereto as Exhibit A; 8 (b) the officers, directors, and employees (including House Counsel) of the

9 Receiving Party to whom disclosure is reasonably necessary for this litigation and who have signed 10 the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 11 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure

12 is reasonably necessary for this litigation and who have signed the "Acknowledgment and 13 Agreement to Be Bound" (Exhibit A); 14 15 (d) (e) the Court and its personnel; court reporters and their staff, professional jury or trial consultants, mock

16 jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and 17 who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); 18 (f) during their depositions, witnesses in the action to whom disclosure is

19 reasonably necessary and who have signed the "Acknowledgment and Agreement to Be Bound" 20 (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the Court. Pages of 21 transcribed deposition testimony or exhibits to depositions that reveal Protected Material must be 22 separately bound by the court reporter and may not be disclosed to anyone except as permitted under 23 this Stipulated Protective Order. 24 (g) the author or recipient of a document containing the information or a

25 custodian or other person who otherwise possessed or knew the information. 26 27 28
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8.

PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION

If a Party is served with a subpoena or a court order issued in other litigation that compels 3 disclosure of any information or items designated in this action as "CONFIDENTIAL," that Party 4 must: 5 (a) 6 include a copy of the subpoena or court order; 7 (b) 8 in the other litigation that some or all of the material covered by the subpoena or order is subject to 9 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 10 (c) 11 the Designating Party whose Protected Material may be affected. 12 If the Designating Party timely seeks a protective order, the Party served with the subpoena 13 or court order shall not produce any information designated in this action as "CONFIDENTIAL" 14 before a determination by the Court from which the subpoena or order issued, unless the Party has 15 obtained the Designating Party's permission. The Designating Party shall bear the burden and 16 expense of seeking protection in that court of its confidential material ­ and nothing in these 17 provisions should be construed as authorizing or encouraging a Receiving Party in this action to 18 disobey a lawful directive from another court. 19 9. 20 21 A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION (a) The terms of this Order are applicable to information produced by a Noncooperate with respect to all reasonable procedures sought to be pursued by promptly notify in writing the party who caused the subpoena or order to issue promptly notify in writing the Designating Party. Such notification shall

22 Party in this action and designated as "CONFIDENTIAL." Such information produced by Non23 Parties in connection with this litigation is protected by the remedies and relief provided by this 24 Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking 25 additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to produce a

27 Non-Party's confidential information in its possession, and the Party is subject to an agreement with 28 the Non-Party not to produce the Non-Party's confidential information, then the Party shall:
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(i)

promptly notify in writing the Requesting Party and the Non-Party that

2 some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 3 (ii) promptly provide the Non-Party with a copy of the Stipulated

4 Protective Order in this litigation, the relevant discovery request(s), and a reasonably specific 5 description of the information requested; and 6 7 Party. 8 (c) If the Non-Party fails to object or seek a protective order from this Court (iii) make the information requested available for inspection by the Non-

9 within 14 days of receiving the notice and accompanying information, the Receiving Party may 10 produce the Non-Party's confidential information responsive to the discovery request. If the Non11 Party timely seeks a protective order, the Receiving Party shall not produce any information in its 12 possession or control that is subject to the confidentiality agreement with the Non-Party before a 13 determination by the Court.1 Absent a court order to the contrary, the Non-Party shall bear the 14 burden and expense of seeking protection in this court of its Protected Material. 15 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected

17 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 18 the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 19 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) 20 inform the person or persons to whom unauthorized disclosures were made of all the terms of this 21 Order, and (d) request such person or persons to execute the "Acknowledgment and Agreement to 22 Be Bound" that is attached hereto as Exhibit A. 23 24 25 26 The purpose of this provision is to alert the interested parties to the existence of confidentiality rights of a Non-Party and to afford the Non-Party an opportunity to protect its 27 confidentiality interests in this court. 28
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11.

INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL

When a Producing Party gives notice to Receiving Parties that certain inadvertently produced 3 material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties 4 are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 5 modify whatever procedure may be established in an e-discovery order that provides for production 6 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 7 parties reach an agreement on the effect of disclosure of a communication or information covered by 8 the attorney-client privilege or work product protection, the parties may incorporate their agreement 9 in the Stipulated Protective Order submitted to the Court. 10 12. 11 12.1 12 its modification by the court in the future. 13 12.2 14 no Party waives any right it otherwise would have to object to disclosing or producing any 15 information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no 16 Party waives any right to object on any ground to use in evidence of any of the material covered by 17 this Protective Order. 18 12.3 19 a court order secured after appropriate notice to all interested persons, a Party may not file in the 20 public record in this action any Protected Material. A Party that seeks to file under seal any 21 Protected Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 22 under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 23 issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing 24 that the Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to 25 protection under the law. If a Receiving Party's request to file Protected Material under seal 26 pursuant to Civil Local Rule 79-5(d) is denied by the court, then the Receiving Party may file the 27 28
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MISCELLANEOUS Right to Further Relief. Nothing in this Order abridges the right of any person to seek

Right to Assert Other Objections. By stipulating to the entry of this Protective Order

Filing Protected Material. Without written permission from the Designating Party or

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1 information in the public record pursuant to Civil Local Rule 79- 5(e) unless otherwise instructed by 2 the court. 3 FINAL DISPOSITION. Within 60 days after the final disposition of this action, as defined

4 in paragraph 4, each Receiving Party must return all Protected Material to the Producing Party or 5 destroy such material. As used in this subdivision, "all Protected Material" includes all copies, 6 abstracts, compilations, summaries, and any other format reproducing or capturing any of the 7 Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party 8 must submit a written certification to the Producing Party (and, if not the same person or entity, to 9 the Designating Party) by the 60 day deadline that (1) identifies (by category, where appropriate) all 10 the Protected Material that was returned or destroyed and (2)affirms that the Receiving Party has not 11 retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing 12 any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 13 archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 14 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and 15 consultant and expert work product, even if such materials contain Protected Material. Any such 16 archival copies that contain or constitute Protected Material remain subject to this Protective Order 17 as set forth in Section 4 (DURATION). 18 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. ROBBINS GELLER RUDMAN & DOWD LLP SHAWN A. WILLIAMS CHRISTOPHER M. WOOD

19 DATED: May 28, 2010 20 21 22 23 24 25 26 27 28
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/s/ CHRISTOPHER M. WOOD 100 Pine Street, Suite 2600 San Francisco, CA 94111 Telephone: [phone] (fax)

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1 2 3 4 5 6 7 8 DATED: May 28, 2010 9 10 11 12 13 14 15 16 I, Christopher M. Wood, am the ECF User whose ID and password are being used to file this 17 Stipulation and [Proposed] Protective Order Regarding Confidentiality of Documents. In compliance with General Order 45, X.B., I hereby attest that Joseph E. Floren has concurred in this 18 filing. 19 DATED: May 28, 2010 20 21 22 23 24 25 26 27 28
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ROBBINS GELLER RUDMAN & DOWD LLP TRAVIS E. DOWNS III JAMES I. JACONETTE BENNY C. GOODMAN III LUCAS F. OLTS 655 West Broadway, Suite 1900 San Diego, CA 92101 Telephone: [phone] (fax) Lead Counsel for Plaintiffs MORGAN, LEWIS & BOCKIUS LLP JOSEPH E. FLOREN

/s/ JOSEPH E. FLOREN One Market Street Spear Street Tower Telephone: [phone] (fax) Attorneys for Defendants

/s/ CHRISTOPHER M. WOOD * * *

ORDER AS MODIFIED BY THE COURT, PURSUANT TO STIPULATION, IT IS SO ORDERED. ^ June 9, 2010 DATED: _________________________ ____________________________________ THE HONORABLEXXXXXXXXXXXXXX XXXXXXXXXXX RONALD M. WHYTE UNITED STATES XXXXXX JUDGE DISTRICT MAGISTRATE HOWARD R. LLOYD

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EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND I, ____________________________________________ [print or type full name], of

4 _____________________________________________________ [print or type full address], 5 declare under penalty of perjury that I have read in its entirety and understand the Stipulation and 6 Protective Order Regarding Confidentiality of Documents that was issued by the United States 7 District Court for the Northern District of California on ____________________ [date] in the case 8 of In re Extreme Networks, Inc. Shareholder Derivative Litigation, Case No. C-07-02268-RMW 9 ("Stipulation and Protective Order"). I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so comply could 11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not 12 disclose in any manner any information or item that is subject to this Stipulated Protective Order to 13 any person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court for the

15 Northern District of California for the purpose of enforcing the terms of this Stipulated Protective 16 Order, even if such enforcement proceedings occur after termination of this action. 17 I hereby appoint __________________________________ [print or type full name] of

18 _________________________________________________________________ [print or type full 19 address and telephone number] as my California agent for service of process in connection with this 20 action or any proceedings related to enforcement of this Stipulated Protective Order. 21 Date: 22 City and State where Sworn and Signed: 23 Printed name: 24 25 26 27 28
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[printed name] Signature: [signature]

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