Vulcan Golf, LLC v. Google Inc. et al

Filing 133

MOTION by Defendant Google Inc. for protective order (AGREED) (Cyrluk, Jonathan)

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Vulcan Golf, LLC v. Google Inc. et al Doc. 133 Case 1:07-cv-03371 Document 133 Filed 02/06/2008 Page 1 of 2 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VULCAN GOLF, LLC., Individually and on behalf of all Others Similarly Situated, Lead Plaintiff, v. GOOGLE INC., OVERSEE.NET, SEDO LLC, DOTSTER, INC., AKA REVENUEDIRECT.COM, INTERNET REIT, INC. d/b/a IREIT, INC., and JOHN DOES I-X, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 07 CV 3371 Honorable Blanche M. Manning Mag. Judge Geraldine Soat Brown AGREED MOTION FOR ENTRY OF PROTECTIVE ORDER Defendant Google, Inc. ("Google"), by and through its attorneys, respectfully moves this Court to enter the Stipulated Pre-Trial Protective Order ("Agreed Protective Order") tendered to the Court at the February 5, 2008 - status hearing, pursuant to Fed. R. Civ. P. 26(c) and L.R. 26.2. In support of this motion, Google states as follows: 1. The parties have stipulated to the terms of the Agreed Protective Order and jointly request the Court enter the Agreed Protective Order to protect certain trade secrets and other confidential information from the public domain. 2. The parties believe the Agreed Protective Order is in accordance with Seventh Circuit case law, the Local Rules of the Northern District of Illinois, and the Standing Order of this Court. 3. The parties submit that this motion is brought in good faith, is not meant to hamper the public's access to the Court system, and submit that the entry of the Agreed Protective order will serve the interests of justice. Case 1:07-cv-03371 Document 133 Filed 02/06/2008 Page 2 of 2 WHEREFORE, for the foregoing reasons, Defendant Google, Inc., respectfully requests that the Court enter the Agreed Protective Order, a copy of which was submitted to the Court at the February 5, 2008 - status hearing, and such other and further relief as the Court deems just and proper. Respectfully submitted, GOOGLE, INC. By: /s/ Jonathan M. Cyrluk One of Its Attorneys Michael H. Page Joseph Gratz Keker & Van Nest, LLP San Francisco, CA 94111 (415) 391-5400 Lead Counsel Admitted Pro Hac Vice Aaron D. Van Oort Faegre & Benson LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, MN 55402-3901 612-766-8138 Joseph J. Duffy Jonathan M. Cyrluk Mariah E.Moran STETLER & DUFFY, LTD. 11 South LaSalle Street, Suite 1200 Chicago, IL 60603 (312) 338-0200 2

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