Certicom Corporation et al v. Sony Corporation et al

Filing 44

Joint MOTION to Amend/Correct 42 Protective Order (Exhibit A to Protective Order), MOTION for Protective Order by Sony Computer Entertainment Inc., Sony Computer Entertainment America Inc., Sony Pictures Entertainment Inc., Sony Electronics Inc., Sony DADC US Inc., Certicom Corporation, Certicom Patent Holding Corporation, Sony Corporation, Sony Corporation of America. (Attachments: # 1 Text of Proposed Order)(Wilcox, Melvin)

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Certicom Corporation and Certicom Patent Holding Corporation; Plaintiffs, v. Sony Corporation, Sony Corporation of America, Sony Computer Entertainment Inc., Sony Computer Entertainment America Inc., Sony Pictures Entertainment Inc., Sony Electronics Inc. and Sony DADC US Inc.; Defendants. Civil Action No. 2:07-CV-216-TJW JURY JOINT MOTION TO AMEND EXHIBIT A OF THE STIPULATED PROTECTIVE ORDER Plaintiffs Certicom Corporation and Certicom Patent Holding Corporation ("Certicom") and Defendants Sony Corporation ("SC"), Sony Corporation of America ("SCA"), Sony Computer Entertainment Inc. ("SCEI"), Sony Computer Entertainment America Inc. ("SCEA"), Sony Pictures Entertainment Inc. ("SPE"), Sony Electronics Inc. ("SEL") and Sony DADC US Inc. ("Sony DADC US") (collectively, "Sony"), by and through their respective undersigned counsel, respectfully move this Court to enter an order substituting the attached Exhibit A for the one attached to the Stipulated Protective Order signed by the Court on May 16, 2008 (D.I. 42). The attached Exhibit A is amended to conform to the designations of Confidential Information contained in the Stipulated Protective Order (D.I. 42). 1 Respectfully submitted this 5th day of June, 2008: By:/s/ Carl R. Roth by permission Melvin R. Wilcox, III By:/s/ Melvin R. Wilcox, III CARL R. ROTH MELVIN R. WILCOX, III Texas Bar No. 17312000 Texas Bar No. 21454800 THE ROTH LAW FIRM YARBROUGH & WILCOX PLLC 115 N. Wellington, Suite 200 100 E. Ferguson Street, Suite 1015 Marshall. TX 75670 Tyler, TX 75702 Tel: (903) 935-1665 (903) 595-1133 Tel: (903) 935-1665 (903) 595-0191(fax) cr@rothfirm.com mrw@yw-lawfirm.com Attorneys for Plaintiffs Attorneys for Defendants CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by certified mail, return receipt requested, on June 5, 2008. /s/ Melvin R. Wilcox, III MELVIN R. WILCOX, III 2 EXHIBIT A UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Certicom Corporation and Certicom Patent Holding Corporation; Plaintiffs, v. Sony Corporation, Sony Corporation of America, Sony Computer Entertainment Inc., Sony Computer Entertainment America Inc., Sony Pictures Entertainment Inc., Sony Electronics Inc. and Sony DADC US Inc.; Defendants. Civil Action No. 2:07-CV-216-TJW ALLEGIANCE TO PROTECTIVE ORDER STATE OF ______________________ ) ) SS: COUNTY OF ____________________ ) I, _____________________ having been retained by _____________________ in connection with the above-captioned lawsuit, hereby acknowledge that I am about to receive "Confidential," "Confidential Outside Counsel's Eyes Only," "Confidential Outside Counsel's Eye's Only Limited" and/or "Super Confidential Material" material as defined in the Protective Order agreed to by the parties and so ordered by the Court in this case. I certify my understanding that the material designated as "Confidential," "Confidential Outside Counsel's Eyes Only," "Confidential Outside Counsel's Eyes Only Limited" and/or A-1 "Super Confidential Material" is being provided to me pursuant to the terms and restrictions of the Protective Order, and that I have been given a copy of and have read and understood my obligations under that Protective Order. I hereby agree to be bound by the terms of the Protective Order. I clearly understand that the "Confidential," "Confidential Outside Counsel's Eyes Only," "Confidential Outside Counsel's Eyes Only Limited" and/or "Super Confidential Material" material and my copies or notes relating thereto may only be disclosed to or discussed with those persons permitted by the Protective Order to receive such material. I will return on request all materials designated as "Confidential," "Confidential Outside Counsel's Eyes Only," "Confidential Outside Counsel's Eyes Only Limited" and/or "Super Confidential Material," copies thereof, and notes that I have prepared relating thereto, to outside counsel for the party by whom or on whose behalf I am retained at the conclusion of my involvement. I hereby submit to the jurisdiction of this Court for the purpose of enforcement of the Protective Order and waive any and all objections to jurisdiction and venue. I make the above statements under penalty of perjury. _________________________________ Printed Name: _____________________ Company Name/Address/Phone: _________________________________ _________________________________ _________________________________ _________________________________ A-2 _________________________________ A-3

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