American Airlines Inc v. Travelport Limited et al

Filing 130

STIPULATED PROTECTIVE ORDER: Unless this order includes a clause that explicitly states that a particular local civil rule is modified as applied to this case, nothing in this order shall be construed to modify the provisions, operation, or effect of any local civil rule of this court. [see Order for specifics] (Ordered by Judge Terry R Means on 8/15/2011) (klm)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
AMERICAN AIRLINES, INC.
VS.
TRAVELPORT LIMITED, et al.

§
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§
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CIVIL ACTION NO. 4:11-CV-244-Y

STIPULATED PROTECTIVE ORDER
The Court enters this Stipulated Protective Order (“Protective Order”) pursuant to
Federal Rule of Civil Procedure 26. The parties stipulate as follows:
1.

Certain documents and information have been and may be sought, produced, or

exhibited by and between the parties to the above-styled proceeding (“Proceeding”) that relate
to the parties’ trade secrets, confidential information, and other kinds of commercially-sensitive
information that the party making the production deems confidential; and
2.

To preserve the confidentiality of certain documents and information, a

protective order should be entered by the Court; and
3.

The confidentiality designation of any materials cannot be used in evidence or

as proof of anything.
Pursuant to the parties’ stipulations and Rule 26(c), the following is hereby ORDERED:
1.

This Protective Order shall govern all documents, the information contained

therein, and all other information produced or disclosed during the Proceeding whether
revealed in a document, deposition, other testimony, discovery response or otherwise, by any
party in this Proceeding (“Supplying Party”) to any other party (“Receiving Party”), when the
same is designated in accordance with the procedures set forth herein. This Protective Order is
binding upon the parties to the Proceeding, including their respective corporate parents,

subsidiaries, and affiliates, as well as their respective attorneys, agents, representatives,
consulting and testifying experts, officers and employees, and others as set forth in this
Protective Order.
2.

A subpoenaed third party who so elects in a writing served on all parties may

avail itself of, and agree to be bound by, the terms and conditions of this Protective Order and
thereby become a Supplying Party for purposes of this Protective Order. The parties, in
conducting discovery from third parties, shall attach to such discovery requests a copy of this
Protective Order so as to apprise such third parties of their rights herein. A third party that
elects to become a Supplying Party for purposes of this Protective Order shall have the same
rights and obligations as any other Supplying Party to designate any “Confidential” or “Outside
Attorneys’ Eyes Only” material it produces consistent with the provisions in this Protective
Order.
3.

Any Supplying Party shall have the right to identify and designate as

“Confidential” or “Outside Attorneys’ Eyes Only” any document or other materials it produces
or provides (whether pursuant to court order, subpoena, or by agreement), or any testimony
given in this Proceeding, which is believed in good faith by that supplying party to constitute,
reflect, or disclose its confidential, proprietary, or trade-secret information, as those terms are
understood under applicable state and federal law (“Designated Material”).
4.

Designated Material as used herein includes, without limitation, documents,

information contained in documents, information revealed during a deposition or other
testimony, information revealed in an interrogatory answer, or information otherwise revealed
during the Proceeding.

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5.

“Inside Counselors” as used herein refers to no more than two in-house

attorneys for each party who are primarily responsible for managing the litigation in this
Proceeding. Inside Counselors shall agree not to participate in negotiations of commercial
agreements between the parties on behalf of their respective clients during the pendency of this
litigation (including appeals) and for two (2) years thereafter.

The designated Inside

Counselors for each party are as follows:
(a)

For American Airlines, Inc: Bruce Wark and Donald Broadfield Jr.

(b)

For Travelport Limited and Travelport, LP, d/b/a Travelport: Richard
Hastings and Shaun Redgrave.

(c)

For Sabre Inc., Sabre Holdings Corp., and Sabre Travel International
Limited d/b/a Sabre Travel Network: Sonia Ferguson and David
Schwarte.

(d)

For Orbitz Worldwide, LLC, d/b/a Orbitz: Craig Sonnenschein and
Suzanne Browne.

Any Party may change the designation of its Inside Counselors upon written notice to
all other parties if the previously-designated Inside Counselor is no longer employed by the
Party or with the Court’s permission for good cause shown.
6.

Specific documents and interrogatory answers produced by a Supplying Party

shall, if appropriate, be designated pursuant to this Protective Order by marking the first page
of the document and each subsequent page thereof containing Confidential Information with
the legend:
“CONFIDENTIAL (No. 4:11-CV-244-Y)”
or
“OUTSIDE ATTORNEYS’ EYES ONLY (No. 4:11-CV-244-Y)”
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Alternatively, a Supplying Party may designate information as Confidential Information
by indicating in a writing served to all counsel of record the page range or bates-stamp range or
otherwise identifying the materials in a manner that is readily ascertainable.
7.

Information disclosed at a deposition taken in connection with this Proceeding

may be designated pursuant to this order as follows:
(a)

(b)

8.

A Supplying Party (or its counsel) may designate testimony, given by
any fact or expert witness as “Confidential” or “Outside Attorneys’ Eyes
Only” on the record during the taking of the deposition, in which case
the stenographic employee or court reporter recording or transcribing
such testimony shall be directed either to bind any transcript page(s)
containing Confidential Information separately and apart from any
transcript page(s) containing no such Confidential Information or to
ensure that the transcript identifies the page-range of the Confidential
Information; or
A Supplying Party (or its counsel) may notify all other parties to this
Protective Order in writing, within twenty-one (21) calendar days of
receipt of the transcript of a deposition of any witness of specific pages
and lines of the transcript which are designated as “Confidential” or
“Outside Attorneys’ Eyes Only,” whereupon each party shall treat the
designated excerpts in accordance with this Order. To facilitate the
designation of Confidential Information, all transcripts of depositions
shall be treated in their entirety as “Outside Attorneys’ Eyes Only” for a
period of twenty-one (21) calendar days following delivery by court
reporter of certified transcripts to all parties.

Confidential Information shall be disclosed by the Receiving Party only to the

following persons:
(a)

Outside counsel for the Plaintiff and Defendants whose lawyers have
filed appearances in this Proceeding, including their attorneys,
paralegals, investigators, stenographic and clerical employees; the
personnel supplied by any independent contractor (including litigation
support service personnel or attorneys and paralegals assisting in
document review) with whom such attorneys work in connection with
the Proceeding;

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(b)
(c)

Any outside consultant or expert who is retained in connection with this
Proceeding and to whom it is necessary to disclose Confidential
Information for the purpose of assisting in, or consulting with respect to,
the preparation of this Proceeding and who signs the document attached
hereto as Exhibit A, agreeing to be bound by the terms of this Protective
Order;

(d)

The Court and any members of its staff to whom it is necessary to
disclose Confidential Information for the purpose of assisting the Court
in this Proceeding;

(e)

Witnesses in this action to whom disclosure is reasonably necessary for
this litigation and who have signed the document attached as Exhibit A,
agreeing to be bound by the terms of this Protective Order;

(f)

Stenographic employees and court reporters recording or transcribing
testimony relating to the Proceeding;

(g)

The author, addressees, or recipients of the document, or the original
source of the Confidential Information, provided such authors,
addressees, or recipients sign the document attached hereto as Exhibit A,
agreeing to be bound by the terms of this Protective Order; and

(h)

9.

Inside Counselors, as that term is defined in Paragraph 5 of this Order;

Any other person to whom the Supplying Party agrees in writing or on
the record, provided that such person signs the document attached hereto
as Exhibit A, agreeing to be bound by the terms of this Protective Order.

Persons having knowledge of Confidential Information by virtue of the

disclosure of such information by a Supplying Party in discovery in this Proceeding shall use
that Protected Information only in connection with the prosecution or appeal of the Proceeding,
and shall neither use such Confidential Information for any other purpose nor disclose such
Confidential Information to any person who is not identified in paragraph 7 of this Protective
Order. The parties agree that Confidential Information can be used in any other proceeding
between the parties and in which a protective order agreed to by the parties is in place, with the

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written permission of the Supplying Party, which permission shall not be unreasonably
withheld. In the event that permission to use Confidential Information is not given by the
Supplying Party, the Receiving Party may petition the Court for relief.
10.

Nothing shall prevent disclosure of Confidential Information beyond the terms

of this Protective Order (a) if the Supplying Party (or its counsel) consents in writing to such
disclosure, (b) if a Supplying Party knowingly discloses its own Confidential Information in a
public or non-redacted pleading filed in the Court’s public record or in a publication
disseminated to the general public, or (c) the Court, after reasonable written notice to counsel
for all the parties, and after an opportunity to be heard by counsel for the Supplying Party,
orders such disclosure.
11.

The Parties expect the Proceeding will require the production (in hard copy

and/or electronic form) of certain categories of extremely sensitive confidential trade secret or
proprietary information that the Supplying Party reasonably believes may substantially
compromise and/or jeopardize the Supplying Party’s business interests, even if limited to the
persons listed in Paragraph 8 above (“Outside Attorneys’ Eyes Only Information”). Outside
Attorneys’ Eyes Only Information may include without limitation: (a) the negotiation, terms,
and course of performance of legal agreements; (b) pricing information; (c) financial
information, including sales and profits, that is not otherwise public information; (d) the
content of and strategy related to current and past business dealings, including confidential
communications with customers (e) intellectual property; (f) trade secrets, know-how, or
proprietary data; (g) information relating to unreleased products and services, or products and
services that may still be in development”).

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12.

All the provisions set forth above applicable to Confidential Information shall

apply equally to Outside Attorneys’ Eyes Only Information, except that disclosure of Outside
Attorneys’ Eyes Only Information by the receiving party shall be limited to the following
persons:
(a)

(b)

Any outside consultant or expert who retained in connection with this
Proceeding and to whom it is necessary to disclose Outside Attorneys’
Eyes Only Information for the purpose of assisting in, or consulting with
respect to, the prosecution or defense of this Proceeding, and who signs
the document attached hereto as Exhibit A, agreeing to be bound to the
terms of this Protective Order;

(c)

The author, addressees, or recipients of the document, or the original
source of the Outside Attorneys’ Eyes Only Information who signs the
document attached hereto as Exhibit A, agreeing to be bound to the
terms of this Protective Order;

(d)

The Court and any members of its staff to whom it is necessary to
disclose Outside Attorneys’ Eyes Only Information for the purpose of
assisting the Court with respect to the Proceeding;

(e)

13.

Outside counsel for the Plaintiff and the Defendants whose lawyers have
filed appearances in this Proceeding (specifically excluding in-house
counsel), including their attorneys, paralegals, investigators,
stenographic and clerical employees; the personnel supplied by any
independent contractor (including litigation support service personnel or
attorneys and paralegals assisting in document review) with whom such
attorneys work in connection with the Proceeding;

Stenographic employees and court reporters recording or transcribing
testimony relating to the Proceeding.

There may be certain limited pieces of information—documents, interrogatory

answers and/or deposition testimony—that are marked “Outside Attorneys’ Eyes Only” by a
Supplying Party and that the Receiving Party believes it must show to its clients to adequately
prepare its case for trial. If a Receiving Party believes that information falls within this

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category, it shall identify the information to the Supplying Party with specificity and disclose
the in-house personnel to whom it wishes to disclose the information. The Supplying Party
will provide a good faith response concerning its willingness (or lack of willingness) to permit
the information to be shown to the disclosed in-house personnel within five (5) business days.
If the Supplying Party is unwilling to permit the Receiving Party to show the information to the
Receiving Party’s clients, the Receiving Party may then raise the matter with the Court.
14.

Persons having knowledge of Outside Attorneys’ Eyes Only Information by

virtue of the disclosure of such information by a Supplying Party in discovery in this
Proceeding shall use that Outside Attorneys’ Eyes Only Information only in connection with
the prosecution or appeal of the Proceeding, and shall neither use such Outside Attorneys’ Eyes
Only Information for any other purpose nor disclose such Outside Attorneys’ Eyes Only
Information to any person who is not identified in paragraph 12 of this Protective Order. The
parties agree that Outside Attorneys’ Eyes Only Information can be used in any other
proceeding in which a protective order agreed to by the parties is in place, with the written
permission of the Supplying Party, which permission shall not be unreasonably withheld. In
the event that permission to use Confidential Information is not given by the Supplying Party,
the Receiving Party may petition the Court for relief.
15.

Prior to the disclosure of any Designated Material to any person identified in

paragraphs 8 (b), (c), (e), (g) or (h) or 12 (b) or (c), such person shall be provided with a copy
of this Protective Order, which he or she shall read and upon reading shall sign a Certification,
in the form attached hereto as Exhibit A, acknowledging that he or she has read this Protective
Order and shall abide by its terms. Counsel for the party seeking to disclose Designated

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Material to any person identified in paragraphs 8(b) or (g) or 12(c) shall then serve all other
parties in this Proceeding with a copy of the executed Certification. Counsel for the party
seeking to disclose Designated Material to any person identified in paragraphs 8(c), (e), or (h)
or 12(b) shall then serve all other parties in this Proceeding with a copy of the executed
Certification and shall refrain from disclosing Designated Material for one business day, during
which time the other parties may raise objections. If such an objection is raised, counsel for the
party seeking to disclose Designated Material shall not do so until the matter is resolved by the
Court. Failure to raise an objection within 24 hours does not waive the right of a party to lodge
an objection at a later date and seek relief from the Court. Persons who come into contact with
Designated Material for clerical, administrative, paralegal, stenographic or court reporting
purposes are not required to execute acknowledgements.
16.

All deponents, their counsel, and all witnesses to depositions, shall be advised of

this Protective Order and its terms on the record at the beginning of all depositions in the
Proceeding (such advising not to count against the time limits for such depositions).

A

deponent shall not be permitted to retain copies of Designated Material unless the deponent is
otherwise entitled to receive and retain such copies under the terms of this Protective Order. A
deponent’s counsel shall not be permitted to retain any copies of Designated Material unless
such counsel represents one of the parties in this Proceeding or is otherwise entitled to receive
and retain such copies under the terms of this Protective Order. Nothing in this paragraph shall
prevent a deponent or deponent’s counsel from having reasonable access to the deponent’s
deposition, including exhibits thereto, for purposes of executing the deposition, preparing to
testify further in this Proceeding, or for other purposes agreed to by all the parties.

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17.

Any party (“Objecting Party”) may challenge the propriety of the designation

(or re-designation) of specific material as “Confidential” or “Outside Attorneys’ Eyes Only” by
serving a written objection that identifies the particular material being challenged (by Bates
number or other reasonable description or identification), and provides the basis for the
challenge. The Supplying Party or its counsel shall thereafter respond to the objection in
writing within five (5) business days of its receipt of such written objection by either (i)
agreeing to remove the designation, or (ii) stating the reasons why the designation was made.
If the Objecting Party and the Supplying Party are subsequently unable to agree upon the terms
and conditions of disclosure for the material(s) at issue, the Objecting Party may file a motion
with the Court in order to resolve the disputed designation. Pending the resolution of the
disputed designation, the material(s) at issue shall continue to be treated in accordance with the
Supplying Party’s designation of the material unless and until differing treatment is directed
pursuant to order of the Court.
18.

Nothing in this Protective Order shall restrict any party’s outside counsel from

rendering advice to its clients with respect to this Proceeding and, in the course thereof, relying
upon Confidential Information or Outside Attorneys’ Eyes Only Information; provided,
however, that in rendering such advice, outside counsel shall not disclose any other party’s
Confidential Information or Outside Attorneys’ Eyes Only Information other than in a manner
provided for in this Protective Order.
19.

Inadvertent production of any document or information without an appropriate

designation of confidentiality will not be deemed to waive a later claim as to its confidential
nature or stop the Supplying Party from designating said document or information at a later

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date by complying with the provisions above. Disclosure of said document or information by
any party prior to such subsequent designation shall not be deemed a violation of this
Protective Order; provided, however, that any party that disclosed the redesignated material
shall make a good-faith effort promptly to procure all copies of such redesignated material
from any persons known to have possession of any such redesignated material who are no
longer entitled to receipt under paragraphs 8 and 12 above.
20.

If a Supplying Party inadvertently discloses information that is subject to the

attorney-client privilege or the work-product doctrine, such disclosure shall not constitute a
waiver of, or an estoppel as to any claim of, such privilege or protection if—upon discovery of
such disclosure—the Supplying Party promptly informs the Receiving Party that the
information is subject to a claim of privilege, immunity, or protection. If the Supplying Party
notifies the Receiving Party that the information is subject to a claim of privilege, immunity or
protection, then counsel for the Receiving Party shall comply with Fed. R. Civ. P. 26(b)(5)(B).
21.

Except as agreed in writing by counsel for the Supplying Party, to the extent that

any Designated Material is, in whole or in part, contained in, incorporated in, disclosed in or
attached to any pleading, motion, memorandum, appendix or other judicial filing, counsel shall
file the submission under seal, and the submission shall be designated and treated as a “Sealed
Document,” in accordance with the Court’s order of June 9, 2011. (Doc. 69.) All Sealed
Documents, filed under seal pursuant to this Protective Order, shall be electronically filed
under seal and shall remain sealed until sixty days after the final disposition of this case in
accordance with local rule 79.4. (See Doc. 69.) Such Sealed Documents shall be released by
the Clerk of the Court only upon further order of the Court, with appropriate notice to all and

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an opportunity to be heard by all parties to the Proceeding.
22.

If Designated Material is used during depositions, it shall not lose its

confidential status through such use, and counsel shall exercise their best efforts and take all
steps reasonably required to protect its confidentiality during such use.
23.

Nothing in this Protective Order shall be deemed a waiver of any objection or

privilege a party may claim to the production of any documents, nor shall anything in this
Protective Order prevent the parties from seeking an order from the Court, upon proper notice
to all parties, further restricting the disclosure of documents or information designated pursuant
to this order.
24.

Upon the conclusion of the Proceeding, including any appeal related thereto, at

the written request and option of the Supplying Party, within thirty (30) calendar days of such
request any person or entity having custody or control of Designated Material or of recordings,
notes, memoranda, summaries or other written materials, and all copies thereof, relating to or
containing Designated Material shall certify that all such Designated Material and any copies
thereof, any and all records, notes, memoranda, summaries or other written material regarding
the Designated Material have been destroyed or returned to the Supplying Party. Any request
for return or destruction shall be made within ninety (90) days of the conclusion of this
Proceeding, including all appeals. If a Supplying Party does not request the return of its
Designated Material within the specified time period, parties in possession of said material
shall destroy the material, and a Clerk of Court in possession of said material may destroy the
material consistent with the terms of this Protective Order.
25.

To the extent Designated Material is in the possession of outside counsel to a

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Party at the conclusion of the Proceeding, outside counsel shall make reasonable efforts to
destroy all Designated Material, including: (a) destroying all hard copies of documents
designated as “Confidential” or “Outside Attorneys’ Eyes Only,”; (b) eliminating any
electronic databases that have been created to assist in the prosecution or defense of the
Proceeding that hold electronic copies of documents designated as “Confidential” or “Outside
Attorneys’ Eyes Only”; and (c) informing all personnel who have worked on the Proceeding
that documents designated as “Confidential” or “Outside Attorneys’ Eyes Only” must be
automatically destroyed pursuant to outside counsel’s typical document retention policy.
26.

If Designated Material is disclosed to any person other than in the manner

authorized by this Protective Order, the party responsible for the disclosure shall within two (2)
business days after learning of such disclosure, inform the Supplying Party of all pertinent facts
relating to such disclosure and shall make every effort to prevent disclosure by each
unauthorized person who received such information.
27.

If a Receiving Party is served with a discovery request, subpoena or an order

issued in other litigation or proceedings that would compel disclosure of any information or
items designated in this action as “Confidential” or “Outside Attorneys’ Eyes Only,” the
Receiving Party must:
a.

Notify in writing, as soon as reasonably practicable, the Supplying Party.
Such notification shall include a copy of the subpoena or court order;

b.

Notify in writing, as soon as reasonably practicable, the party who
caused the subpoena or order to issue in the other litigation that some or
all of the material covered by the subpoena or order is subject to this
Protective Order. Such notification shall include a copy of this
Protective Order; and

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If the Supplying Party timely seeks a protective order, the Receiving Party served with
the subpoena or court order shall not produce any information designated in this action as
“Confidential” or “Outside Attorneys’ Eyes Only” before a determination by the court from
which the subpoena or order issued, unless the Receiving party has obtained the Supplying
Party’s permission.

The Supplying Party shall bear the burden and expense of seeking

protection in that court of its Designated Material – and nothing in these provisions should be
construed as authorizing or encouraging a Receiving Party in this action to disobey a lawful
directive from another court.
28.

Subject to the applicable rules of evidence, Designated Material may be offered

in evidence at trial or any court hearing, provided that the party offering Designated Material
(“the Offering Party”) provides reasonable notice to the Supplying Party. Any party or third
party may move the Court for an order that evidence, including documents and testimony, be
received in camera or under other conditions to prevent unnecessary disclosure of Confidential
or Outside Attorneys’ Eyes Only Information. Prior to trial or to a hearing in open court, the
Court may determine what protection, if any, will be afforded to such information at the trial or
hearing. In the event the Offering Party cannot practicably provide notice to the Supplying
Party, the Offering Party shall, prior to offering in evidence any Designated Material, move the
Court for an order that evidence, including documents and testimony, be received in camera or
under other conditions to prevent unnecessary disclosure of Confidential or Outside Attorneys’
Eyes Only Information.
29.

The terms of this Protective Order shall be binding upon all current and future

parties to this Proceeding and their counsel. If any new party and its counsel should enter this

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litigation, within five (5) days of the entry of appearance by a new party and its counsel to this
Proceeding, Plaintiff shall serve the new party and its counsel with a copy of this Protective
Order, and the new party shall be required to sign it or lodge any objections to this Protective
Order within three (3) business days after receiving service of the Protective Order.
30.

Nothing contained in this Protective Order shall preclude any party from using

its own Confidential Information or Outside Attorneys’ Eyes Only Information in any manner
it sees fit, without prior consent of any party or the Court. If a Supplying Party knowingly
discloses its own Confidential Information or Outside Attorneys’ Eyes Only Information in a
public or non-redacted pleading filed in the Court’s public record or in a publication
disseminated to the general public, the Supplying Party shall be deemed thereby to have
consented to the removal of that designation with respect to the information disclosed.
31.

By written agreement of the parties or upon motion and order of the Court the

terms of this Protective Order may be amended, modified or vacated.
Unless this order includes a clause that explicitly states that a particular local civil
rule is modified as applied to this case, nothing in this order shall be construed to modify
the provisions, operation, or effect of any local civil rule of this court.
SIGNED August 15, 2011.

____________________________
TERRY R. MEANS
UNITED STATES DISTRICT JUDGE

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Dated: August 4, 2011
AGREED BY AND ENTRY REQUESTED:
/s Yolanda C. Garcia
R. Paul Yetter
State Bar No. 22154200
Anna Rotman
State Bar No. 24046761
YETTER COLEMAN LLP
909 Fannin, Suite 3600
Houston, Texas 77010
713.632.8000
713.632.8002 (fax)
Bill Bogle
State Bar No. 025661000
Roland K. Johnson
State Bar No. 00000084
HARRIS, FINLEY & BOGLE, P.C.
777 Main Street, Suite 3600
Fort Worth, Texas 76102
817.870.8700
817.332.6121 (fax)
Yolanda C. Garcia
State Bar No. 24012457
Michelle Hartmann
State Bar No. 24032401
WEIL, GOTSHAL & MANGES LLP
200 Crescent Court, Suite 300
Dallas, Texas 75201-6950
214.746.7700
214.746.7777 (fax)
Of Counsel:
DEWEY & LEBOEUF LLP
M.J. Moltenbrey
1101 New York Ave. NW
Washington, D.C. 20005
202.346.8738

AGREED BY AND ENTRY REQUESTED:
/s Walker C. Friedman
Walker C. Friedman
State Bar No. 07472500
[e-mail]
FRIEDMAN, SUDER & COOKE
604 E. 4th Street, Suite 200
Fort Worth, Texas 76102
817.334.0144
817.334.0401 (fax)
Michael L. Weiner
[e-mail]
Dechert LLP
1095 Avenue of the Americas
New York, New York 10036-6797
212.698.3608
212.698.3599 (Fax)
Mike Cowie
[e-mail]
Craig Falls
[e-mail]
Dechert LLP
1775 I Street, NW
Washington, D.C. 20006-2401
202.261.3300
202.261.3333 (Fax)
John T. Schriver
[e-mail]
Paul E. Chronis
[e-mail]
Duane Morris LLP
Suite 3700
190 South LaSalle Street
Chicago, Illinois 60603-3433
312.499.6700
312.499.6701 (Fax)

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202.346.8102 (fax)

Attorneys for Defendants Travelport Ltd.,
Travelport, L.P.,

WEIL, GOTSHAL & MANGES LLP
Richard A. Rothman
James W. Quinn
767 Fifth Avenue
New York, New York 10153
212.310.8426
212.310.8285 (fax)
Attorneys for Plaintiff American Airlines, Inc.

/s Christopher S.
Yates____________________
Christopher S. Yates
Email: [e-mail]
Daniel M. Wall
Email: [e-mail]
Brendan A. McShane
Email: [e-mail]
LATHAM & WATKINS LLP
505 Montgomery Street, Suite 2000
San Francisco, CA 94111-6538
Telephone: [phone]
Facsimile: [phone]
John J. Little
Email: [e-mail]
Stephen G. Gleboff
Texas State Bar No. 08024500
Email: [e-mail]
Megan K. Dredla
Email: [e-mail]
LITTLE PEDERSEN FANKHAUSER LLP
901 Main Street, Suite 4110
Dallas, TX 75202-3714
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Orbitz Worldwide,
LLC

/s Scott A. Fredricks
Scott A. Fredricks
Texas Bar No. 24012657
([e-mail])
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Ralph H. Duggins
Texas Bar No. 06183700
([e-mail])
Philip A. Vickers
Texas Bar No. 24051699
([e-mail])
CANTEY HANGER LLP
Cantey Hanger Plaza
600 West 6th Street, Suite 300
Fort Worth, TX 76102-3685
Phone: [phone]
Facsimile: [phone]
Donald E. Scott
Colorado Bar No. 21219, Illinois Bar No.
2531321
([e-mail])
Karma M. Giulianelli
Colorado Bar No. 30919, California Bar No.
184175
([e-mail])
Sean C. Grimsley
Colorado Bar No. 36422, California Bar No.
216741
([e-mail])
Sundeep K. (Rob) Addy
Colorado Bar No. 38754
([e-mail])
BARTLIT BECK HERMAN PALENCHAR &
SCOTT LLP
1899 Wynkoop Street, 8th Floor
Denver, Colorado 80202
Phone: [phone]
Facsimile: [phone]
Chris Lind
Illinois Bar No. 6225464, Colorado Bar No
27719
([e-mail])
Andrew K. Polovin
Illinois Bar No. 6275707
([e-mail])
Katherine M. Swift
Illinois Bar No. 6290878
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([e-mail])
BARTLIT BECK HERMAN PALENCHAR &
SCOTT LLP
54 West Hubbard Street, Suite 300
Chicago, IL 60610
Phone: [phone]
Facsimile: [phone]
George S. Cary
([e-mail])
Steven J. Kaiser
([e-mail])
CLEARY GOTTLIEB STEEN & HAMILTON LLP
2000 Pennsylvania Ave., N.W.
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]
Attorneys for Sabre Inc., Sabre Holdings
Corporation, and Sabre Travel Int’l Ltd.
d/b/a Sabre Travel Network

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Exhibit A
AMERICAN AIRLINES, INC.
VS.
TRAVELPORT LIMITED, et al.

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CIVIL ACTION NO. 4:11-CV-244-Y

I hereby certify (i) my understanding that “Designated Material” and/or “Confidential
Information” and/or “Outside Attorneys’ Eyes Only Information” are being provided to me
pursuant to the terms and restrictions of the Protective Order (“Order”) entered by the United
States District Court for the Northern District of Texas (“District Court”) in the above-captioned
action, and (ii) that I have read and understood the terms the Order.
I hereby agree to be fully bound by the Order and further agree to submit to the
jurisdiction of the District Court for purposes of enforcement of the Order. I certify that I will
not use any information disclosed to me under the terms of this Order other than for the purposes
described in the Order. I understand that violation of the Order may be punishable by contempt
of Court.
Dated:

Signature:

Printed Name and Title:

Business Address:

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