Leader Technologies Inc. v. Facebook Inc.

Filing 699

Joint STIPULATION Regarding Amendment to Stipulated Protective Order re 138 Stipulation by Facebook Inc.(a Delaware corporation). (Caponi, Steven)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
LEADER TECHNOLOGIES, INC., a Delaware
corporation,
Plaintiff,
v.
FACEBOOK, INC., a Delaware corporation,
Defendant.

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C. A. No. 08-862-LPS

STIPULATION REGARDING AMENDMENT TO STIPULATED
PROTECTIVE ORDER
WHEREAS, the parties executed a Stipulated Protective Order on April 27, 2009 (D.I.
35);
WHEREAS, the Court entered the Stipulated Protective Order on April 28, 2009 (D.I.
35);
WHEREAS, the parties executed an Amendment to the Stipulated Protective Order on
October 26, 2009 (D.I. 138);
WHEREAS, the Court entered the Amendment to the Stipulated Protective Order on
October 27, 2009 (D.I. 138);
WHEREAS, the Amendment to the Stipulated Protective Order (D.I. 138) identified
Cooley Godward Kronish LLP as outside counsel for Facebook, Inc.;
WHEREAS, Cooley Godward Kronish LLP continues to represent Facebook, Inc. in
connection with this litigation;
WHEREAS, Gibson, Dunn & Crutcher LLP now also represents Facebook, Inc. in
connection with this litigation;

WHEREAS, both parties desire to amend the Stipulated Protective Order to identify
additional outside counsel for the parties;
NOW, THEREFORE, HAVING BEEN STIPULATED AND AGREED by and between
the parties, through their respective counsel, subject to the approval of the Court, the parties
hereby agree to amend the Stipulated Protective Order to include Gibson, Dunn & Crutcher LLP
as additional outside counsel for Facebook;
THE PARTIES agree that Facebook’s additional outside counsel at Gibson, Dunn &
Crutcher LLP are subject to the terms of the Stipulated Protective Order;
THE PARTIES also agree that Facebook’s outside counsel at Cooley Godward Kronish
LLP remains subject to the terms of the Stipulated Protective Order.

POTTER ANDERSON & CORROON LLP

BLANK ROME LLP

By: /s/ Philip A. Rovner
Philip A. Rovner (#3215)
Hercules Plaza
P.O. Box 951
Wilmington, DE 19899
[phone]
[e-mail]

By: /s/ Steven L. Caponi
Steven L. Caponi (#3484)
1201 Market Street
Suite 800
Wilmington, DE 19801
[phone]
[e-mail]

Attorneys for Plaintiff
Leader Technologies, Inc.

Attorneys for Defendant
Facebook, Inc.

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OF COUNSEL:

OF COUNSEL:

Paul J. Andre
King & Spalding LLP
333 Twin Dolphin Drive
Suite 400
Redwood Shores, California 94065
[phone]

Heidi L. Keefe
Cooley Godward Kronish LLP
3000 El Camino Real
5 Palo Alto Square
Palo Alto, California 94306
[phone]
Thomas G. Hungar
William G. Jenks
Gibson, Dunn & Crutcher LLP
1050 Connecticut Ave. N.W.
Washington, DC 20036
[phone]

101097652.2

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