Case 2|/P1-cv-09880-ODW-AFM Document 23 Filed 08/26/22 Page1of17 Page ID #:139

1|| Kelly Cunningham SBN 186229)

WSYLAX, LLC

REID E. DAMMANN (SBN: 249031)

8 nefanneraningt ers Conn

JULIANA C. FERRAZ (SBN: 293851)

9 Lemraci-grsm.com

IOLAINE BRUNET (SBN: 305609)

0, 10 □□ Secon 0. GORDON REES SCULLY MANSUKHANTI, LLP 5 11 || 633 West Fifth Street, 52 floor wn Los Angeles, CA 90071 Lu 12 || Telephone: Gb) 576-5065 ~ Facsimile: (213) 680-4470 ww 13 Zz Attorneys for Defendant > 14 || TRUE LACROSSE, LLC

S 15 UNITED STATES DISTRICT COURT

= 16 CENTRAL DISTRICT OF CALIFORNIA ox Lij 17 18 || WSYLAX, LLC, a Delaware Limited Case No. 2:21-cv-9880-ODW (AFM) Liability Company, 19 {PROPOSED} PROTECTIVE Plaintiff, ORDER 20

V. Hon. Alexander F. MacKinnon

21 TRUE LACROSSE, LLC, a Illinois 22 Pimited Liability Company; and DOES | Action Filed: December 22, 2021 23 Defendants. 24 25 || AND COUNTERCLAIMS 26 27 28 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1}/1. INTRODUCTION 2 1.1 Purposes and Limitations. Discovery in this action is likely to involve 3 || production of confidential, proprietary, or private information for which special 4 || protection from public disclosure and from use for any purpose other than 5 || prosecuting this litigation may be warranted. Accordingly, the parties hereby 6 || stipulate to and petition the Court to enter the following Stipulated Protective 7 || Order. The parties acknowledge that this Order does not confer blanket protections 8 || on all disclosures or responses to discovery and that the protection it affords from 9 || public disclosure and use extends only to the limited information or items that are 10 || entitled to confidential treatment under the applicable legal principles. The parties 5 11 || further acknowledge, as set forth in Section 12.3, below, that this Stipulated □□ 12 || Protective Order does not entitle them to file confidential information under seal; 13 || Civil Local Rule 79-5 sets forth the procedures that must be followed and the a 14 || standards that will be applied when a party seeks permission from the court to file S 15 || material under seal. = 16 1.2. Good Cause Statement. This action is likely to involve trade secrets, a 17 || customer and pricing lists and other valuable research, development, commercial, 18 || financial, technical and/or proprietary information for which special protection 19 || from public disclosure and from use for any purpose other than prosecution of this 20 || action is warranted. Such confidential and proprietary materials and information 21 || consist of, among other things, confidential business or financial information, 22 || information regarding confidential business practices, or other confidential 23 || research, development, or commercial information (including information 24 || implicating privacy rights of third parties), information otherwise generally 25 || unavailable to the public, or which may be privileged or otherwise protected from 26 || disclosure under state or federal statutes, court rules, case decisions, or common 27 ||law. Accordingly, to expedite the flow of information, to facilitate the prompt 28 || resolution of disputes over confidentiality of discovery materials, to adequately 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1 || protect information the parties are entitled to keep confidential, to ensure that the 2 || parties are permitted reasonable necessary uses of such material in preparation for 3 || and in the conduct of trial, to address their handling at the end of the litigation, and 4 || serve the ends of justice, a protective order for such information is justified in this 5 || matter. It is the intent of the parties that information will not be designated as 6 || confidential for tactical reasons and that nothing be so designated without a good 7 || faith belief that it has been maintained in a confidential, non-public manner, and 8 || there is good cause why it should not be part of the public record of this case. a 10 |} 2. DEFINITIONS 5 ou 2.1 Action: WSYLAX, LLC v. True Lacrosse, LLC, United States District □□ 12 || Court, Central District of California Case No. 2:21-cv-9880-ODW (AFM). 13 2.2 Challenging Party: a Party or Non-Party that challenges the designation a 14 || of information or items under this Order. S 15 2.3. “CONFIDENTIAL” and “CONFIDENTIAL -- ATTORNEY’S EYES = 16 || ONLY” Information or Items: information (regardless of how it is generated, stored in 17 || or maintained) or tangible things that qualify for protection under Federal Rule of 18 || Civil Procedure 26(c), and as specified above in the Good Cause Statement. 19 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 20 || their support staff). 21 2.5 Designating Party: a Party or Non-Party that designates information or 22 \|items that it produces in disclosures or in responses to discovery as 23 || “CONFIDENTIAL” or “CONFIDENTIAL -- ATTORNEY’S EYES ONLY.” 24 2.6 Disclosure or Discovery Material: all items or information, regardless 25 || of the medium or manner in which it is generated, stored, or maintained (including, 26 || among other things, testimony, transcripts, and tangible things), that are produced or 27 || generated in disclosures or responses to discovery in this matter. 28 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1 2.7 Expert: a person with specialized knowledge or experience in a matter 2 || pertinent to the litigation who has been retained by a Party or its counsel to serve as 3 || an expert witness or as a consultant in this Action. 4 2.8 House Counsel: attorneys who are employees of a party to this Action. 5 || House Counsel does not include Outside Counsel of Record or any other outside 6 || counsel. 7 2.9 Non-Party: any natural person, partnership, corporation, association, or 8 || other legal entity not named as a Party to this action. 9 2.10 Qutside Counsel of Record: attorneys who are not employees of a party 10 || to this Action but are retained to represent or advise a party to this Action and have 5 11 || appeared in this Action on behalf of that party or are affiliated with a law firm that □□ 12 || has appeared on behalf of that party, including support staff. 13 2.11 Party: any party to this Action, including all of its officers, directors, a 14 || employees, consultants, retained experts, and Outside Counsel of Record (and their S 15 || support staffs). = 16 2.12 Producing Party: a Party or Non-Party that produces Disclosure or in 17 || Discovery Material in this Action. 18 2.13 Professional Vendors: persons or entities that provide litigation support 19||services (e.g., photocopying, videotaping, translating, preparing exhibits or 20 || demonstrations, and organizing, storing, or retrieving data in any form or medium) 21 || and their employees and subcontractors. 22 2.14 Protected Material: any Disclosure or Discovery Material that 1s 23 || designated as “CONFIDENTIAL” or “CONFIDENTIAL — ATTORNEY’S EYES 24 || ONLY”. 25 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 26 || from a Producing Party. 27 28 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1|/3. SCOPE 2 The protections conferred by this Stipulation and Order cover not only 3 || Protected Material (as defined above), but also (1) any information copied or 4/|extracted from Protected Material; (2) all copies, excerpts, summaries, or 5||compilations of Protected Material; and (3) any testimony, conversations, or 6 || presentations by Parties or their Counsel that might reveal Protected Material. 7 || Any use of Protected Material at trial shall be governed by the orders of the trial 8 || judge. This Order does not govern the use of Protected Material at trial. 9 10||4. DURATION 5 11 Once a case proceeds to trial, all of the court-filed information to be introduced □□ 12 ||that was previously designated as confidential or maintained pursuant to this 13 || protective order becomes public and will be presumptively available to all members a 14 || of the public, including the press, unless compelling reasons supported by specific S 15 || factual findings to proceed otherwise are made to the trial judge in advance of the = 16 || trial. See, Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1180-81 (9th in 17 || Cir. 2006) (distinguishing “good cause” showing for sealing documents produced in 18 || discovery from “compelling reasons” standard when merits-related documents are 19 || part of court record). Accordingly, the terms of this protective order do not extend 20 || beyond the commencement of the trial. 21 22 || 5. DESIGNATING PROTECTED MATERIAL 23 5.1 Exercise of Restraint and Care in Designating Material for Protection. 24 || Each Party or Non-Party that designates information or items for protection under 25 this Order must take care to limit any such designation to specific material that 26 || qualifies under the appropriate standards. The Designating Party must designate for 27 || protection only those parts of material, documents, items, or oral or written 28 || communications that qualify so that other portions of the material, documents, items, 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1 || or communications for which protection is not warranted are not swept unjustifiably 2 || within the ambit of this Order. 3 Mass, indiscriminate, or routinized designations are prohibited. Designations 4||that are shown to be clearly unjustified or that have been made for an improper 5 || purpose (e.g., to unnecessarily encumber the case development process or to impose 6 || unnecessary expenses and burdens on other parties) may expose the Designating 7 || Party to sanctions. 8 If it comes to a Designating Party’s attention that information or items that it 9 || designated for protection do not qualify for protection, that Designating Party must 9 10 || promptly notify all other Parties that it is withdrawing the inapplicable designation. 5 11 5.2 Manner and Timing of Designations. Except as otherwise provided in □□ 12 ||this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 13 || stipulated or ordered, Disclosure or Discovery Material that qualifies for protection a 14 || under this Order must be clearly so designated before the material is disclosed or S 15 || produced. S 16 Designation in conformity with this Order requires: Lu 17 (a) for information in documentary form (e.g., paper or electronic 18 || documents, but excluding transcripts of depositions or other pretrial or trial 19 || proceedings), that the Producing Party affix, at a minimum, the legend 20||““CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEY’S EYES ONLY” 21 || (hereinafter “CONFIDENTIAL legend’), to each page that contains protected 22 ||material. If only a portion or portions of the material on a page qualifies for 23 || protection, the Producing Party also must clearly identify the protected portion(s) 24 || (e.g., by making appropriate markings in the margins). 25 A Party or Non-Party that makes original documents available for inspection 26 need not designate them for protection until after the inspecting Party has indicated 27 || which documents it would like copied and produced. During the inspection and 28 || before the designation, all of the material made available for inspection shall be 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1||}deemed “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEY’S EYES □ □□ ONLY.” After the inspecting Party has identified the documents it wants copied and 3 || produced, the Producing Party must determine which documents, or portions thereof, 4|| qualify for protection under this Order. Then, before producing the specified 5 || documents, the Producing Party must affix the “CONFIDENTIAL legend” to each 6 || page that contains Protected Material. If only a portion or portions of the material on 7\|a page qualifies for protection, the Producing Party also must clearly identify the 8 || protected portion(s) (e.g., by making appropriate markings in the margins). 9 (b) for testimony given in depositions that the Designating Party 9 10 || identify the Disclosure or Discovery Material on the record, before the close of the 5 11 || deposition. □□ 12 (c) for information produced in some form other than documentary 13 || and for any other tangible items, that the Producing Party affix in a prominent place a 14 || on the exterior of the container or containers in which the information is stored the S 15 || legend “CONFIDENTIAL.” If only a portion or portions of the information warrants S 16 || protection, the Producing Party, to the extent practicable, shall identify the protected Lu 17 || portion(s). 18 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 19 || failure to designate qualified information or items does not, standing alone, waive 20 || the Designating Party’s right to secure protection under this Order for such material. 21 || Upon timely correction of a designation, the Receiving Party must make reasonable 22 || efforts to assure that the material is treated in accordance with the provisions of this 23 || Order. 24 5.4 Productions by Third Parties. If a party believes that documents 25 || produced in response to a subpoena to a third party may contain documents which 26||are confidential and proprietary and would be properly designated as 27 || “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEY’S EYES ONLY” such 28 || party may notify the subpoenaing party in writing prior to the designated production 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1|/date that it expects confidential and proprietary information may be provided. 2 || Following such written notice and upon receipt of the documents to all parties, all 3 || documents provided in response to the subpoena shall be provisionally designated 4 || “CONFIDENTIAL” for five court days. During such time any party may designate 5||documents provided in response to such subpoena “CONFIDENTIAL” as 6 || appropriate under this protective order. 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 5 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. Any discovery motion must strictly > 14 || comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3. S 15 6.3. Burden. The burden of persuasion in any such challenge proceeding = 16 ||shall be on the Designating Party. Frivolous challenges, and those made for an in 17 || improper purpose (e.g., to harass or impose unnecessary expenses and burdens on 18 || other parties) may expose the Challenging Party to sanctions. Unless the Designating 19 || Party has waived or withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protection to which it is 21 || entitled under the Producing Party’s designation until the Court rules on the 22 || challenge. 23 24 || 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is 26 || disclosed or produced by another Party or by a Non-Party in connection with this 27|| Action only for prosecuting, defending, or attempting to settle this Action. Such 28 || Protected Material may be disclosed only to the categories of persons and under the 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1||conditions described in this Order. When the Action has been terminated, a 2||Receiving Party must comply with the provisions of section 13 below (FINAL 3 || DISPOSITION).3.9 4 Protected Material must be stored and maintained by a Receiving Party at 5 || alocation and in a secure manner that ensures that access is limited to the persons 6 || authorized under this Order. 7 7.2 Disclosure _of “CONFIDENTIAL” Information or Items. Unless 8 || otherwise ordered by the Court or permitted in writing by the Designating Party, a 9||Receiving Party may disclose any information or item designated 9 10 || “CONFIDENTIAL” only to: 5 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, □□ 12 ||as well as employees of said Outside Counsel of Record to whom it is reasonably w 13 || necessary to disclose the information for this Action; a 14 (b) the officers, directors, and employees (including House Counsel) S 15 || of the Receiving Party to whom disclosure is reasonably necessary for this Action; S 16 (c) | Experts (as defined in this Order) of the Receiving Party to whom LJ 17||disclosure is reasonably necessary for this Action and who have signed the 18 || “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the Court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and 22 || Professional Vendors to whom disclosure is reasonably necessary for this Action and 23 || who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information 25 || or a custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, 27 || in the Action to whom disclosure is reasonably necessary provided: (1) the deposing 28 || party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) 17959.1:10672440.2

STIPULATED PROTECTIVE ORDER

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1 || they will not be permitted to keep any confidential information unless they sign the 2||“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 ||agreed by the Designating Party or ordered by the Court. Pages of transcribed 4 || deposition testimony or exhibits to depositions that reveal Protected Material may be 5 || separately bound by the court reporter and may not be disclosed to anyone except as 6 || permitted under this Stipulated Protective Order; and 7 (i) any mediator or settlement officer, and their supporting 8 || personnel, mutually agreed upon by any of the parties engaged in settlement 9 || discussions. 9 10 7.3. Disclosure of “CONFIDENTIAL- ATTORNEYS’ EYES ONLY” 5 11 || Information or Items. Unless otherwise ordered by the Court or permitted in □□ 12 || writing by the Designating Party, a Receiving Party may disclose any information 13 || or item designated “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” only to a 14 || those identified in section 7.2 above, with the exception that information and/or S 15 || items designated “CONFIDENTIAL — ATTORNEYS’ EYES ONLY” may not, S 16 || unless otherwise ordered by the Court or permitted in writing by the Designating Lu 17 || Party, be disclosed to any of the following individuals: 18 (a) any officer, director, or employee (including House Counsel) of 19 || any Receiving Party; 20 (b) any expert (as defined in this Order) of the Receiving Party if 21 ||such expert has or has ever had a financial relationship (other than the retention as 22 || an expert in the present Action) or familial relationship with any Receiving Party. 23 || /// 24 |] /// 25 || /// 26 || 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 27 PRODUCED IN OTHER LITIGATION 28 17959.1:10672440.2 10

STIPULATED PROTECTIVE ORDER

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1 If a Party is served with a subpoena or a court order issued in other litigation 2 ||that compels disclosure of any information or items designated in this Action as 3 || ““CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEY’S EYES ONLY” that 4 || Party must: 5 (a) promptly notify in writing the Designating Party. Such 6 || notification shall include a copy of the subpoena or court order; 7 (b) promptly notify in writing the party who caused the subpoena or 8 || order to issue in the other litigation that some or all of the material covered by the 9 || subpoena or order is subject to this Protective Order. Such notification shall include 9 10 ||a copy of this Stipulated Protective Order; and 5 11 (c) cooperate with respect to all reasonable procedures sought to be □□ 12 || pursued by the Designating Party whose Protected Material may be affected. © 13 If the Designating Party timely seeks a protective order, the Party served with a 14 || the subpoena or court order shall not produce any information designated in this S 15 action as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEY’S EYES = 16 || ONLY” before a determination by the court from which the subpoena or order issued, in 17 || unless the Party has obtained the Designating Party’s permission. The Designating 18 || Party shall bear the burden and expense of seeking protection in that court of its 19 ||confidential material and nothing in these provisions should be construed as 20 || authorizing or encouraging a Receiving Party in this Action to disobey a lawful 21 || directive from another court. 22 23/19. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 24 PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced 26||by a Non-Party in this Action and designated as “CONFIDENTIAL” or 27 || “CONFIDENTIAL - ATTORNEY’S EYES ONLY”. Such information produced by 28 || Non-Parties in connection with this litigation 1s protected by the remedies and relief 17959.1:10672440.2 ll

STIPULATED PROTECTIVE ORDER

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□□□ provided by this Order. Nothing in these provisions should be construed as 2 || prohibiting a Non-Party from seeking additional protections. 3 (b) Inthe event that a Party is required, by a valid discovery request, 4 || to produce a Non-Party’s confidential information in its possession, and the Party is 5||subject to an agreement with the Non-Party not to produce the Non-Party’s 6 || confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the 8 Non-Party that some or all of the information requested is subject to a 9 confidentiality agreement with a Non-Party; 9 10 (2) promptly provide the Non-Party with a copy of the 5 11 Stipulated Protective Order in this Action, the relevant discovery request(s), □□ 12 and a reasonably specific description of the information requested; and © 13 (3) make the information requested available for inspection by a 14 the Non-Party, if requested. S 15 (c) Ifthe Non-Party fails to seek a protective order from this Court S 16 || within 14 days of receiving the notice and accompanying information, the Receiving 17|| Party may produce the Non-Party’s confidential information responsive to the 18 || discovery request. If the Non-Party timely seeks a protective order, the Receiving 19 || Party shall not produce any information in its possession or control that is subject to 20||the confidentiality agreement with the Non-Party before a determination by the 21 || Court. Absent a court order to the contrary, the Non-Party shall bear the burden and 22 || expense of seeking protection in this Court of its Protected Material. 23 24 25 26|/|10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 27 Ifa 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 17959.1:10672440.2 12

STIPULATED PROTECTIVE ORDER

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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. 8)}11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 9 PROTECTED MATERIAL 10 When a Producing Party gives notice to Receiving Parties that certain 5 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 S 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 in 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. 17959.1:10672440.2 13

STIPULATED PROTECTIVE ORDER

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1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 || Protected Material must comply with Civil Local 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 at issue; good cause must be shown in the request to file 5 || under seal. If a Party’s request to file Protected Material under seal is denied by the 6 || Court, then the Receiving Party may file the information in the public record unless 7 || otherwise instructed by the Court. 9|/13. FINAL DISPOSITION 9 10 After the final disposition of this Action, within 60 days of a written request 5 11 || by the Designating Party, each Receiving Party must return all Protected Material to □□ 12 ||the Producing Party or destroy such material. As used in this subdivision, “all © 13 || Protected Material” includes all copies, abstracts, compilations, summaries, and any a 14 || other format reproducing or capturing any of the Protected Material. Whether the S 15 || Protected Material is returned or destroyed, the Receiving Party must submit a = 16 || written certification to the Producing Party (and, if not the same person or entity, to in 17 || the Designating Party) by the 60 day deadline that (1) identifies (by category, where 18 || appropriate) all the Protected Material that was returned or destroyed and (2) affirms 19 || that the Receiving Party has not retained any copies, abstracts, compilations, 20|;summaries or any other format reproducing or capturing any of the Protected 21 || Material. Notwithstanding this provision, counsel are entitled to retain an archival 22 || copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 23 || memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 24 || work product, and consultant and expert work product, even if such materials contain 25 || Protected Material. Any such archival copies that contain or constitute Protected 26 || Material remain subject to this Protective Order as set forth in Section 4 27 || (DURATION). 28 17959.1:10672440.2 14

STIPULATED PROTECTIVE ORDER

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1\/14. Any violation of this Order may be punished by any and all appropriate 2||measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. □ IS SO STIPULATED THROUGH COUNSEL OF RECORD: 6 || DATED: August 26, 2022 ERVIN COHEN & JESSUP LLP 7 Kelly Cunningham By: /s/ Kelly Cunningham 10 Kelly Cunningham oO. W Attorneys for Plaintiff

Z WSYLAX, LLC

im 8612 = Dated: August 26, 2022 GORDON REES SCULLY MANSUKHANI, LLP 13 ia xs i4 By: Oo _/s/Reid Dammann WU 15 Reid E. Dammann z Juliana C. Ferraz > 16 Violaine Brunet ox Attorneys for Defendants Li} 17 TRUE LACROSSE, LLC 18 19 20 21 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 22 23|| DATED: 8/26/2022 24 - a, 25 26 || Alexander F. MacKinnon United States Magistrate Judge 27 28 17959.1:10672440.2 ] 5

STIPULATED PROTECTIVE ORDER

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STIPULATED PROTECTIVE ORDER

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1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 4|{I, [print or type full name], of 5 [print or type full address], 6 || declare under penalty of perjury that I have read in its entirety and understand the 7 || Stipulated Protective Order that was issued by the United States District Court for the g || Central District of California on [date] in the above-referenced g || Action, I agree to comply with and to be bound by all the terms of this Stipulated 0 10 || Protective Order and I understand and acknowledge that failure to so comply could ao 11 || XPose me to sanctions and punishment in the nature of contempt. I solemnly promise a □ that I will not disclose in any manner any information or item that is subject to this B Stipulated Protective Order to any person or entity except in strict compliance with a 14 the provisions of this Order. I further agree to submit to the jurisdiction of the United S 1s States District Court for the Central District of California for the purpose of enforcing z 16 the terms of this Stipulated Protective Order, even if such enforcement proceedings a u occur after termination of this action.

18 19 (Signature) 20 21 (City and State where signed) 22 23 (Date) 24 25 26 27 28 17959.1:10672440.2 17

STIPULATED PROTECTIVE ORDER