Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page1of15 Page ID #:127

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

10 AROVAST CORPORATION and ETEKCITY CORPORATION Case No. 8:22-cv-1037-MRW Plaintiffs, 12 PROPOSED ES TIPULATED 3 V. ROTECTIVE ORDER

4 OKAY SOU CORPORATION and (MRW VERSION 4/19) 15 Defendant. Check if submitted without material modifications to MRW form 16 | 1. INTRODUCTION

M 1.1 PURPOSES AND LIMITATIONS

18 Discovery in this action is likely to involve production of confidential, 19 proprietary, or private information for which special protection from public 20 | disclosure and from use for any purpose other than prosecuting this litigation may *1 |! be warranted. Accordingly, the parties hereby stipulate to and petition the Court to |! enter the following Stipulated Protective Order. The parties acknowledge that this 23 |! Order does not confer blanket protections on all disclosures or responses to 24 discovery and that the protection it affords from public disclosure and use extends 25 only to the limited information or items that are entitled to confidential treatment 76 |! under the applicable legal principles. The parties further acknowledge, as set forth 27 |! in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 28

Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 2 of 15 Page ID #:128

1 file confidential information under seal; Civil Local Rule 79-5 sets forth the 2 procedures that must be followed and the standards that will be applied when a party 3 seeks permission from the court to file material under seal. 4 1.2 GOOD CAUSE STATEMENT 5 The above captioned matter involves claims for design patent infringement. The 6 parties are competitors in the field of air purifiers and similar consumer products. It 7 is anticipated that discovery on both sides will involve the disclosure of business 8 information, i.e., a trade secret or other confidential research, development, or 9 commercial information, that is proprietary to one party or the other, particularly as 10 they are direct competitors. The types of information already sought in discovery 11 includes records of design, purchase, sale, and shipment of products. It is 12 anticipated that further discovery may involve the identities of suppliers, 13 distributors, customers, and other service providers, as well as terms of business 14 transactions therewith. If such information were to become available to a party’s 15 competitor, the party is likely to suffer loss of a competitive advantage that it 16 presently has by maintaining such proprietary information as confidential. 17 2. DEFINITIONS 18 2.1 Action: this pending federal law suit. 19 2.2 Challenging Party: a Party or Non-Party that challenges the 20 designation of information or items under this Order. 21 2.3.1 “CONFIDENTIAL” Information or Items: information (regardless of 22 how it is generated, stored or maintained) or tangible things that qualify for 23 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 24 the Good Cause Statement. 25 2.3.2 “HIGHLY CONFIDENTIAL” Information or Items: information 26 (regardless of how it is generated, stored or maintained) or tangible things that 27 qualify for protection under Federal Rule of Civil Procedure 26(c), and comprise 28 business information, i.e., a trade secret or other confidential research, development, 2 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 3 of 15 Page ID #:129

1 or commercial information, that is proprietary to one party or the other, particularly 2 as they are direct competitors, as specified above in the Good Cause Statement. 3 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 4 their support staff). 5 2.5 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.” 8 2.6 Disclosure or Discovery Material: all items or information, regardless 9 of the medium or manner in which it is generated, stored, or maintained (including, 10 among other things, testimony, transcripts, and tangible things), that are produced or 11 generated in disclosures or responses to discovery in this matter. 12 2.7 Expert: a person with specialized knowledge or experience in a matter 13 pertinent to the litigation who has been retained by a Party or its counsel to serve as 14 an expert witness or as a consultant in this Action. 15 2.8 House Counsel: attorneys who are employees of a party to this Action. 16 House Counsel does not include Outside Counsel of Record or any other outside 17 counsel. 18 2.9 Non-Party: any natural person, partnership, corporation, association, or 19 other legal entity not named as a Party to this action. 20 2.10 Outside Counsel of Record: attorneys who are not employees of a 21 party to this Action but are retained to represent or advise a party to this Action and 22 have appeared in this Action on behalf of that party or are affiliated with a law firm 23 which has appeared on behalf of that party, and includes support staff. 24 2.11 Party: any party to this Action, including all of its officers, directors, 25 employees, consultants, retained experts, and Outside Counsel of Record (and their 26 support staffs). 27 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 28 Discovery Material in this Action. 3 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 4 of 15 Page ID #:130

1 2.13 Professional Vendors: persons or entities that provide litigation 2 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 demonstrations, and organizing, storing, or retrieving data in any form or medium) 4 and their employees and subcontractors. 5 2.14 Protected Material: any Disclosure or Discovery Material that is 6 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 7 2.15 Receiving Party: a Party that receives Disclosure or Discovery 8 Material from a Producing Party. 9 3. SCOPE 10 The protections conferred by this Stipulation and Order cover not only 11 Protected Material (as defined above), but also (1) any information copied or 12 extracted from Protected Material; (2) all copies, excerpts, summaries, or 13 compilations of Protected Material; and (3) any testimony, conversations, or 14 presentations by Parties or their Counsel that might reveal Protected Material. 15 Any use of Protected Material at trial will be governed by the orders of the 16 trial judge. This Order does not govern the use of Protected Material at trial. 17 4. DURATION 18 Once a case proceeds to trial, all of the information that was designated as 19 confidential or maintained pursuant to this protective order becomes public and will 20 be presumptively available to all members of the public, including the press, unless 21 compelling reasons supported by specific factual findings to proceed otherwise are 22 made to the trial judge in advance of the trial. See Kamakana v. City and County of 23 Honolulu, 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” 24 showing for sealing documents produced in discovery from “compelling reasons” 25 standard when merits-related documents are part of court record). Accordingly, the 26 terms of this protective order do not extend beyond the commencement of the trial. 27 28 4 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 5 of 15 Page ID #:131

1 5. DESIGNATING PROTECTED MATERIAL 2 5.1 Exercise of Restraint and Care in Designating Material for Protection. 3 Each Party or Non-Party that designates information or items for protection under 4 this Order must take care to limit any such designation to specific material that 5 qualifies under the appropriate standards. The Designating Party must designate for 6 protection only those parts of material, documents, items, or oral or written 7 communications that qualify so that other portions of the material, documents, 8 items, or communications for which protection is not warranted are not swept 9 unjustifiably within the ambit of this Order. 10 Mass, indiscriminate, or routinized designations are prohibited. Designations 11 that are shown to be clearly unjustified or that have been made for an improper 12 purpose (e.g., to unnecessarily encumber the case development process or to impose 13 unnecessary expenses and burdens on other parties) may expose the Designating 14 Party to sanctions. 15 If it comes to a Designating Party’s attention that information or items that it 16 designated for protection do not qualify for protection, that Designating Party must 17 promptly notify all other Parties that it is withdrawing the inapplicable designation. 18 5.2 Manner and Timing of Designations. Except as otherwise provided in 19 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 20 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 21 under this Order must be clearly so designated before the material is disclosed or 22 produced. 23 Designation in conformity with this Order requires: 24 (a) for information in documentary form (e.g., paper or electronic documents, 25 but excluding transcripts of depositions or other pretrial or trial proceedings), that 26 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” or 27 “HIGHLY CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each 28 page that contains protected material. If only a portion or portions of the material on 5 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 6 of 15 Page ID #:132

1 a page qualifies for protection, the Producing Party also must clearly identify the 2 protected portion(s) (e.g., by making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for 4 inspection need not designate them for protection until after the inspecting Party has 5 indicated which documents it would like copied and produced. During the 6 inspection and before the designation, all of the material made available for 7 inspection will be deemed “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 8 After the inspecting Party has identified the documents it wants copied and 9 produced, the Producing Party must determine which documents, or portions 10 thereof, qualify for protection under this Order. Then, before producing the specified 11 documents, the Producing Party must affix the appropriate “CONFIDENTIAL 12 legend” to each page that contains Protected Material. If only a portion or portions 13 of the material on a page qualifies for protection, the Producing Party also must 14 clearly identify the protected portion(s) (e.g., by making appropriate markings in the 15 margins). 16 (b) for testimony given in depositions that the Designating Party identify the 17 Disclosure or Discovery Material on the record, before the close of the deposition all 18 protected testimony. 19 (c) for information produced in some form other than documentary and for 20 any other tangible items, that the Producing Party affix in a prominent place on the 21 exterior of the container or containers in which the information is stored the 22 appropriate “CONFIDENTIAL legend.” If only a portion or portions of the 23 information warrants protection, the Producing Party, to the extent practicable, will 24 identify the protected portion(s). 25 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 26 failure to designate qualified information or items does not, standing alone, waive 27 the Designating Party’s right to secure protection under this Order for such material. 28 Upon timely correction of a designation, the Receiving Party must make reasonable 6 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 7 of 15 Page ID #:133

1 efforts to assure that the material is treated in accordance with the provisions of this 2 Order. 3 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 4 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 5 designation of confidentiality at any time that is consistent with the Court’s 6 Scheduling Order. 7 6.2 Meet and Confer. The Challenging Party will initiate the dispute 8 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 9 et seq. 10 6.3 The burden of persuasion in any such challenge proceeding will be on 11 the Designating Party. Frivolous challenges, and those made for an improper 12 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 13 parties) may expose the Challenging Party to sanctions. Unless the Designating 14 Party has waived or withdrawn the confidentiality designation, all parties will 15 continue to afford the material in question the level of protection to which it is 16 entitled under the Producing Party’s designation until the Court rules on the 17 challenge. 18 7. ACCESS TO AND USE OF PROTECTED MATERIAL 19 7.1 Basic Principles. A Receiving Party may use Protected Material that is 20 disclosed or produced by another Party or by a Non-Party in connection with this 21 Action only for prosecuting, defending, or attempting to settle this Action. Such 22 Protected Material may be disclosed only to the categories of persons and under the 23 conditions described in this Order. When the Action has been terminated, a 24 Receiving Party must comply with the provisions of section 13 below (FINAL 25 DISPOSITION). 26 Protected Material must be stored and maintained by a Receiving Party at a 27 location and in a secure manner that ensures that access is limited to the persons 28 authorized under this Order. 7 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 8 of 15 Page ID #:134

1 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 2 otherwise ordered by the court or permitted in writing by the Designating Party, a 3 Receiving Party may disclose any information or item designated 4 “CONFIDENTIAL” only to: 5 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 6 well as employees of said Outside Counsel of Record to whom it is reasonably 7 necessary to disclose the information for this Action; 8 (b) the officers, directors, and employees (including House Counsel) of 9 the Receiving Party to whom disclosure is reasonably necessary for this Action; 10 (c) Experts (as defined in this Order) of the Receiving Party to whom 11 disclosure is reasonably necessary for this Action and who have signed the 12 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 13 (d) the Court and its personnel; 14 (e) court reporters and their staff; 15 (f) professional jury or trial consultants, mock jurors, and Professional 16 Vendors to whom disclosure is reasonably necessary for this Action and who have 17 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 18 (g) the author or recipient of a document containing the information or a 19 custodian or other person who otherwise possessed or knew the information; 20 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 21 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 22 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 23 will not be permitted to keep any confidential information unless they sign the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 25 agreed by the Designating Party or ordered by the court. Pages of transcribed 26 deposition testimony or exhibits to depositions that reveal Protected Material may 27 be separately bound by the court reporter and may not be disclosed to anyone except 28 as permitted under this Stipulated Protective Order; and 8 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 9 of 15 Page ID #:135

1 (i) any mediator or settlement officer, and their supporting personnel, 2 mutually agreed upon by any of the parties engaged in settlement discussions. 3 7.3 Disclosure of “HIGHLY CONFIDENTIAL” Information or Items. 4 Unless otherwise ordered by the court or permitted in writing by the Designating 5 Party, a Receiving Party may disclose any information or item designated 6 “HIGHLY CONFIDENTIAL” only to: 7 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably 9 necessary to disclose the information for this Action; 10 (b) the Receiving Party’s Inside Counsel Designated in this Action, who 11 shall have an obligation to ensure that all HIGHLY CONFIDENTIAL information 12 is not disclosed to any other persons within the company; 13 (c) Experts (as defined in this Order) of the Receiving Party to whom 14 disclosure is reasonably necessary for this Action and who have signed the 15 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (d) the Court and its personnel; 17 (e) court reporters and their staff; 18 (f) professional jury or trial consultants, mock jurors, and Professional 19 Vendors to whom disclosure is reasonably necessary for this Action and who have 20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (g) the author or recipient of a document containing the information or a 22 custodian or other person who otherwise possessed or knew the information; 23 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 25 requests that the witness sign the form attached as Exhibit A hereto; and (2) they 26 will not be permitted to keep any confidential information unless they sign the 27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 28 agreed by the Designating Party or ordered by the court. Pages of transcribed 9 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 10 of 15 Page ID #:136

1 deposition testimony or exhibits to depositions that reveal Protected Material may 2 be separately bound by the court reporter and may not be disclosed to anyone except 3 as permitted under this Stipulated Protective Order; and 4 (i) any mediator or settlement officer, and their supporting personnel, 5 mutually agreed upon by any of the parties engaged in settlement discussions. 6 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 7 IN OTHER LITIGATION 8 If a Party is served with a subpoena or a court order issued in other litigation 9 that compels disclosure of any information or items designated in this Action as 10 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL,” that Party must: 11 (a) promptly notify in writing the Designating Party. Such notification 12 will include a copy of the subpoena or court order; 13 (b) promptly notify in writing the party who caused the subpoena or order 14 to issue in the other litigation that some or all of the material covered by the 15 subpoena or order is subject to this Protective Order. Such notification will include 16 a copy of this Stipulated Protective Order; and 17 (c) cooperate with respect to all reasonable procedures sought to be 18 pursued by the Designating Party whose Protected Material may be affected. 19 If the Designating Party timely seeks a protective order, the Party served with 20 the subpoena or court order will not produce any information designated in this 21 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” before a 22 determination by the court from which the subpoena or order issued, unless the 23 Party has obtained the Designating Party’s permission. The Designating Party will 24 bear the burden and expense of seeking protection in that court of its confidential 25 material and nothing in these provisions should be construed as authorizing or 26 encouraging a Receiving Party in this Action to disobey a lawful directive from 27 another court. 28 10 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 11 of 15 Page ID #:137

1 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 2 PRODUCED IN THIS LITIGATION 3 (a) The terms of this Order are applicable to information produced by a 4 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 5 CONFIDENTIAL.” Such information produced by Non-Parties in connection with 6 this litigation is protected by the remedies and relief provided by this Order. 7 Nothing in these provisions should be construed as prohibiting a Non-Party from 8 seeking additional protections. 9 (b) In the event that a Party is required, by a valid discovery request, to 10 produce a Non-Party’s confidential information in its possession, and the Party is 11 subject to an agreement with the Non-Party not to produce the Non-Party’s 12 confidential information, then the Party will: 13 (1) promptly notify in writing the Requesting Party and the Non-Party 14 that some or all of the information requested is subject to a confidentiality 15 agreement with a Non-Party; 16 (2) promptly provide the Non-Party with a copy of the Stipulated 17 Protective Order in this Action, the relevant discovery request(s), and a reasonably 18 specific description of the information requested; and 19 (3) make the information requested available for inspection by the 20 Non-Party, if requested. 21 (c) If the Non-Party fails to seek a protective order from this court within 22 14 days of receiving the notice and accompanying information, the Receiving Party 23 may produce the Non-Party’s confidential information responsive to the discovery 24 request. If the Non-Party timely seeks a protective order, the Receiving Party will 25 not produce any information in its possession or control that is subject to the 26 confidentiality agreement with the Non-Party before a determination by the court. 27 Absent a court order to the contrary, the Non-Party will bear the burden and expense 28 of seeking protection in this court of its Protected Material. 11 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 12 of 15 Page ID #:138

1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 3 Protected Material to any person or in any circumstance not authorized under this 4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 7 persons to whom unauthorized disclosures were made of all the terms of this Order, 8 and (d) request such person or persons to execute the “Acknowledgment and 9 Agreement to Be Bound” that is attached hereto as Exhibit A. 10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 11 PROTECTED MATERIAL 12 When a Producing Party gives notice to Receiving Parties that certain 13 inadvertently produced material is subject to a claim of privilege or other protection, 14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 16 procedure may be established in an e-discovery order that provides for production 17 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 18 (e), insofar as the parties reach an agreement on the effect of disclosure of a 19 communication or information covered by the attorney-client privilege or work 20 product protection, the parties may incorporate their agreement in the stipulated 21 protective order submitted to the court. 22 12. MISCELLANEOUS 23 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 24 person to seek its modification by the Court in the future. 25 12.2 Right to Assert Other Objections. By stipulating to the entry of this 26 Protective Order no Party waives any right it otherwise would have to object to 27 disclosing or producing any information or item on any ground not addressed in this 28 12 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 13 of 15 Page ID #:139

1 Stipulated Protective Order. Similarly, no Party waives any right to object on any 2 ground to use in evidence of any of the material covered by this Protective Order. 3 12.3 Filing Protected Material. A Party that seeks to file under seal any 4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 5 only be filed under seal pursuant to a court order authorizing the sealing of the 6 specific Protected Material at issue. If a Party's request to file Protected Material 7 under seal is denied by the court, then the Receiving Party may file the information 8 in the public record unless otherwise instructed by the court. 9 13. FINAL DISPOSITION 10 After the final disposition of this Action, as defined in paragraph 4, within 60 11 days of a written request by the Designating Party, each Receiving Party must return 12 all Protected Material to the Producing Party or destroy such material. As used in 13 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 14 summaries, and any other format reproducing or capturing any of the Protected 15 Material. Whether the Protected Material is returned or destroyed, the Receiving 16 Party must submit a written certification to the Producing Party (and, if not the same 17 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 18 (by category, where appropriate) all the Protected Material that was returned or 19 destroyed and (2) affirms that the Receiving Party has not retained any copies, 20 abstracts, compilations, summaries or any other format reproducing or capturing any 21 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 22 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 23 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 24 reports, attorney work product, and consultant and expert work product, even if such 25 materials contain Protected Material. Any such archival copies that contain or 26 constitute Protected Material remain subject to this Protective Order as set forth in 27 Section 4 (DURATION). 28 13 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 14 of 15 Page ID #:140

1 14. Any willful violation of this Order may be punished by civil or criminal 2 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 3 authorities, or other appropriate action at the discretion of the Court. 4 5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 6 7 DATED: _09/09/2022_____ _/R Joseph Trojan/__________ R. Joseph Trojan (137,067) 8 Dylan C. Dang (223, 455)

TROJAN LAW OFFICES

9 Attorneys for Plaintiffs Arovast Corporation and Etekcity Corporation 10 11 12 DATED: _09/09/2022_____ _/Michael A DiNardo/________ Michael A. DiNardo (216,991) 13 YK LAW LLP Attorneys for Defendants Okaysou 14 Corporation and Hao Ma 15 16

FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

17 18 19

DATED:____0_9_/1_2_/_2_0_2_2___ ___________/S_/______________________

20 HON. MICHAEL R. WILNER United States Magistrate Judge 21 22 23 24 25 26 27 28 14 Case 8:22-cv-01037-MRW Document 29 Filed 09/12/22 Page 15 of 15 Page ID #:141

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of Arovast 8 Corp and Etekcity Corp v. Okaysou Corp and Hao Ma, 8:22-cv-1037-MRW. I agree 9 to comply with and to be bound by all the terms of this Stipulated Protective Order 10 and I understand and acknowledge that failure to so comply could expose me to 11 sanctions and punishment in the nature of contempt. I solemnly promise that I will 12 not disclose in any manner any information or item that is subject to this Stipulated 13 Protective Order to any person or entity except in strict compliance with the 14 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 the purpose of enforcing the terms of this 17 Stipulated Protective Order, even if such enforcement proceedings occur after 18 termination of this action. I hereby appoint __________________________ [full 19 name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27 28 Signature: __________________________________ 15