1 BENJAMIN W. CLEMENTS (SBN 299126) Email: bclements@troygould.com 2 CHINELO N. IKEM (SBN 343780) Email: cikem@troygould.com 3 TROYGOULD PC 1801 Century Park East, 16th Floor 4 Los Angeles, CA 90067-2367 Telephone: (310) 553-4441 5 Facsimile: (310) 201-4746 6 Attorneys for Defendants Kangnam1957, Inc.; La Park’s Milpitas, Inc.; Han 7 Paan, Inc.; Jiim, Inc.; Daeho Las Vegas, Inc.; and Daeho Hwang 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 SUN NONG DAN FOODS, INC., a Case No. 2:23-cv-09779-WLH-RAO California corporation, 13 STIPULATED PROTECTIVE ORDER Plaintiff, 14 Complaint Filed: November 17, 2023 v. Trial Date: June 23, 2025 15 KANGNAM1957, INC., a California 16 corporation; LA PARK’S MILPITAS, INC., a California corporation; HAN 17 PAAN, INC., a California corporation; JIIM, INC., a California corporation; 18 DAEHO LAS VEGAS, INC., a California corporation; DAEHO 19 HWANG, an individual; IL PARK, an individual; CHAN WON PARK, an 20 individual; DOES 1 through 10, inclusive, 21 Defendants. 22 23 24 25 26 27 28 1 This Stipulated Protective Order is entered into by and between Plaintiff Sun 2 Nong Dan Foods, Inc., Defendants Kangnam1957, Inc., La Park’s Milpitas, Inc., Han 3 Paan, Inc., Jiim, Inc., Daeho Las Vegas, Inc., and Daeho Hwang, and Defendants Il 4 Park and Chan Won Park (each individually a “party” and collectively the “parties”), 5 through their counsel of record, as follows: 6 1. A. PURPOSES AND LIMITATIONS 7 Discovery in this action is likely to involve production of confidential, 8 proprietary or private information for which special protection from public disclosure 9 and from use for any purpose other than prosecuting this litigation may be warranted. 10 Accordingly, the parties hereby stipulate to and petition the Court to enter the 11 following Stipulated Protective Order. The parties acknowledge that this Order does 12 not confer blanket protections on all disclosures or responses to discovery and that 13 the protection it affords from public disclosure and use extends only to the limited 14 information or items that are entitled to confidential treatment under the applicable 15 legal principles. 16 B. GOOD CAUSE STATEMENT 17 This action is likely to involve alleged trade secrets and other valuable 18 research, development, commercial, financial, technical and/or proprietary 19 information for which special protection from public disclosure and from use for any 20 purpose other than prosecution of this action is warranted. Such confidential and 21 proprietary materials and information consist of, among other things, confidential 22 business or financial information, information regarding confidential business 23 practices, or other confidential research, development, or commercial information 24 (including information that may implicate privacy rights of third parties), information 25 otherwise generally unavailable to the public, or which may be privileged or 26 otherwise protected from disclosure under state or federal statutes, court rules, case 27 decisions, or common law. Accordingly, to expedite the flow of information, 28 facilitate the prompt resolution of disputes over confidentiality of discovery 1 materials, adequately protect information the parties are entitled to keep confidential, 2 ensure that the parties are permitted reasonable necessary uses of such material in 3 preparation for and in the conduct of trial, address their handling at the end of the 4 litigation, and serve the ends of justice, a protective order for such information is 5 justified in this matter. It is the intent of the parties that information will not be 6 designated as confidential for tactical reasons and that nothing be so designated 7 without a good faith belief that it has been maintained in a confidential, non-public 8 manner, and there is good cause why it should not be part of the public record of this 9 case. 10 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 11 The parties further acknowledge, as set forth in Section 12.3, below, that this 12 Stipulated Protective Order does not entitle them to file confidential information 13 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 14 the standards that will be applied when a party seeks permission from the court to file 15 material under seal. 16 There is a strong presumption that the public has a right of access to judicial 17 proceedings and records in civil cases. In connection with non-dispositive motions, 18 good cause must be shown to support a filing under seal. See Kamakana v. City & 19 Cnty. of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006); Phillips v. Gen. Motors 20 Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002); Makar-Welbon v. Sony Elecs., Inc., 21 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good 22 cause showing). A specific showing of good cause or compelling reasons with 23 proper evidentiary support and legal justification must be made with respect to 24 Protected Material that a party seeks to file under seal. The parties’ mere designation 25 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 26 submission of competent evidence by declaration, establishing that the material 27 sought to be filed under seal qualifies as confidential, privileged, or otherwise 28 protectable—constitute good cause. 1 Further, if a party requests sealing related to a dispositive motion or trial, then 2 compelling reasons, not only good cause, for the sealing must be shown, and the 3 relief sought shall be narrowly tailored to serve the specific interest to be protected. 4 See Pintos v. Pac. Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir. 2010). For each 5 item or type of information, document, or thing sought to be filed or introduced 6 under seal in connection with a dispositive motion or trial, the party seeking 7 protection must articulate compelling reasons, supported by specific facts and legal 8 justification, for the requested sealing order. Again, competent evidence supporting 9 the application to file documents under seal must be provided by declaration. 10 Any document that is not confidential, privileged, or otherwise protectable in 11 its entirety will not be filed under seal if the confidential portions can be redacted. If 12 documents can be redacted, then a redacted version for public viewing, omitting only 13 the confidential, privileged, or otherwise protectable portions of the document, shall 14 be filed. Any application that seeks to file documents under seal in their entirety 15 should include an explanation of why redaction is not feasible. 16 17 2. DEFINITIONS 18 2.1 Action: The above-captioned action titled Sun Nong Dan Foods, Inc. v. 19 Kangnam1957, Inc., et al., Case No. 2:23-cv-9779-WLH-RAO. 20 2.2 Challenging Party: a Party or Non-Party that challenges the designation 21 of information or items under this Order. 22 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 23 how it is generated, stored or maintained) or tangible things that qualify for 24 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 25 Good Cause Statement. 26 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 27 Information or Items: extremely sensitive “CONFIDENTIAL” Information or Items, 28 1 the disclosure of which to another Party or Non-Party would create a substantial risk 2 of serious harm that could not be avoided by less restrictive means. 3 2.5 Counsel: Outside Counsel of Record and House Counsel (as well as 4 their support staff). 5 2.6 Designating Party: a Party or Non-Party that designates information or 6 items that it produces in disclosures or in responses to discovery as 7 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 8 ONLY.” 9 2.7 Disclosure or Discovery Material: all items or information, regardless of 10 the medium or manner in which it is generated, stored, or maintained (including, 11 among other things, testimony, transcripts, and tangible things), that are produced or 12 generated in disclosures or responses to discovery in this matter. 13 2.8 Expert: a person with specialized knowledge or experience in a matter 14 pertinent to the litigation who has been retained by a Party or its counsel to serve as 15 an expert witness or as a consultant in this Action. 16 2.9 House Counsel: attorneys who are employees of a party to this Action. 17 House Counsel does not include Outside Counsel of Record or any other outside 18 counsel. 19 2.10 Non-Party: any natural person, partnership, corporation, association or 20 other legal entity not named as a Party to this action. 21 2.11 Outside Counsel of Record: attorneys who are not employees of a party 22 to this Action but are retained to represent or advise a party to this Action and have 23 appeared in this Action on behalf of that party or are affiliated with a law firm that 24 has appeared on behalf of that party, and includes support staff. 25 2.12 Party: any party to this Action, including all of its officers, directors, 26 employees, consultants, retained experts, and Outside Counsel of Record (and their 27 support staffs). 28 1 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 2 Discovery Material in this Action. 3 2.14 Professional Vendors: persons or entities that provide litigation support 4 services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) 6 and their employees and subcontractors. 7 2.15 Protected Material: any Disclosure or Discovery Material that is 8 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 9 ATTORNEYS’ EYES ONLY.” 10 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 11 from a Producing Party. 12 13 3. SCOPE 14 The protections conferred by this Stipulation and Order cover not only 15 Protected Material (as defined above), but also (1) any information copied or 16 extracted from Protected Material; (2) all copies, excerpts, summaries, or 17 compilations of Protected Material; and (3) any testimony, conversations, or 18 presentations by Parties or their Counsel that might reveal Protected Material. 19 Any use of Protected Material at trial shall be governed by the orders of the 20 trial judge. This Order does not govern the use of Protected Material at trial. 21 22 4. DURATION 23 Once a case proceeds to trial, information that was designated as 24 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 25 as an exhibit at trial becomes public and will be presumptively available to all 26 members of the public, including the press, unless compelling reasons supported by 27 specific factual findings to proceed otherwise are made to the trial judge in advance 28 of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing “good cause” 1 showing for sealing documents produced in discovery from “compelling reasons” 2 standard when merits-related documents are part of court record). Accordingly, the 3 terms of this protective order do not extend beyond the commencement of the trial. 4 5 5. DESIGNATING PROTECTED MATERIAL 6 5.1 Exercise of Restraint and Care in Designating Material for Protection. 7 Each Party or Non-Party that designates information or items for protection under 8 this Order must take care to limit any such designation to specific material that 9 qualifies under the appropriate standards. The Designating Party must designate for 10 protection only those parts of material, documents, items or oral or written 11 communications that qualify so that other portions of the material, documents, items 12 or communications for which protection is not warranted are not swept unjustifiably 13 within the ambit of this Order. 14 Mass, indiscriminate or routinized designations are prohibited. Designations 15 that are shown to be clearly unjustified or that have been made for an improper 16 purpose (e.g., to unnecessarily encumber the case development process or to impose 17 unnecessary expenses and burdens on other parties) may expose the Designating 18 Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, that Designating Party must 21 promptly notify all other Parties that it is withdrawing the inapplicable designation. 22 5.2 Manner and Timing of Designations. Except as otherwise provided in 23 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 24 stipulated or ordered, Disclosure of Discovery Material that qualifies for protection 25 under this Order must be clearly so designated before the material is disclosed or 26 produced. 27 Designation in conformity with this Order requires: 28 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix at a minimum, the legend 4 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 5 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains 6 protected material. If only a portion of the material on a page qualifies for protection, 7 the Producing Party also must clearly identify the protected portion(s) (e.g., by 8 making appropriate markings in the margins). 9 A Party or Non-Party that makes original documents available for inspection 10 need not designate them for protection until after the inspecting Party has indicated 11 which documents it would like copied and produced. During the inspection and 12 before the designation, all of the material made available for inspection shall be 13 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 14 it wants copied and produced, the Producing Party must determine which documents, 15 or portions thereof, qualify for protection under this Order. Then, before producing 16 the specified documents, the Producing Party must affix the “CONFIDENTIAL” 17 legend to each page that contains Protected Material. If only a portion of the material 18 on a page qualifies for protection, the Producing Party also must clearly identify the 19 protected portion(s) (e.g., by making appropriate markings in the margins). 20 (b) for testimony given in depositions that the Designating Party identifies 21 the Disclosure or Discovery Material on the record, before the close of the deposition 22 all protected testimony. 23 (c) for information produced in some form other than documentary and for 24 any other tangible items, that the Producing Party affix in a prominent place on the 25 exterior of the container or containers in which the information is stored the legend 26 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 27 ONLY.” If only a portion or portions of the information warrants protection, the 28 Producing Party, to the extent practicable, shall identify the protected portion(s). 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive the 3 Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1. Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 13 resolution process under Local Rule 37-1 et seq. 14 6.3 The burden of persuasion in any such challenge proceeding shall be on 15 the Designating Party. Frivolous challenges, and those made for an improper purpose 16 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 17 expose the Challenging Party to sanctions. Unless the Designating Party has waived 18 or withdrawn the confidentiality designation, all parties shall continue to afford the 19 material in question the level of protection to which it is entitled under the Producing 20 Party’s designation until the Court rules on the challenge. 21 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this 25 Action only for prosecuting, defending or attempting to settle this Action. Such 26 Protected Material may be disclosed only to the categories of persons and under the 27 conditions described in this Order. When the Action has been terminated, a 28 1 Receiving Party must comply with the provisions of section 13 below (FINAL 2 DISPOSITION). 3 Protected Material must be stored and maintained by a Receiving Party at a 4 location and in a secure manner that ensures that access is limited to the persons 5 authorized under this Order. 6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 7 otherwise ordered by the court or permitted in writing by the Designating Party, a 8 Receiving Party may disclose any information or item designated 9 “CONFIDENTIAL” only to: 10 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 11 as employees of said Outside Counsel of Record to whom it is reasonably necessary 12 to disclose the information for this Action; 13 (b) the officers, directors, and employees (including House Counsel) of the 14 Receiving Party to whom disclosure is reasonably necessary for this Action; 15 (c) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (d) the court and its personnel; 19 (e) court reporters and their staff; 20 (f) professional jury or trial consultants, mock jurors, and Professional 21 Vendors to whom disclosure is reasonably necessary for this Action and who have 22 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 23 (g) the author or recipient of a document containing the information or a 24 custodian or other person who otherwise possessed or knew the information; 25 (h) during their depositions, witnesses, and attorneys for witnesses, in the 26 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 27 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will 28 not be permitted to keep any confidential information unless they sign the 1 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 2 agreed by the Designating Party or ordered by the court. Pages of transcribed 3 deposition testimony or exhibits to depositions that reveal Protected Material may be 4 separately bound by the court reporter and may not be disclosed to anyone except as 5 permitted under this Stipulated Protective Order; and 6 (i) any mediator or settlement officer and their supporting personnel, 7 mutually agreed upon by any of the parties engaged in settlement discussions. 8 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 9 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 10 writing by the Designating Party, a Receiving Party may disclose any information or 11 item designated “HIGHLY CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 13 as employees of said Outside Counsel of Record to whom it is reasonably necessary 14 to disclose the information for this Action; 15 (b) Experts (as defined in this Order) of the Receiving Party to whom 16 disclosure is reasonably necessary for this Action and who have signed the 17 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (c) the court and its personnel; 19 (d) private court reporters and their staff to whom disclosure is reasonably 20 necessary for this Action and who have signed the “Acknowledgment and 21 Agreement to Be Bound” (Exhibit A); 22 (e) professional jury or trial consultants, mock jurors, and Professional 23 Vendors to whom disclosure is reasonably necessary for this Action and who have 24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 25 (f) the author or recipient of a document containing the information or a 26 custodian or other person who otherwise possessed or knew the information; and 27 (g) any mediator or settlement officer, and their supporting personnel, 28 mutually agreed upon by any of the parties engaged in settlement discussions. 1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 2 OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY,” that Party must: 7 (a) promptly notify in writing the Designating Party. Such notification shall 8 include a copy of the subpoena or court order; 9 (b) promptly notify in writing the party who caused the subpoena or order 10 to issue in the other litigation that some or all of the material covered by the 11 subpoena or order is subject to this Protective Order. Such notification shall include a 12 copy of this Stipulated Protective Order; and 13 (c) cooperate with respect to all reasonable procedures sought to be pursued 14 by the Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with 16 the subpoena or court order shall not produce any information designated in this 17 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 18 EYES ONLY” before a determination by the court from which the subpoena or order 19 issued, unless the Party has obtained the Designating Party’s permission. The 20 Designating Party shall bear the burden and expense of seeking protection in that 21 court of its confidential material and nothing in these provisions should be construed 22 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 23 directive from another court. 24 25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 26 PRODUCED IN THIS LITIGATION 27 (a) The terms of this Order are applicable to information produced by a 28 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 1 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 2 Non-Parties in connection with this litigation is protected by the remedies and relief 3 provided by this Order. Nothing in these provisions should be construed as 4 prohibiting a Non-Party from seeking additional protections. 5 (b) In the event that a Party is required, by a valid discovery request, to 6 produce a Non-Party’s confidential information in its possession, and the Party is 7 subject to an agreement with the Non-Party not to produce the Non-Party’s 8 confidential information, then the Party shall: 9 (1) promptly notify in writing the Requesting Party and the Non- 10 Party that some or all of the information requested is subject to a confidentiality 11 agreement with a Non-Party; 12 (2) promptly provide the Non-Party with a copy of the Stipulated 13 Protective Order in this Action, the relevant discovery request(s), and a reasonably 14 specific description of the information requested; and 15 (3) make the information requested available for inspection by the 16 Non-Party, if requested. 17 (c) If the Non-Party fails to seek a protective order from this court within 18 14 days of receiving the notice and accompanying information, the Receiving Party 19 may produce the Non-Party’s confidential information responsive to the discovery 20 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 21 not produce any information in its possession or control that is subject to the 22 confidentiality agreement with the Non-Party before a determination by the court. 23 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 24 of seeking protection in this court of its Protected Material. 25 26 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 28 Protected Material to any person or in any circumstance not authorized under this 1 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 2 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 3 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 4 persons to whom unauthorized disclosures were made of all the terms of this Order, 5 and (d) request such person or persons to execute the “Acknowledgment and 6 Agreement to Be Bound” that is attached hereto as Exhibit A. 7 8 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 9 PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that certain 11 inadvertently produced material is subject to a claim of privilege or other protection, 12 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 13 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 14 may be established in an e-discovery order that provides for production without prior 15 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 16 parties reach an agreement on the effect of disclosure of a communication or 17 information covered by the attorney-client privilege or work product protection, the 18 parties may incorporate their agreement in the stipulated protective order submitted 19 to the court. 20 21 12. MISCELLANEOUS 22 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 23 person to seek its modification by the Court in the future. 24 12.2 Right to Assert Other Objections. By stipulating to the entry of this 25 Protective Order, no Party waives any right it otherwise would have to object to 26 disclosing or producing any information or item on any ground not addressed in this 27 Stipulated Protective Order. Similarly, no Party waives any right to object on any 28 ground to use in evidence of any of the material covered by this Protective Order. 1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Local Civil Rule 79-5. Protected Material may 3 only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material. If a Party’s request to file Protected Material under seal 5 is denied by the court, then the Receiving Party may file the information in the public 6 record unless otherwise instructed by the court. 7 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 2.1, within 10 60 days of a written request by the Designating Party, each Receiving Party must 11 return all Protected Material to the Producing Party or destroy such material. As used 12 in this subdivision, “all Protected Material” includes all copies, abstracts, 13 compilations, summaries, and any other format reproducing or capturing any of the 14 Protected Material. Whether the Protected Material is returned or destroyed, the 15 Receiving Party must submit a written certification to the Producing Party (and, if 16 not the same person or entity, to the Designating Party) by the 60-day deadline that 17 (1) identifies (by category, where appropriate) all the Protected Material that was 18 returned or destroyed and (2) affirms that the Receiving Party has not retained any 19 copies, abstracts, compilations, summaries or any other format reproducing or 20 capturing any of the Protected Material. Notwithstanding this provision, Counsel are 21 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, 22 and hearing transcripts, legal memoranda, correspondence, deposition and trial 23 exhibits, expert reports, attorney work product, and consultant and expert work 24 product, even if such materials contain Protected Material. Any such archival copies 25 that contain or constitute Protected Material remain subject to this Protective Order 26 as set forth in Section 4 (DURATION). 27 /// 28 /// 1 14. VIOLATION 2 Any violation of this Order may be punished by appropriate measures 3 including, without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 6 Dated: September 9, 2024 LUCEM, PC

7 By: /s/ Heedong Chae 8 Heedong Chae 9 Attorneys for Plaintiff Sun Nong Dan Foods, Inc. 10

11 Dated: September 9, 2024 TROYGOULD PC 12

13 By: /s/ Benjamin W. Clements Benjamin W. Clements 14 Attorneys for Defendants 15 Kangnam1957, Inc.; La Park’s Milpitas, Inc.; Han Paan, Inc.; Jjim, Inc.; Daeho 16 Las Vegas Inc.; and Daeho Hwang 17 18 Dated: September 9, 2024 JEON & PARK, LLP

19 By: /s/ Terry S. Park 20 Terry S. Park 21 Attorneys for Defendants Il Park and Chan Won Park 22

28 1 ATTESTATION 2 Pursuant to Local Rule 5-4.3.4(a)(2)(i), the undersigned hereby attests that the 3 | other signatories listed, and on whose behalf the filing is submitted, concur in the 4 | filing’s content and have authorized the filing. 5 6 || Dated: September 9, 2024 By: /s/ Benjamin W. Clements 7 Benjamin W. Clements 8 9 10 'l /EOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 12 13 DATED: 9/11/2024 14 □ is] Reyella a, QC 16 HON. ROZELLA A. OLIVER M7 United States Magistrate Judge 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 _________________ [print or type full address], declare under penalty of perjury 6 that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California 8 on [date] in the case of Sun Nong Dan Foods, Inc. v. Kangnam1957, Inc., et al., Case 9 No. 2:23-cv-9779-WLH-RAO. I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any information 13 or item that is subject to this Stipulated Protective Order to any person or entity 14 except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court 16 for the Central District of California for enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of 18 this action. I hereby appoint __________________________ [print or type full 19 name] of _______________________________________ [print or type full address 20 and telephone number] as my California agent for service of process in connection 21 with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 Date: ______________________________________ 24 City and State where sworn and signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________