GLOBAL COMMUNICATIONS INC v. DIRECTV INC et al

Filing 222

AMENDED JOINT STIPULATED PROTECTIVE ORDER. Signed by JUDGE ROBERT L HINKLE on 5/16/2014. (dlt)

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
TALLAHASSEE DIVISION
GLOBAL COMMUNICATIONS, INC.,
Plaintiff,
v.
DIRECTV Inc., THE DIRECTV
GROUP, INC., and JOHN DOE
MANUFACTURERS Nos. 1-10,
Defendant.
DIRECTV, LLC and THE DIRECTV
GROUP, INC.,
Counterclaimants,
v.
GLOBAL COMMUNICATIONS, INC.,
Counterclaim Defendant.

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Case No.: 4:12-cv-00651-RH-CAS

AMENDED JOINT STIPULATED PROTECTIVE ORDER
WHEREAS, it appears that certain documents, information, and tangible objects that may
be produced in discovery conducted in this proceeding or submitted to this Court by way of
pleadings, motions, declarations or other materials, may contain trade secrets, confidential
research development, technology, commercial information, other proprietary or other highly,
confidential information belonging to DIRECTV, LLC and The DIRECTV Group, Inc.
(collectively, “DIRECTV”), GLOBAL COMMUNICATIONS, INC. (“GLOBAL”), other parties
that are named in this action, or third-parties (hereinafter “Confidential Information”); and

WHEREAS, such Confidential Information should not be released in the public domain,
but rather should be treated as confidential in accordance with the Federal Rules of Civil
Procedure and the privacy interests of the parties and other persons; and
WHEREAS, the disclosure or dissemination of such Confidential Information could
cause irreparable competitive harm to the owner of such information;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between DIRECTV and
Global, through their respective counsel of record, that the Court should issue this Protective
Order concerning and protecting the confidentiality of documents, information, and tangible
objects produced during discovery as follows:
1.

Discovery Material.
a.

This stipulation and order (the “Protective Order”) shall govern the use,

handling and disclosure of all documents,1 things, transcripts of and exhibits to depositions,
initial disclosures, interrogatory answers, responses to requests for admissions, and other written,
recorded, or graphic material, including all copies, excerpts, abstracts, or summaries therefore
(collectively, “Discovery Material”), produced, made available for inspection, filed with the
Court, served, or obtained by any party or non-party in this action (collectively, “Person(s)”).
b.

Discovery Material may be designated as “CONFIDENTIAL” or

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” by the counsel of record for the
Party producing such Discovery Material (“the Designating Party”), so long as such counsel
determines, in good faith, that such Discovery Material complies with the definition in Paragraph
2(a) or 3(a) of this Order, respectively.

1

The term “document,” as used herein encompasses “documents or electronically stored information—
including writings, drawings, graphs, charts, photographs, sound recordings, images and other data or data
compilations—stored in any medium from which information can be obtained either directly or, if necessary, after
translation by the responding party into reasonably usable form.” See Federal Rules of Civil Procedure, Rule 34(a).

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c.

Non-parties required to produce Discovery Material may avail themselves

of the protections of this Protective Order, provided they agree, in writing, to be bound by all of
the terms and conditions of this Protective Order.
2.

“CONFIDENTIAL” Discovery Material.
a.

Discovery Material designated as “CONFIDENTIAL” shall be limited to

Discovery Materials that have been treated as confidential in the ordinary course of business,
have not been disclosed publicly, and which the Designating Party believes in good faith must be
held confidential to protect business or commercial interests.
b.

Discovery Material designated as “CONFIDENTIAL,” or information

derived therefrom, may be disclosed, shown, or made available, or communicated in any way
only to the following Persons:
(i)

outside counsel for the parties to this litigation, including Persons

working solely in secretarial, clerical, and paralegal capacities, and who are
providing assistance to counsel in this action;
(ii)

qualified Persons taking testimony involving Designated Material,

and necessary stenographic, videographic, and clerical personnel thereof;
(iii)

consultants or experts and their staff who are employed for the

purposes of this litigation, provided that the provisions of Paragraph 8 of this
Protective Order are complied with prior to any disclosure of any Designated
Material to such an expert or consultant;
(iv)

the Court and the Court’s staff;

(v)

officers, directors and employees of a non-Designating Party, but

only to the extent necessary to participate in, assist in and monitor the progress of

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this action and for no other purpose, and provided the provisions of Paragraph 8
of this Order are complied with prior to any disclosure;
(vi)

third-parties specifically retained to assist outside counsel in

copying, imaging, and/or coding of documents, but for that purpose only,
provided that all such documents are kept and maintained in a separate and secure
place.
3.

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Discovery
Material
a.

Discovery Material designated as “HIGHLY CONFIDENTIAL –

ATTORNEYS’ EYES ONLY” shall be limited to Discovery Materials that have not been
disclosed publicly and which the Designating Party believes in good faith are so commercially
sensitive or confidential that the disclosure to employees of another party or a third party, even
under the restricted terms and conditions applicable to Discovery Materials designated as
“CONFIDENTIAL,” would not provide adequate protection to the business or commercial
interests of the producing Person. Examples of “HIGHLY CONFIDENTIAL – ATTORNEYS’
EYES ONLY” materials would include documents that reflect the terms of business relationships
with vendors (including bids, proposals, offers, licenses and contractual terms); documents that
reveal trade secrets and proprietary information about the technical aspects of the Designating
Party; financial or investment information (including revenues, costs, expenditures,
compensation and profits); confidential government filings (including tax returns); and
documents that reflect business strategies that either party would not, in the ordinary course of
business, disclose to the other party (including, among other things, financial projections,
competitive strategy and business models).

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b.

Discovery Material designated as “HIGHLY CONFIDENTIAL –

ATTORNEYS’ EYES ONLY,” or information derived therefrom, may be disclosed, shown, or
made available, or communicated in any way only to the following Persons:
(i)

Persons identified in Paragraphs 2(b)(i)-(iv), and 2(b)(vi) of this

Order; and
(ii)

in-house counsel for any non-Designating Party, but only if the

Designating Party in writing permits access to particular items of such Discovery
Material to particular in-house counsel. If such written permission is granted,
then unless otherwise expressly stated, such permission is limited to a single
identified non-Designating Party’s in-house counsel who may have access to
these particular items of such Discovery Material. In-house counsel receiving
access under such permission shall use and disclose such Discovery Material only
as permitted by this Protective Order.
c.

Notwithstanding the foregoing, the parties recognize that it may be

desirable to permit certain summary financial information derived from Discovery Material
designated as “HIGHLY CONFIDENTIAL–ATTORNEYS’ EYES ONLY” to be considered by
the Non-Designating Party for purposes of mediation and/or settlement negotiations.
accordingly, should counsel for the non-Designating Party believe that it would be beneficial to
review certain summary financial documents with a Person identified in Paragraph 2(b)(v),
counsel may request permission from counsel for the Designating Party by disclosing, in writing,
the particular document or information sought to be disclosed and the Person identified in
Paragraph 2(b)(v) to whom the information is to be disclosed.

Upon receipt of written

authorization of counsel for the Designating Party, but not otherwise, counsel for the non-

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Designating Party may review the identified Designated Material with the identified Person.
Any financial summaries authorized to be disclosed to a Person identified in Paragraph 2(b)(v)
pursuant

to

this

Paragraph

shall

remain

designated

“HIGHLY

CONFIDENTIAL–

ATTORNEYS’ EYES ONLY” under this Protective Order and all of the remaining provisions of
this Protective Order shall remain applicable to them.
d.

All Discovery Material that is produced by another party (or a third-party)

and that is designated as “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY” shall be
maintained in the United States and shall never be sent or taken outside of the United States.
4.

Designated Material.
a.

All Discovery Material designated as either “CONFIDENTIAL” or

“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” and all information derived
therefrom, shall be referred to in this Protective Order as “Designated Material” and shall be
handled in strict accordance with the terms of this Protective Order. Specifically, absent an order
by this Court, such Designated Material shall be used by the parties to this action solely in
connection with this action or any appeal therefrom, and not for any other purpose, except as
required by law, and such Designated Material shall not be disclosed to anyone except as
provided herein. Designated Material may be disclosed only under the circumstances and to the
Persons specifically provided for herein or in any subsequent Court order, or with the explicit
written consent of the Designating Party with respect to specifically identified Designated
Material.
b.

Nothing contained herein shall prevent any party from disclosing or using

its own Designated Material or information contained therein as it deems appropriate.

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5.

Designating Discovery Material.
a.

Designated Material shall be so designated by marking or stamping each

page or thing of such material “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY” prior to delivery of possession to another party.
b.

If a person producing documents or things elects to make the documents

and things available for inspection and copying rather than producing then, then designation need
not be made until copies of the materials are requested after inspection by counsel. Making
documents and things available for inspection by another party’s counsel shall not constitute a
waiver of any claim of confidentiality, and all materials provided for inspection by a party’s
counsel shall be treated as though designated HIGHLY CONFIDENTIAL – ATTORNEYS’
EYES ONLY at the time of inspection. All materials produced for inspection but not selected
for more formal production will continue to be considered and treated as if designated HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY, except to the extent such other materials are
otherwise formally produced or used in this matter.
c.

A party may designate Discovery Material produced by another party or

third party, within seven (7) business days from the date the Designating Party receives notice
that the Discovery Material has been produced, by identifying the Discovery Material and
requested Designation.
6.

Designating Depositions.

Any deposition testimony or portions thereof may be classified as Designated Material
under the terms of this Protective Order by a party either orally at the deposition by stating the
appropriate confidentiality designation on the record, or by doing so within fifteen (15) business
days after receipt of the official transcript of such deposition by sending a written list of the

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pages, lines and/or exhibits to be so designated to counsel for the other parties. The parties shall
then treat any designated portions of the transcript and/or exhibits in accordance with the terms
of this Protective Order as if marked or stamped pursuant to Paragraphs 5(a). Before the
expiration of the fifteen (15) business days, deposition transcripts and exhibits not previously
produced shall be treated as if they had been designated HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY.
a.

Where testimony is designated under the terms of this Protective Order at

a deposition, the Designating Party may exclude from the deposition all Persons other than those
to whom the Designated Material may be disclosed under Paragraphs 2(b) or 3(b) of this
Protective Order, as applicable. The failure of such other Persons to comply with a request of
this type shall constitute substantial justification for outside counsel to advise the witness not to
answer a question seeking the revelation of Designated Material.
b.

Any party may mark a deposition exhibit Designated Material and

examine any witness thereon, provided the deposition witness is one to whom the exhibit may be
disclosed under Paragraphs 2(b), 3(b) or 7 of this Protective Order. In addition, Designated
Material may be used by receiving or Non-Designating parties in deposing the Designating Party
and in deposing any directors, officers, employees, agents, or attorneys of such Designating
Party.
7.

Disclosure to Authors and Addressees.

The designation of any document under the terms of this Protective Order shall not
preclude any party from showing the document to any Person who appears as an author,
addressee, or recipient on the face of the document.

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8.

Disclosure to Other Persons.

Except for Persons described in Paragraphs 2(b)(i)-(ii), 2(b)(iv), and 2(b)(vi) of this
Protective Order, all Persons to whom Designated Material is disclosed or by whom Designated
Material is used, including parties, non-parties, and their representatives, shall be informed of
and agree to be bound by the terms of this Protective Order and shall take all necessary
precautions to prevent any disclosure or use of Designated Material other than as authorized
herein.
a.

At least five (5) business days prior to disclosing Designated Material to

any Person, other than Persons described in Paragraph 2(b)(i)-(ii), 2(b)(iv), and 2(b)(vi) of this
Protective Order, the Disclosing Party shall provide to the Person whose Designated Material it
wishes to disclose, a copy of the current Curriculum Vitae of the Person to whom it proposes
disclosing Designated Material. In addition, prior to dissemination of Designated Material to
any Person, other than Persons described in Paragraph 2(b)(i)-(ii), 2(b)(iv), and 2(b)(vi) herein,
the Disclosing Party shall: (i) obtain from such Person a written acknowledgment, substantially
in the form of Exhibit A annexed hereto, that such Person has reviewed a copy of this Protective
Order, will comply with its terms in all respects, and will submit to the jurisdiction of this Court
for adjudication of any dispute about whether such Person has complied with the terms of this
Protective Order; (ii) maintain a copy of this acknowledgement evidencing that such Person has
executed the undertaking set out in this Paragraph; and (iii) provide a copy of this
acknowledgement to the Designating Party whose Designated Material it proposes to disclose.
b.

Individuals who are authorized to review Designated Material pursuant to

this Protective Order shall hold the Designated Material and its contents in confidence and shall
not divulge the Designated Material or its contents, either verbally or in writing, except as

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expressly permitted herein, unless authorized to do so by a further Order of this Court or as
specifically required by law.
9.

Custody of Designated Material.

All Designated Material shall be maintained in the custody of the receiving party’s
outside counsel of record, and no partial or complete copies thereof containing Designated
Material shall be retained by anyone else at any location, other than the offices of such counsel
not on the premises of a party, except that those Persons identified in Paragraphs 2(b)(iii) and
2(b)(vi) herein may retain documents on a temporary basis for purposes of study, analysis, and
preparation of this case. A Person with custody of Designated Material shall maintain it in a
manner that limits access solely to those qualified persons set forth in Paragraphs 2(b), 3(b) and
7 herein.
10.

Filings with the Court.
a.

Designated Material, when filed with the Court as part of any pleading or

as evidence, shall be delivered to the Clerk of the Court in sealed enclosures on which shall be
affixed the title of this action, an indication of the nature of their contents, the designation
specifying whether the material contained within is “CONFIDENTIAL” and/or “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY,” whose Confidential Information is
contained therein, and a statement substantially in the following form:
THIS ENVELOPE CONTAINS MATERIALS SUBJECT TO
A PROTECTIVE ORDER ENTERED IN THIS ACTION. IT
IS NOT TO BE OPENED NOR ARE ITS CONTENTS TO BE
DISPLAYED, REVEALED, OR MADE PUBLIC, EXCEPT
BY ORDER OF THE COURT.
The submission shall clearly indicate which portions contain Designated Material.
b.

Designated Material contained or substantially described in the papers

shall remain under seal until further Order of this Court, provided, however, that such papers

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may be furnished to Persons or entities that may receive Designated Material as allowed by
Paragraphs 2(b) and 3(b) herein. Upon or after filing of any paper containing or substantially
describing Designated Material, the filing party may file on the public record a redacted
duplicate copy of the paper that does not reveal the Designated Material.

Further, if the

protection for any such material expires, a party may file on the public record a duplicate copy
that also contains the formerly protected material.
11.

Failure to Designate.

A Designating Party that inadvertently fails to mark Designated Material as
“CONFIDENTIAL’ and/or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” at the
time of the production shall have five (5) business days from discovery of the oversight to
correct its failure to designate. Such correction and notice thereof shall be made in writing,
accompanied by substitute copies of each Discovery Material appropriately marked as
“CONFIDENTIAL” and/or “HIGHLY, CONFIDENTIAL–ATTORNEYS’ EYES ONLY.”
Within five (5) business days of receipt of the substitute copies, the receiving party shall return
or destroy the previously unmarked materials and all copies thereof.
12.

Inadvertent Disclosure.
a.

A receiving party that inadvertently discloses Designated Material to any

Person not authorized to view such material under Paragraphs 2(b) or 3(b) herein shall promptly,
upon learning of such inadvertent disclosure of Designated Material: (1) demand immediate
return or destruction from the unauthorized Person of any and all copies, extracts, summaries or
records of the disclosed Designated Material and any documents created in whole or in part with
information derived from such Designated Material; and (2) immediately notify the Designating
Party of the inadvertent disclosure. A receiving party’s demand for return from unauthorized

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Persons and notification to the Designating Party for such inadvertently disclosed Designated
Material is without prejudice to its right to challenge the designation of the Designated Material.
b.

The parties expect to produce substantial quantities of documents, items

and information in this case, which may result in an inadvertent disclosure of information,
documents, or materials which are subject to the claims of protection under the attorney-client
privilege, work product doctrine, or other doctrines or privileges of nondisclosure. Promptly
upon learning of such inadvertent disclosure, the producing Person may notify any party that said
production was inadvertent disclosure of confidential or privileged material and demand return
thereof. On such timely demand, the other party must return such assertedly confidential or
privileged material and destroy all copies, extracts, summaries, or record thereof. A party’s
return of such document or item is without prejudice to its right to challenge the claim of
privilege or confidentiality.
13.

Objections to Designations. If at any time during the pendency or trial of this

action, counsel for any party claims that Designated Material is not appropriately designated,
objecting counsel may serve a written notice of objection on all parties and affected entities,
identifying with particularity the Designated Material for the challenged designation, stating the
basis for each challenge, and proposing a new designation for such materials. The Designating
Party has ten (10) business days either to re-designate the materials according to the proposal or
to file and serve a motion seeking an Order that such materials remain as designated, in which
case the Designating Party shall have the burden of proving that the original designation was
appropriate or that a designation other than that proposed is appropriate. T he original
designation shall remain effective until three (3) business days after entry of an Order redesignating the materials. The failure of any party to challenge any designation by any other

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party shall not constitute a waiver of the right to challenge the designation at a later time nor an
admission of the correctness of the designation.
14.

Use at Trial.
Disclosure and use of Designated Material at trial and in subsequent proceedings

shall be governed by the terms of an Order to be entered by the Court at the appropriate time.
15.

No Prejudice.
a.

Unless the Court orders it, or unless all parties stipulate otherwise,

evidence of the existence or nonexistence of a designation under this Protective Order shall not
be admissible for any purpose during the trial of this action. This provision, however, does not
impact a party’s right otherwise to proffer the document during the trial of this action with the
designation removed.
b.

This Protective Order is being entered without prejudice to the right of any

party to move the Court for modification of or relief from any of its terms.
16.

Subpoena By Third Parties, Other Courts or Agencies.
If any of the parties receives a subpoena or other lawful process (referred to in

this Paragraph as a Subpoena) requesting or directing that party to produce to a third-party
(including, without limitation, a governmental agency) any Designated Material produced by
another party, the party receiving the Subpoena shall immediately give notice to the Designating
Party of the fact of the Subpoena and a summary of the documents requested in the Subpoena so
as to enable the Designating Party to attempt to intervene or otherwise object to the production of
the Designated Material.

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17.

Applicability of Designations.
Notwithstanding any other provision herein to the contrary, the confidentiality

obligations of this Protective Order shall not apply or shall cease to apply to any information
that:
a.

at the time of disclosure hereunder, was already in the public domain by

publication or otherwise;
b.

since the time of disclosure hereunder, has become, through no act or

failure on the part of the receiving party, part of the public domain by publication or otherwise;
or
c.

after disclosure hereunder, was acquired by the receiving party from a

third party lawfully possessing the same and having no obligation to the Designating Party
hereunder.
18.

Final Disposition.
a.

Upon the termination of this proceeding, this Protective Order shall

continue to be binding upon the parties hereto, and upon all Persons to whom Designated
Material has been disclosed or communicated, and this Court shall retain jurisdiction to enforce
this Protective Order.
b.

Subject to final order of the Court upon completion of any matters relating

to this case, within sixty (60) days after entry of any final and unappealable judgment in this
litigation, any and all Designated Material produced by the other party or by a third party, and all
copies thereof, shall be returned to the producing Person or destroyed; provided, however,
outside counsel for each party shall be permitted to retain and archive Designated Material that is
contained in correspondence, documents filed with the Court, written discovery responses, work

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product, expert work product, and transcripts, together with all exhibits thereto. If Designated
Material is destroyed pursuant to this Paragraph, the party destroying such Designated Material
shall certify in writing to the producing Person that it has taken all reasonably necessary
measures to destroy the materials.
19.

No Contract. This proposed Order is for the Court’s consideration and approval

as an Order. It shall not be construed to create a contract between the parties or between the
parties and their respective counsel.

Dated: May 13, 2014

Respectfully Submitted,

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/s/ Larry D. Simpson
Larry D. Simpson (FL Bar No. 176070)
[e-mail]
James P. Judkins (FL Bar No. 174168)
[e-mail]
Judkins, Simpson, High & Schulte
Post Office Box 10368
Tallahassee, FL 32302; Fax [phone]
Phone: [phone]; ax: 850-561-1471

/s/ James C. Bradley
James C. Bradley (SC Bar No. 16611)
[e-mail]
Michael J. Brickman (SC Bar No. 000874)
[e-mail]
Nina H. Fields (SC Bar No. 68294)
[e-mail]
Richardson, Patrick, Westbrook &
Brickman, LLC
1017 Chuck Dawley Blvd. (29464)
Post Office Box 1007
Mount Pleasant, SC 29465
Phone: [phone]; Fax [phone]

Louis Touton (CA Bar No. 102380)
[e-mail]
Jones Day
555 South Flower Street, 50th Floor
Los Angeles, CA 90071
Phone: [phone]; Fax [phone]

J. Wiley Horton (FL Bar No. 59242)
[e-mail]
Pennington, Moore, Wilkinson, Bell &
Dunbar, P.A.
215 S. Monroe Street, 2nd Floor
Tallahassee, FL 32301
Phone: [phone]; Fax: [phone]

E. Kendrick Smith (GA Bar No. 656725)
[e-mail]
Jones Day
1420 Peachtree Street, N.E., Suite 800
Atlanta, GA 30309-3053
Phone: [phone]; Fax [phone]

Guy M. Burns (FL Bar No. 0160901)
[e-mail]
Johnson, Pope, Bokor, Ruppel & Burns, LLP
Post Office Box 1100
Phone: [phone]; Fax: [phone]
Virginia Langston Ponder (FL Bar No. 99947)
[e-mail]
Pennington Moore Wilkinson
215 S. Monroe St, Suite 200
Tallahassee, FL 32301
Phone: [phone]; Fax: [phone]
Attorneys for Plaintiff and Counterclaim
Defendant Global Communications, Inc.

/s/ Christopher JM Collings
Christopher JM Collings (FL Bar No. 184403)
[e-mail]
Morgan Lewis & Bockius LLP
200 S. Biscayne Blvd, Suite 5300
Wachovia Financial Center

Krista Sue Schwartz (IL Bar No. 6238053)
[e-mail]
Jones Day
77 W. Wacker, Suite 3500
Chicago, IL 60601-1692
Phone: [phone]; Fax: [phone]
Attorneys for the Counterclaimant and
Cross-Claim Defendant DIRECTV, LLC;
Counterclaimant The DIRECTV Group,
Inc.; Defendant and Counterclaimant Pace
Americas, LLC; and Defendants ASC
Signal Corp., CalAmp Corp., Humax Co.
Ltd, Humax USA Inc., Kuehne + Nagel Inc.,
LG Electronics, Inc., LG Electronics U.S.A.,
Inc.; Microelectronics Technology, Inc.,
MTI Network Inc., Philips Consumer
Electronics North America; Polecoz
Electronics Ltd.; Pro Brand International,
Inc., Technicolor USA, Inc. (formerly
Thomson, Inc.), Unitron NV, Wistron
NeWeb Corp., W-NeWeb Corporation,

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Miami, FL 33131-2339
Phone: [phone]; Fax: [phone]

Zinwell Corp., and ZCWC, Inc.

Attorneys for Defendant Funai Corporation

/s/ Vijay G. Brijbasi
Vijay Gibran Brijbasi (FL Bar No. 15037)
[e-mail]
Roetzel & Andress LPA
3550 E. Las Olas Blvd, Suite 1150
Fort Lauderdale, FL 33301
Phone: [phone]; Fax: [phone]

/s/ J. Rick Tache
Joseph Rick Tache (195100)
[e-mail]
Greenberg Traurig LLP
3161 Michelson Dr., Suite 1000
Irvine, CA 92612
Phone: [phone]; Fax: [phone]
Jenny Soojin Kim (CA Bar No. 282562)
[e-mail]
Greenberg Traurig LLP
3161 Michelson Dr., Suite 1000
Irving, CA 92612
Phone: [phone]; Fax: [phone]

Robert Edward Pershes (FL Bar No. 301906)
[e-mail]
Roetzell & Andress LPA
350 E. Las Olas Blvd.
Suite 1150
Fort Lauderdale, FL 33301
Phone: [phone]; Fax: [phone]
Attorneys for Defendant ASC Signal
Corporation

Attorneys for Defendant Samsung
Electronics America Inc. and Samsung
Telecommunications America, LLC

ORDER
Pursuant to the Parties’ Stipulation, IT IS SO ORDERED on May 16, 2014.

s/Robert L. Hinkle
United States District Judge

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EXHIBIT A
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
TALLAHASSEE DIVISION
GLOBAL COMMUNICATIONS, INC.,
Plaintiff,
v.
DIRECTV Inc., THE DIRECTV
GROUP, INC., and JOHN DOE
MANUFACTURERS Nos. 1-10,
Defendant.
DIRECTV, LLC and THE DIRECTV
GROUP, INC.,
Counterclaimants,
v.
GLOBAL COMMUNICATIONS, INC.,
Counterclaim Defendant.

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Case No.: 4:12-cv-00651-RH-CAS

My name is _____________________________________________. My home address
is ______________________________________________________. I am employed as (state
position) _____________________________________ at (state name and address of employer),
______________________________________________________________________________
______________________________________________________________________________
_____________________________________________________________________________.
1.

I have read the Stipulation and Protective Order Regarding Confidential

Information, and a copy of it has been given to me. I understand the provisions of this Order,
and I agree to comply with and to be bound by its provisions.

2.

I further agree to submit to the jurisdiction of this Court for adjudication of any

dispute regarding my compliance with the terms of this Stipulation and Order.
I declare under penalty of perjury under the law of the United States of America that the
foregoing is true and correct.
Executed this _________ day of ______________________, 2013, at_____________.

ATI-2604801v1

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