1 |} MCCORMICK, BARSTOW, SHEPPARD,

WAYTE & CARRUTH LLP

2 Shane G. Smith, # 272630 3 shane.smith@ mccormickbarstow.com 7647 N. Fresno St. 4 || Fresno, California 93729-8912 Telephone: (559) 433-1300 5 || Facsimile: (559) 433-2300 6 Attorneys for Defendant, 7 || WestCoast Products & Design LLC 9 UNITED STATES DISTRICT COURT

10 EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION 11 REV ROBOTICS, LLC, Case No. 1:25-cv-00275-JLT-BAM Plaintiff, {Prepesed} STIPULATED PROTECTIVE 13 ORDER Vv. 14 WESTCOAST PRODUCTS & DESIGN LLC, Hon. Jennifer L. Thurston 15 Hon. Barbara A. McAuliffe Defendant. 16 17 18 19 20 21 22 23 24 25 26 27 28

BARSTOW,

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1 Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, Plaintiff REV Robotics LLC 2 and Defendant WestCoast Products & Design LLC, through counsel undersigned, jointly submit 3 this Stipulated Protective Order to govern the handling of information and materials produced in the 4 course of discovery or filed with the Court in advance of trial in this action. 5 GOOD CAUSE STATEMENT PURSUANT TO L.R. 141.1(c) 6 Disclosure and discovery activity in this action are likely to involve (and have involved) 7 production of confidential, proprietary, or private information for which special protection from 8 public disclosure and from use for any purpose other than prosecuting this litigation may be 9 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following 10 Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket 11 protections on all disclosures or responses to discovery, and that the protection it affords from public 12 disclosure and use extends only to the limited information or items that are entitled to confidential 13 treatment under applicable legal principles. It is the intent of the parties and the Court that 14 information will not be designated as confidential for tactical reasons in this case, and that nothing 15 will be so designated without a good faith belief that there is good cause as to why information 16 should not be part of the public record. 17 Statement Under L.R. 141.1(c)(1): Examples of confidential information that the parties 18 may seek to protect from unrestricted or unprotected disclosure include: 19 a) Information that is the subject of a non-disclosure or confidentiality agreement or 20 obligation; 21 b) Agreements with third-parties; 22 c) Information related to budgets, sales, profits, costs, margins, product pricing, or other 23 internal financial/accounting information, including non-public information related to 24 financial condition or performance and income or other non-public tax information; 25 d) Information showing the price or other information related to the terms of sale or 26 purchase of products and materials relevant to this case; 27 e) Information related to internal operations, including personnel information; 1 marketing development, including plans, strategies, forecasts and competition; 2 g) Customer information maintained by either Party including contact information and 3 history and terms of past purchases; 4 h) Manufacturing and shipment details for the product offerings of either Party; 5 i) Internal business strategies of either Party; and 6 j) Any other information or records from either Party that would be competitively 7 harmful to the producing party if publicly disclosed. 8 Statement Under L.R. 141.1(c)(2): Generally speaking, information and documents shall 9 only be designated under this protective order because the Designating Party believes the 10 information or documents are proprietary, confidential, and/or trade secret information that the 11 Designating Party would not release publicly. Unrestricted or unprotected disclosure of such 12 confidential, technical, commercial, or personal information may result in prejudice or harm to the 13 Producing Party by revealing the Producing Party’s competitive confidential information. 14 Accordingly, the parties respectfully submit that there is good cause for the entry of this Protective 15 Order. 16 Statement Under L.R. 141.1(c)(3): The parties submit that protecting the confidential 17 nature of information in this way will be most efficient for the parties and the Court. That is because 18 the liability issues in this case will involve the mutual exchange of documents, deposition testimony, 19 and other information that a Party may consider to be its proprietary and confidential information. 20 Remedies issues in this case are likely to involve the mutual exchange of business-sensitive 21 financial, pricing, and related information. The parties have met and conferred on this issue and 22 agree that any private agreement between the parties to safeguard this information will only need to 23 be replicated through orders of this Court at the time of filing dispositive or non-dispositive motions. 24 PROTECTIVE ORDER 25 1. DEFINITIONS. 26 (a) The term “Challenging Party” shall mean a Party or Non-Party that challenges the 27 designation of information or items under this Order. 1 stored, or maintained) or tangible things that the Designating Party in good faith reasonably believes 2 will disclose confidential, proprietary and nonpublic financial, commercial, personal, or business 3 information eligible for protection under the Federal Rule of Civil Procedure 26(c). “Confidential” 4 information shall not include information that either: (a) is in the public domain at the time of 5 disclosure; (b) lawfully becomes part of the public domain through no fault of the recipient, or (c) 6 was lawfully in the possession of the Receiving Party at the time of disclosure. 7 (c) The term “Outside Counsel” shall mean the attorneys of record for any party in this 8 action, their associates and their staff. If any party seeks to add counsel of record or substitute 9 counsel of record, then no “Confidential” Documents and information shall be discussed to such 10 additional or substitute counsel until they have agreed to this stipulation by executing the attached 11 Exhibit A. 12 (d) The term “House Counsel” shall mean attorneys who are employees of a party to this 13 action. House Counsel does not include Outside Counsel of Record or any other outside counsel. 14 (e) The term “Designating Party” shall mean a Party or Non-Party that designates 15 information or items that it produces in disclosures or in responses to discovery as “Confidential” 16 or “Outside Counsels’ Eyes Only.” 17 (f) The term “Documents” shall have the same meaning as the term “documents and 18 electronically stored information” in Federal Rule of Civil Procedure 34. 19 (g) The term “Expert” shall mean a person with specialized knowledge or experience in 20 a matter pertinent to this litigation who has been retained by a Party to serve as an expert witness or 21 as a consultant in this litigation and who, at the time of retention, is not anticipated to become an 22 officer, director, or employee of a Party. Nothing in this Protective Order purports to alter in any 23 way the requirements for offering testimony under Fed. R. Evid. 703, or to define the term “expert” 24 for purposes other than those addressed in this Protective Order. 25 (h) The term “Non-Party” shall mean any natural person, partnership, corporation, 26 association, or other legal entity not named as a Party to this action. 27 (i) The term “Party” shall mean any party to this action, including all of its officers, 1 (j) The term “Producing Party” shall mean a Party or Non-Party that produces 2 information or other discovery material in this action. 3 (k) The term “Professional Vendors” shall mean persons or entities that provide 4 litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or 5 demonstrations, and organizing, storing, or retrieving data in any form or medium) and their 6 employees and subcontractors. 7 (l) The term “Protected Material” shall mean any information or other discovery 8 material that is designated as “Confidential” or “Outside Counsels’ Eyes Only.” 9 (m) The term “Receiving Party” shall mean a Party that receives information or other 10 discovery material from a Producing Party. 11 (n) The term “Outside Counsels’ Eyes Only” shall mean and include those Confidential 12 documents, answers to interrogatories, responses to requests for admission, deposition transcripts, 13 affidavits, expert reports, legal briefs or memoranda, and portions of such materials, and information 14 derived therefrom, that the Designating Party in good faith believes is highly confidential such that, 15 if disclosed to the Receiving Party, might cause competitive harm to the Designating Party. 16 Information and material that may be subject to this protection include, but is not limited to, financial 17 statements; proprietary technical and/or research and development data; financial, marketing and 18 other sales data (such as actual or prospective customer lists, actual or prospective vendor lists, 19 purchase prices, and sales and pricing information); trade secrets under applicable law; highly 20 confidential information belonging to third parties, and/or information having strategic commercial 21 value to the Designating Party’s trade or business. Additionally, relevant documents related to an 22 individual’s employment or employment related disclosures may be made pursuant to an “Outside 23 Counsels’ Eyes Only” designation to protect the privacy of the individuals. 24 2. SCOPE 25 The protections conferred by this Order cover not only Protected Material, but also (1) any 26 information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or 27 compilations of Protected Material; and (3) any testimony, conversations, or presentations by a Party 1 3. DESIGNATING PROTECTED MATERIAL. 2 (a) Exercise of Restraint and Care in Designating Material for Protection. Each Party or 3 Non-Party that designates information or items for protection under this Order must take care to 4 limit any such designations. The Designating Party must designate for protection only those parts 5 of material, documents, items, or oral or written communications that qualify under the appropriate 6 standards so that other portions of the material, documents, items, or communications for which 7 protection is not warranted are not swept unjustifiably within the ambit of this Order. Mass, 8 indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly 9 unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or 10 retard the case development process or to impose unnecessary expenses and burdens on other 11 parties) expose the Designating Party to sanctions. If it comes to a Designating Party’s attention 12 that information or items that it designated for protection do not qualify for protection, that 13 Designating Party must promptly notify all other Parties that it is withdrawing the mistaken 14 designation. 15 (b) Manner and Timing of Designations. Except as otherwise provided in this Order or 16 as otherwise stipulated or ordered, discovery material and information that qualify for protection 17 under this Order must be clearly so designated before the material is disclosed or produced. The 18 Designating Party must use reasonable efforts to ensure that the applicable legend appears on each 19 page of each file produced, as permitted by the particular format of a given Document. 20 (c) Materials Subject to Designation. Each Party to this litigation may designate any 21 Document, thing, interrogatory answer, admission, deposition testimony, and portions of such 22 materials, or other information that it has provided or which a third-party has provided as 23 “Confidential” or “Outside Counsels’ Eyes Only” in accordance with this Order. The party 24 designating such information as “Confidential” or “Outside Counsels’ Eyes Only” shall be known 25 as the “Designating Party” and the designation shall be set out thereon. In designating Documents 26 or information as “Confidential” or “Outside Counsels’ Eyes Only,” the Designating Party’s counsel 27 shall make a good faith determination, before applying the designation, that the information warrants 1 (d) Designating Originals or Tangible Items. In the event the Producing Party elects to 2 produce original Documents and things for inspection rather than produce copies of Documents, the 3 Producing Party shall identify those original Documents or tangible items which the Producing Party 4 is designating as “Confidential” or “Outside Counsels’ Eyes Only” at the initial inspection. 5 Thereafter, upon selection of specified Documents for copying by the inspecting party, the 6 Producing Party shall mark the copies of such Documents as may contain protected subject matter 7 with the appropriate confidentiality marking at the time the copies are produced to the inspecting 8 party. Said marking shall not delay the production of the copies. Information obtained by counsel 9 from an initial review of Documents or tangible items, whether in written form or not, shall be 10 maintained as “Confidential” or “Outside Counsels’ Eyes Only” pursuant to the Producing Party’s 11 designations at the time of initial inspection, unless such information is produced without a 12 designation of confidentiality, or as otherwise designated in writing by the Producing Party. 13 (e) Inadvertent Failures to Designate. If timely corrected after its discovery, an 14 inadvertent failure to designate qualified information or items does not, standing alone, waive the 15 Designating Party’s right to secure protection under this Order for such material. Upon timely 16 correction of a designation, the Receiving Party must make reasonable efforts to assure that the 17 material is treated in accordance with the provisions of this Order. 18 (f) Production by Non-Parties. Documents produced by Non-Parties without a 19 confidentiality designation shall be provisionally designated as “Confidential” for a period of 20 fourteen (14) days from the date of production, during which period any Party may designate any 21 portion of the production as “Confidential” for the remainder of the litigation unless and until the 22 designation is successfully challenged pursuant to Section 4 below. 23 4. CHALLENGING CONFIDENTIALITY DESIGNATIONS. 24 (a) Timing of Challenges. Any Party or Non-Party may challenge a designation of 25 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality 26 designation is necessary to avoid a foreseeable, substantial unfairness, unnecessary economic 27 burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to 1 original designation is disclosed. 2 (b) Meet and Confer. The Challenging Party shall initiate the dispute resolution process 3 by providing written notice of each designation it is challenging and describing the basis for each 4 challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must 5 recite that the challenge to confidentiality is being made in accordance with this specific paragraph 6 of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must 7 begin the process by conferring directly (in voice-to-voice dialogue; other forms of communication 8 are not sufficient) within fourteen (14) days of the date of service of notice. In conferring, the 9 Challenging Party must explain the basis for its belief that the confidentiality designation was not 10 proper and must give the Designating Party an opportunity to review the designated material, to 11 reconsider the circumstances, and, if no change in designation is offered, to explain the basis for the 12 chosen designation. A Challenging Party may proceed to the next stage of the challenge process 13 only if it has engaged in this meet and confer process first or establishes that the Designating Party 14 is unwilling to participate in the meet and confer process in a timely manner. 15 (c) Judicial Intervention. If the Parties cannot resolve a challenge without court 16 intervention, the Designating Party shall file and serve a motion to retain confidentiality (in 17 compliance with Local Rules 140 and 141, if applicable) within 21 days of the initial notice of 18 challenge or 14 days of the parties agreeing that the meet and confer process will not resolve their 19 dispute, whichever is later. Each such motion must be accompanied by a competent declaration 20 affirming that the movant has complied with the meet and confer requirements imposed in the 21 preceding paragraph. Failure by the Designating Party to make such a motion, including the 22 required declaration within 21 days (or 14 days, if applicable), shall automatically waive the 23 confidentiality designation for each challenged designation. 24 The burden of persuasion in any such challenge proceeding shall be on the Designating 25 Party. Frivolous challenges or oppositions to challenges, and those made for an improper purpose 26 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose the 27 Challenging Party to sanctions. All parties shall continue to afford the material in question the level 1 the challenge. 2 5. ACCESS TO “CONFIDENTIAL” MATERIALS. 3 All information designated as “Confidential” shall not be disclosed to anyone other than the 4 Parties, Counsel, the Court and its personnel, court reporters and/or videographers in the course of 5 covering depositions, as well as any experts, consultants, and Professional Vendors retained by any 6 Party or its Counsel. All persons other than Counsel, the Court, and the Court’s personnel in the 7 instant action to whom “Confidential” information is disclosed shall read this Protective Order in 8 advance of such disclosure and agree in writing to be bound by its terms by executing the attached 9 Exhibit A. 10 “Confidential” information subject to this Protective Order shall be used by the Party(ies) to 11 whom it is produced solely and exclusively for purposes of the above-captioned litigation unless 12 and until such designation is removed either by agreement of the Parties or by order of the Court. 13 6. ACCESS TO “OUTSIDE COUNSELS’ EYES ONLY” MATERIALS 14 Unless otherwise ordered by the court or permitted in writing by the Designating Party, a 15 Receiving Party may disclose any information or item designated “Outside Counsels’ Eyes Only” 16 only to: 17 (a) The Receiving Party’s Outside Counsel, as well as employees of said Outside 18 Counsel to whom it is reasonably necessary to disclose the information for this litigation and who 19 signed the attached Exhibit A; 20 (b) Experts of the Receiving Party to whom disclosure is reasonably necessary for this 21 litigation and who have signed the attached Exhibit A, provided, however, that the Experts who may 22 view “Outside Counsels’ Eyes Only” materials cannot, within the past ten (10) years, be or have 23 been employees or independent contractors of any Party, nor of any Parties’ subsidiaries or affiliated 24 companies. 25 (c) The Court and its personnel; and 26 (d) Court reporters and their staff, professional jury or trial consultants, mock jurors, and 27 Professional Vendors to whom disclosure is reasonably necessary for this litigation and who have 1 7. USE OF “CONFIDENTIAL” OR “OUTSIDE COUNSELS’ EYES ONLY” MATERIALS 2 Absent written consent from the Producing Party, any person affiliated with either Party and 3 permitted to receive a Party’s “Confidential” or “Outside Counsels’ Eyes Only” materials, who 4 obtains, receives, has access to, or otherwise learns, in whole or in part, said Party’s “Confidential” 5 or “Outside Counsels’ Eyes Only” materials under this Order, shall not prepare, prosecute, 6 supervise, or assist in the preparation or prosecution of any patent application pertaining to (a) 7 splines, (b) any products or services accused by REV Robotics LLC in this action, or (c) the patents 8 asserted in this action or and any patent or application claiming priority to or otherwise related to 9 the patents asserted in this action (collectively, the “Field of Invention”) during the pendency of this 10 action and for two years after its conclusion, including any appeals. For the purposes of this 11 paragraph, “prosecution” includes any activity related to (i) the preparation or prosecution (for any 12 person or entity) of patent applications, or (ii) participating, drafting, amending, advising, or 13 otherwise affecting the scope or maintenance of patent claims. This provision shall not preclude 14 any person (including counsel or experts) who obtains, receives, or otherwise learns, in whole or in 15 party of the other Party’s “Confidential” or “Outside Counsels’ Eyes Only” materials under this 16 Order from participating in or representing it in reexamination proceedings, Post-Grant Review 17 proceedings, Inter Partes Review proceedings, or Covered Business Method Review proceedings 18 involving the patent-in-suit provided that they do not advise on, consult on, prepare, draft, or edit 19 any amendment to specifications or claims based on those proceedings. 20 Absent written consent from the Designating Party, any individual affiliated with REV 21 Robotics LLC who obtains, receives, has access to, or otherwise learns, in whole or in party, any 22 other Party’s “Confidential” or “Outside Counsels’ Eyes Only” material under this Order shall not 23 be involved in any activity related to: (i) the acquisition of patents or patent applications relating to 24 the Fields of Invention or (ii) the advising or counseling of clients regarding the same. This 25 Acquisition Bar shall begin when such “Confidential” or “Outside Counsels’ Eyes Only” materials 26 are first received by the affected individual and shall end two (2) years after the conclusion of this 27 action, including any appeals. 1 8. EXPERTS & CONSULTANTS. 2 (a) Persons Covered By This Provision. The procedure specified under Paragraph 6(b) 3 shall apply to Experts expressly retained by Counsel to assist in the preparation of this litigation for 4 trial, whether or not the Expert is expected to testify at trial or not, as well as any personnel who 5 support such Expert’s work under the Expert’s direction and supervision, and who are necessary for 6 the completion of that work (“Support Personnel”). Disclosures to any such Support Personnel are 7 to be limited to only those disclosures necessary to assist the Expert. 8 (b) Procedure for Designating Experts & Consultants Under the Protective Order. As a 9 condition precedent to disclosure of any “Confidential” or “Outside Counsels’ Eyes Only” materials 10 to an individual described in Paragraph 8(a) above, Counsel for the Receiving Party shall require 11 the Expert and his/her Support Personnel (if any) to execute the form of Exhibit A attached hereto. 12 Such executed Exhibit A shall be maintained by Counsel for the Receiving Party for the term of this 13 Stipulated Protective Order. Counsel for the Receiving Party shall serve the executed Exhibit A 14 upon the Producing Party along with a current curriculum vitae of the current consultant or expert 15 at least ten (10) days before access to the Protected Material is to be given to that expert or consultant 16 in order to allow the Producing Party an opportunity to object to and notify the Receiving Party in 17 writing that the Producing Party objects to the disclosure of “Confidential” or “Outside Counsels’ 18 Eyes Only” information to the consultant or expert. The Parties agree to promptly meet and confer 19 in good faith to resolve any such objection. If the Parties are unable to resolve any objection, the 20 objecting Party may file a motion with the Court within fourteen (14) days of the notice, or within 21 such other time as the Parties may agree, seeking a protective order with respect to the proposed 22 disclosure. The objecting Party shall have the burden of proving the need for the protective order. 23 No disclosure shall occur until all such objections are resolve by agreement or Court order. 24 9. STORAGE OF PROTECTED INFORMATION BY RECEIVING PARTY. 25 The recipient of any “Confidential” or “Outside Counsels’ Eyes Only” materials provided 26 under this Protective Order (including copies or excerpts made thereof) shall maintain such 27 information in a secure and safe area, and shall exercise reasonable and proper care with respect to 1 10. TREATMENT OF PROTECTED MATERIAL AT DEPOSITIONS IN THIS 2 LITIGATION. 3 (a) Deposition of the Authors and Recipients of Protected Material. With respect to 4 Documents designated as “Confidential” or “Outside Counsels’ Eyes Only,” any person indicated 5 on the face of the Document to be its originator, author, or recipient may be shown the Documents. 6 Additionally, any Document designated as “Confidential” or “Outside Counsels’ Eyes Only” may 7 be shown to any employee of the Designating Party and/or the Party or Non-Party that produced in 8 this litigation the Document so designated during the deposition of that employee if it is reasonably 9 probable that the employee would have access to or knowledge of the information contained in that 10 Document. 11 (b) Exclusion of Certain Persons From Protected Deposition Testimony. Any Party shall 12 have the right to exclude from attendance at a deposition, during such time as the “Confidential” or 13 “Outside Counsels’ Eyes Only” Documents or information are to be disclosed, every individual not 14 entitled under the Protective Order to receipt of the information, excluding the deponent and the 15 court reporter, interpreter, translator, and/or videographer. However, if a document designated 16 “Confidential” or “Outside Counsels’ Eyes Only” is produced for the first time during the course of 17 such deposition, the non-designating Party shall be entitled to stay the deposition with respect to the 18 subject Document. 19 (c) Procedure for Designating Transcript Sections as Protected Material. Whenever a 20 deposition taken on behalf of any Party involves a disclosure of “Confidential” or “Outside 21 Counsels’ Eyes Only” Documents or information of any Party or Non-Party, said deposition or 22 portions thereof shall be designated as containing “Confidential” or “Outside Counsels’ Eyes Only” 23 information subject to the provisions of this Protective Order at the time the deposition is taken 24 whenever possible; however, any Party shall have until thirty (30) days after receipt of the deposition 25 transcript within which to designate, in writing, those portions of the transcript it wishes to remain 26 designated as “Confidential” or “Outside Counsels’ Eyes Only” and the right to make such 27 designation shall be waived unless made within the thirty (30) day period. During such thirty (30) 1 Counsels’ Eyes Only” to preserve the right of any Party to make a designation of “Confidential” or 2 “Outside Counsels’ Eyes Only” during that thirty (30) day period. 3 11. PROTECTED MATERIAL SUBPOENAED, ORDERED TO BE PRODUCED IN OTHER 4 LITIGATION. 5 If a Party is served with a subpoena, or a court order issues in another litigation, that compels 6 disclosure of any information or items designated in this action as “Confidential” or “Outside 7 Counsels’ Eyes Only” that Party must: 8 (a) Promptly notify the Designating Party in writing. Such notification shall include a 9 copy of the subpoena or court order; 10 (b) Promptly notify, in writing, the party who caused the subpoena or order to issue in 11 the other litigation that some or all of the material covered by the subpoena or order is subject to 12 this Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and 13 (c) Cooperate with respect to all reasonable procedures sought to be pursued by the 14 Designating Party whose Protected Material may be affected. 15 If the Designating Party timely seeks a protective order, the Party served with the subpoena 16 or court order shall not produce any information designated in this action as “Confidential” or 17 “Outside Counsels’ Eyes Only” before a determination by the court from which the subpoena or 18 order issued, unless the Party has obtained the Designating Party’s permission. The Designating 19 Party shall bear the burden and expense of seeking protection in that court of its confidential material 20 ― and nothing in these provisions should be construed as authorizing or encouraging a Receiving 21 Party in this action to disobey a lawful directive from another court. 22 12. PROTECTED MATERIAL OF A NON-PARTY SOUGHT TO BE PRODUCED IN THIS 23 LITIGATION. 24 (a) Applicability. The terms of this Order are applicable to information produced by a 25 Non-Party in this action and designated as “Confidential” or “Outside Counsels’ Eyes Only.” Such 26 information produced by Non-Parties in connection with this litigation is protected by the remedies 27 and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a 1 (b) Notice Procedure. In the event that a Party is required, by a valid discovery request, 2 to produce a Non-Party’s confidential information in its possession, and the Party is subject to an 3 agreement with the Non-Party not to produce the Non-Party’s confidential information, then the 4 Party shall: 5 (i) Promptly notify, in writing, the Requesting Party and the Non-Party that 6 some or all of the information requested is subject to a confidentiality agreement with a Non-Party; 7 (ii) Promptly provide the Non-Party with a copy of the Stipulated Protective 8 Order in this litigation, the relevant discovery request(s), and a reasonably specific description of 9 the information requested; and 10 (iii) Make the information requested available for inspection by the Non-Party. 11 (c) Disclosure and Remedy. If the Non-Party fails to object or seek a protective order 12 from this Court within fourteen (14) days of receiving the above notice and accompanying 13 information, the Receiving Party may produce the Non-Party’s confidential information responsive 14 to the discovery request. If the Non-Party timely seeks a protective order, the Receiving Party shall 15 not produce any information in its possession or control that is subject to the confidentiality 16 agreement with the Non-Party before a determination by the Court. Absent a court order to the 17 contrary, the Non-Party shall bear the burden and expense of seeking protection in this Court of its 18 Protected Material. 19 13. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL. 20 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 21 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, 22 the Receiving Party must immediately (1) notify in writing the Designating Party of the 23 unauthorized disclosures, (2) use its best efforts to retrieve all unauthorized copies of the Protected 24 Material, (3) inform the person or persons to whom unauthorized disclosures were made of all the 25 terms of this Order, and (4) request such person or persons to execute the “Acknowledgment and 26 Agreement to Be Bound” that is attached hereto as Exhibit A. 27 14 INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED 1 When a Producing Party gives notice to Receiving Parties that certain inadvertently 2 produced material is subject to a claim of privilege or other protection, the obligations of the 3 Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision 4 is not intended to modify whatever procedure may be established in an e-discovery order that 5 provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) 6 and (e), insofar as the parties reach an agreement on the effect of disclosure of a communication or 7 information covered by the attorney-client privilege or work product protection, the parties may 8 incorporate their agreement in the stipulated protective order submitted to the court. 9 15 FINAL DISPOSITION. 10 (a) Upon Termination of this Action. Within forty-five (45) days after a final disposition 11 of the action, which shall include entry of final judgment and the exhaustion of all rights of appeal, 12 or a dismissal of the action, a Receiving Party shall either return to the Producing Party or destroy 13 all Documents and things or transcripts of depositions, together with all copies thereof, which have 14 been designated “Confidential” or “Outside Counsels’ Eyes Only.” Notwithstanding this provision, 15 Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 16 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, 17 attorney work product, and consultant and expert work product, even if such materials contain 18 Protected Material. Any such archival copies that contain or constitute Protected Material remain 19 subject to this Protective Order. 20 (b) Continuing Obligations. Even after final disposition of this litigation, the 21 confidentiality obligations imposed by this Order shall remain in effect until a Designating Party 22 agrees in writing or a court order otherwise directs, except that the continuing nature of the 23 obligations in this provision shall not apply to the Court or its personnel. 24 16 LIMITATIONS. 25 (a) Attorneys’ Right to Counsel Clients. Nothing in this Protective Order shall bar or 26 otherwise restrict any attorney herein from rendering legal advice to the attorney’s Party-client with 27 respect to this action, and in the course thereof, relying upon an examination of “Confidential” or 1 advice and in otherwise communicating with the Party-client, the attorney shall not disclose any 2 “Confidential” or “Outside Counsels’ Eyes Only” Documents or information to anyone not 3 authorized to receive such Documents, things, materials, or information pursuant to the terms of this 4 Protective Order. 5 (b) Filing Protected Materials. Any Documents produced in discovery, answers to 6 interrogatories, deposition transcripts, or other Documents that are filed with the Court for any 7 purpose and that incorporate information that is designated “Confidential” or “Outside Counsels’ 8 Eyes Only” shall be filed in compliance with Local Rule 141. 9 (c) Reservation of Rights. Nothing in this Protective Order, nor the taking of any action 10 in accordance with the provisions of this Protective Order, nor the failure to object thereto, shall be 11 construed as a waiver or admission of any claim or defense of this action. Moreover, the failure to 12 designate information in accordance with this Order and the failure to object to a designation at a 13 given time shall not preclude the filing of a motion at a later date seeking to impose such designation 14 or challenging the propriety thereof. The entry of this Order shall not be construed as a waiver of 15 any right to object to the furnishing of information in response to discovery or to object to a 16 requested inspection of Documents or things, and, except as expressly provided, shall not relieve 17 any Party of the obligation of producing information in the course of discovery. This Order shall 18 not in any way limit what the Producing Party may do with its own Documents or information. 19 (d) Meet and Confer In Advance of Trial. Subject to Paragraph 16(b) and the Federal 20 Rules of Evidence, Documents, material, and information designated “Confidential” or “Outside 21 Counsels’ Eyes Only” may be offered in evidence at any pre-trial hearing in the instant action upon 22 three (3) day’s written notice of the intention to do so or, if that is not possible, such shorter notice 23 as the circumstances permit. In the instant action, any Party may move the Court orally or in writing 24 for an order that the evidence be received in camera at a hearing or under other conditions to prevent 25 unnecessary disclosure. The Party seeking to use Documents, material, and information designated 26 “Confidential” or “Outside Counsels’ Eyes Only” must request that the portion of the proceeding 27 where use is made be conducted so as to exclude persons not qualified to receive such Documents, 1 The parties shall meet and confer concerning the use and protection of Documents, material, 2 and information designated “Confidential” or “Outside Counsels’ Eyes Only” in open court at any 3 pre-trial hearing or trial. 4 Prior to the pretrial conference, the parties shall meet and confer concerning appropriate 5 methods for dealing with Documents, material, and information designated “Confidential” at trial. 6 17 MISCELLANEOUS. 7 (a) Right to Seek Modification. The Parties may, by written stipulation, provide for 8 exceptions to this Protective Order, and any Party may seek an order of this Court modifying or 9 interpreting this Protective Order. No stipulation amending this Protective Order will have the force 10 or effect of a Court order absent the Court’s written approval of it. 11 (b) Right to Further Relief. Nothing in the foregoing provisions of this Protective Order 12 shall be deemed to preclude any Party from seeking and obtaining, on an appropriate showing, 13 additional protection with respect to the confidentiality or relief from this Protective Order regarding 14 matter designated as containing “Confidential” or “Outside Counsels’ Eyes Only.” 15 (c) Right to Assert Other Objections. By stipulating to entry of this Protective Order, 16 no Party waives any right it otherwise would have to object to disclosing or producing any 17 information on any ground not addressed in this Stipulated Protective Order. Similarly, no Party 18 waives any right to object on any ground to use in evidence of any of the material covered by this 19 Protective Order. 20 IT IS SO ORDERED.

21 Dated: ______________, 2025 By: 22

HON. BARBARA A. MCAULIFFE

23 UNITED STATES MAGISTRATE JUDGE

24 25 26 27 1 Respectfully submitted, 2 Dated: August 18, 2025 Carstens, Allen & Gourley, LLP 3

4 By: /s/ Theodore G. Baroody 5 Theodore G. Baroody Matthew Conner Hutchisson 6 Attorneys for Plaintiff REV Robotics lLC 7 8 9 Dated: August 18, 2025 McCORMICK, BARSTOW, SHEPPARD,

WAYTE & CARRUTH LLP

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11 12 By: /s/ Shane G. Smith Shane G. Smith 13 Shaun W. Hasssett Attorneys for Defendant WestCoast Products & 14 Design LLC 15 -oOo- 16

17 SIGNATURE ATTESTATION 18 I hereby attest that concurrence has been obtained from counsel for Theodore G. Baroody, 19 counsel for REV Robotics LLC, as indicated by a “conformed” signature (/s/) within this e-filed 20 document. 21 /s/ Shane G. Smith Shane G. Smith 22

23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 I, __________________________________ [type or print full name] of 4 ____________________________________________________________ [print or type full 5 address], hereby declare under penalty of perjury that I have read and am fully familiar with the 6 terms of the Protective Order entered in REV Robotics LLC v. WestCoast Products & Design, LLC, 7 Case No. 1:25-cv-00275-JLT-BAM in the United States District Court for the Eastern District of 8 California, and hereby agree to comply with and be bound by the terms and conditions of said Order 9 unless and until modified by further Order of the Court. 10 I acknowledge that I am about to receive Confidential Documents and/or information in said 11 action, and hereby certify my understanding that such information is being provided to me pursuant 12 to the terms and restrictions of the Protective Order. I understand that such information, and any 13 copies I make of any material containing “Confidential” information, or any notes or other records 14 that may be made regarding any such information, shall not be disclosed to others, except other 15 persons that are identified in or have agreed to comply with and be bound by the terms of the 16 Protective Order. I hereby consent to the jurisdiction of said Court for purposes of enforcing this 17 Order, even if such enforcement proceedings occur after termination of this action. 18 I hereby appoint ____________________________________ [print or type full name] of 19 _______________________________________________________________________________ 20 _______________________________________________________________________________ 21 [print or type full address, telephone number, and email address] as my California agent for service 22 of process in connection with this action or any proceedings related to enforcement of this Protective 23 Order. 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed Name: _______________________________ 27 Signature: __________________________________ 1 PROOF OF SERVICE REV Robotics LLC v. WestCoast Products & Design LLC 2 U.S. District Court Case No. 1:25-cv-00275-JLT-BAM 3

STATE OF CALIFORNIA, COUNTY OF FRESNO

4 At the time of service, I was over 18 years of age and not a party to this action. I am 5 employed in the County of Fresno, State of California. My business address is 7647 North Fresno Street, Fresno, CA 93720. 6 On August 18, 2025, I served true copies of the following document(s) described as 7 [Proposed] STIPULATED PROTECTIVE ORDER on the interested parties in this action as follows: 8 9 Matthew Conner Hutchisson Theodore G. Baroody , PHV Carstens, Allen & Gourley, LLP Carstens, Allen & Gourley, LLP 10 1707 Cole Blvd, Suite 210 7500 Dallas Parkway, Suite 300 Denver, CO 80401 Plano, TX 75024 11 Tel: 727-432-3506; Fax: 972-367-2002 Tel: 972-367-2001; Fax: 972-367-2002 Email: hutchisson@caglaw.com Email: tbaroody@caglaw.com 12

13 Attorneys for Plaintiff Attorneys for Plaintiff 14 BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed the document(s) with the Clerk of the Court by using the CM/ECF system. Participants in the case who 15 are registered CM/ECF users will be served by the CM/ECF system. Participants in the case who are not registered CM/ECF users will be served by mail or by other means permitted by the court 16 rules. 17 I declare under penalty of perjury under the laws of the United States of America that the 18 foregoing is true and correct. 19 Executed on August 18, 2025, at Fresno, California. 20

21 /s/ Shane G. Smith 22 Shane G. Smith

23 042859-000000 11928249.3 24

25 26 27 1 2 ORDER 3 The Court has reviewed the Stipulated Protective Order filed by Plaintiff Rev Robotics 4 LLC (“Plaintiff”) and Defendant WestCoast Products & Design LLC (“Defendant”), through 5 their counsel of record, requesting that the Court enter an Order. 6 Having considered the above stipulation, and finding good cause, the Court adopts the signed 7 8 stipulated protective order, (Doc. 22), subject to the following: 9 Exhibit A, lines 16-17: “I hereby consent to the jurisdiction of said Court for purposes of 10 enforcing this Order, even if such enforcement proceedings occur after termination of this action.” 11 is hereby struck and replaced with “I hereby consent to the jurisdiction of said Court for purposes 12 of enforcing this Order, up to and until the termination of this action.” 13 The parties are advised that pursuant to the Local Rules of the United States District Court, 14 15 Eastern District of California, any documents subject to the protective order to be filed under seal 16 must be accompanied by a written request which complies with Local Rule 141 prior to sealing. The 17 party making a request to file documents under seal shall be required to show good cause for 18 documents attached to a non-dispositive motion or compelling reasons for documents attached to a 19 dispositive motion. Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-78 (9th Cir. 2009). Within 20 five (5) days of any approved document filed under seal, the party shall file a redacted copy of the 21 sealed document. The redactions shall be narrowly tailored to protect only the information that is 22 23 confidential or was deemed confidential. 24 /// 25 /// 26 /// 27 /// 1 Additionally, the parties shall consider resolving any dispute arising under the protective 2 order according to the Court’s informal discovery dispute procedure. 3 4

IT IS SO ORDERED.

5 Dated: August 18, 2025 /s/ Barbara A. McAuliffe _ 6

UNITED STATES MAGISTRATE JUDGE

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