1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 ALVANTOR INDUSTRYCO., LTD., ) ) Case No. 2:22-cv-04844-DOC-JPR 11 ) Plaintiff, ) STIPULATED PROTECTIVE 12 ) ORDER ) 13 v. ) ) 14 )

SHENZHEN JORDA TRADING CO., )

15 LTD., DBA ELEVENS, PEX FIX, ET ) ) 16 AL., SHENZHEN 703, AKA, )

SHENZHEN QILINGSAN NETWORK )

17 )

TECHNOLOGY CO., LTD., NEUTYPE,

) 18 AND MIRUO MIRROR, INC., ) ) 19 ) Defendants. ) 20 )

21 Pursuant to the Parties’ Stipulation, and for good cause shown, the 22 Court finds and orders as follows. 23 1. PURPOSES AND LIMITATIONS 24 Discovery in this action is likely to involve production of confidential, 25 26 proprietary or private information for which special protection from public 27 disclosure and from use for any purpose other than pursuing this litigation may 28 be warranted. Accordingly, the parties hereby stipulate to and petition the 1 Court to enter the following Stipulated Protective Order. The parties 2 acknowledge that this Order does not confer blanket protections on all 3 disclosures or responses to discovery and that the protection it affords from 4 public disclosure and use extends only to the limited information or items that 5 are entitled to confidential treatment under the applicable legal principles. 6 2. GOOD CAUSE STATEMENT 7 This action is likely to involve trade secrets, customer and pricing lists 8 and other valuable research, development, commercial, financial, technical 9 and/or proprietary information for which special protection from public 10 disclosure and from use for any purpose other than prosecution of this action is 11 warranted. Such confidential and proprietary materials and information 12 consist of, among other things, confidential business or financial information, 13 information regarding confidential business practices, or other confidential 14 research, development, or commercial information (including information 15 implicating privacy rights of third parties), information otherwise generally 16 unavailable to the public, or which may be privileged or otherwise protected 17 from disclosure under state or federal statutes, court rules, case decisions, or 18 common law. Accordingly, to expedite the flow of information, to facilitate the 19 prompt resolution of disputes over confidentiality of discovery materials, to 20 21 adequately protect information the parties are entitled to keep confidential, to 22 ensure that the parties are permitted reasonable necessary uses of such material 23 in preparation for and in the conduct of trial, to address their handling at the 24 end of the litigation, and serve the ends of justice, a protective order for such 25 information is justified in this matter. It is the intent of the parties that 26 information will not be designated as confidential for tactical reasons and that 27 nothing be so designated without a good faith belief that it has been 28 maintained in a confidential, non-public manner, and there is good cause why 1 it should not be part of the public record of this case. 2 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 3 PROCEDURE 4 The parties further acknowledge, as set forth in Section 14.3, below, that 5 this Stipulated Protective Order does not entitle them to file confidential 6 information under seal; Local Civil Rule 79-5 sets forth the procedures that 7 must be followed and the standards that will be applied when a party seeks 8 permission from the court to file material under seal. There is a strong 9 presumption that the public has a right of access to judicial proceedings and 10 records in civil cases. In connection with non-dispositive motions, good cause 11 must be shown to support a filing under seal. See Kamakana v. City and 12 County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. 13 Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony 14 Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 15 protective orders require good cause showing), and a specific showing of good 16 cause or compelling reasons with proper evidentiary support and legal 17 justification, must be made with respect to Protected Material that a party 18 seeks to file under seal. The parties’ mere designation of Disclosure or 19 Discovery Material as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL 20 21 – ATTORNEY’S EYES ONLY” does not— without the submission of 22 competent evidence by declaration, establishing that the material sought to be 23 filed under seal qualifies as confidential, privileged, or otherwise protectable— 24 constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, 26 then compelling reasons, not only good cause, for the sealing must be shown, 27 and the relief sought shall be narrowly tailored to serve the specific interest to 28 be protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th 1 Cir. 2010). For each item or type of information, document, or thing sought to 2 be filed or introduced under seal, the party seeking protection must articulate 3 compelling reasons, supported by specific facts and legal justification, for the 4 requested sealing order. Again, competent evidence supporting the application 5 to file documents under seal must be provided by declaration. 6 Any document that is not confidential, privileged, or otherwise 7 protectable in its entirety will not be filed under seal if the confidential portions 8 can be redacted. If documents can be redacted, then a redacted version for 9 public viewing, omitting only the confidential, privileged, or otherwise 10 protectable portions of the document, shall be filed. Any application that seeks 11 to file documents under seal in their entirety should include an explanation of 12 why redaction is not feasible. 13 4. DEFINITIONS 14 4.1 Action: Alvantor Industry Co., LTD. v. Shenzen Jorda Trading Co., 15 LTD. et al., Case No. 2:22-cv-04844-DOC-JPR. 16 4.2 Challenging Party: a Party or Non-Party that challenges the 17 designation of information or items under this Order. 18 4.3 “CONFIDENTIAL” Information or Items: information 19 20 (regardless of how it is generated, stored or maintained) or tangible things that 21 qualify for protection under Federal Rule of Civil Procedure 26(c), and as 22 specified above in the Good Cause Statement. 23 4.4 “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” 24 Information or Items: information (regardless of how it is generated, stored or 25 maintained) or tangible things that qualify for protection under Federal Rule of 26 Civil Procedure 26(c), and as specified above in the Good Cause Statement, 27 and also the disclosure of which to another party or non-party may seriously 28 harm the party producing the information. Examples of information that 1 might be considered HIGHLY CONFIDENTIAL – ATTORNEY’S EYES 2 ONLY include sales data, sales units, pricing structures, product development 3 documents, safety testing and analysis documents, business and marketing 4 plans, and personally identifying information of customers. 5 4.5 Counsel: Outside Counsel of Record and House Counsel (as well 6 as their support staff). 7 4.6 Designating Party: a Party or Non-Party that designates 8 information or items that it produces in disclosures or in responses to discovery 9 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S 10

EYES ONLY.”

11 4.7 Disclosure or Discovery Material: all items or information, 12 regardless of the medium or manner in which it is generated, stored, or 13 maintained (including, among other things, testimony, transcripts, and tangible 14 things), that are produced or generated in disclosures or responses to discovery. 15 4.8 Expert: a person with specialized knowledge or experience in a 16 matter pertinent to the litigation who has been retained by a Party or its 17 counsel to serve as an expert witness or as a consultant in this Action. 18 4.9 House Counsel: attorneys who are employees of a party to this 19 Action. House Counsel does not include Outside Counsel of Record or any 20 21 other outside counsel. 22 4.10 Non-Party: any natural person, partnership, corporation, 23 association or other legal entity not named as a Party to this action. 24 4.11 Outside Counsel of Record: attorneys who are not employees of a 25 party to this Action but are retained to represent a party to this Action and 26 have appeared in this Action on behalf of that party or are affiliated with a law 27 firm that has appeared on behalf of that party, and includes support staff. 28 4.12 Party: any party to this Action, including all of its officers, 1 directors, employees, consultants, retained experts, and Outside Counsel of 2 Record (and their support staffs). 3 4.13 Producing Party: a Party or Non-Party that produces Disclosure or 4 Discovery Material in this Action. 5 4.14 Professional Vendors: persons or entities that provide litigation 6 support services (e.g., photocopying, videotaping, translating, preparing 7 exhibits or demonstrations, and organizing, storing, or retrieving data in any 8 form or medium) and their employees and subcontractors. 9 4.15 Protected Material: any Disclosure or Discovery Material that is 10 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 11

ATTORNEY’S EYES ONLY.”

12 4.16 Receiving Party: a Party that receives Disclosure or Discovery 13 Material from a Producing Party. 14 5. SCOPE 15 The protections conferred by this Stipulation and Order cover not only 16 Protected Material (as defined above), but also (1) any information copied or 17 extracted from Protected Material; (2) all copies, excerpts, summaries, or 18 compilations of Protected Material; and (3) any testimony, conversations, or 19 presentations by Parties or their Counsel that might reveal Protected Material. 20 21 Any use of Protected Material at trial shall be governed by the orders of 22 the trial judge and other applicable authorities. This Order does not govern the 23 use of Protected Material at trial. 24 6. DURATION 25 Once a case proceeds to trial, information that was designated as 26 CONFIDENTIAL or maintained pursuant to this protective order used or 27 introduced as an exhibit at trial becomes public and will be presumptively 28 available to all members of the public, including the press, unless compelling 1 reasons supported by specific factual findings to proceed otherwise are made to 2 the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 3 (distinguishing “good cause” showing for sealing documents produced in 4 discovery from “compelling reasons” standard when merits-related documents 5 are part of court record). Accordingly, the terms of this protective order do not 6 extend beyond the commencement of the trial. 7 7. DESIGNATING PROTECTED MATERIAL 8 7.1 Exercise of Restraint and Care in Designating Material for 9 Protection. Each Party or Non-Party that designates information 10 or items for protection under this Order must take care to limit any such 11 designation to specific material that qualifies under the appropriate standards. 12 The Designating Party must designate for protection only those parts of 13 material, documents, items or oral or written communications that qualify so 14 that other portions of the material, documents, items or communications for 15 which protection is not warranted are not swept unjustifiably within the ambit 16 of this Order. 17 Mass, indiscriminate or routinized designations are prohibited. 18 Designations that are shown to be clearly unjustified or that have been made 19 for an improper purpose (e.g., to unnecessarily encumber the case development 20 21 process or to impose unnecessary expenses and burdens on other parties) may 22 expose the Designating Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items 24 that it designated for protection do not qualify for protection, that Designating 25 Party must promptly notify all other Parties that it is withdrawing the 26 inapplicable designation. 27 7.2 Manner and Timing of Designations. Except as otherwise 28 provided in this Order, or as otherwise stipulated or ordered, Disclosure of 1 Discovery Material that qualifies for protection under this Order must be 2 clearly so designated before the material is disclosed or produced. 3 Designation in conformity with this Order requires: 4 (a) for information in documentary form (e.g., paper or electronic 5 documents, but excluding transcripts of depositions or other pretrial or trial 6 proceedings), that the Producing Party affix at a minimum, the legend 7 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY 8 CONFIDENTIAL – ATTORNEY’S EYES ONLY” (hereinafter “HIGHLY 9 CONFIDENTIAL ATTORNEY’S EYES ONLY legend”), to each page that 10 contains protected material. If only a portion of the material on a page 11 qualifies for protection, the Producing Party also must clearly identify the 12 protected portion(s) (e.g., by making appropriate markings in the margins). 13 A Party or Non-Party that makes original documents available for 14 inspection need not designate them for protection until after the inspecting 15 Party has indicated which documents it would like copied and produced. 16 During the inspection and before the designation, all of the material made 17 available for inspection shall be deemed “CONFIDENTIAL” or “HIGHLY 18 CONFIDENTIAL – ATTORNEY’S EYES ONLY”. After the inspecting 19 Party has identified the documents it wants copied and produced, the 20 21 Producing Party must determine which documents, or portions thereof, qualify 22 for protection under this Order. Then, before producing the specified 23 documents, the Producing Party must affix the “CONFIDENTIAL legend” or 24 “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY legend” to 25 each page that contains Protected Material. If only a portion of the material on 26 a page qualifies for protection, the Producing Party also must clearly identify 27 the protected portion(s) (e.g., by making appropriate markings in the margins). 28 (b) for testimony given in depositions that the Designating Party 1 identifies the Disclosure or Discovery Material on the record, before the close 2 of the deposition all protected testimony. 3 (c) for information produced in some form other than 4 documentary and for any other tangible items, that the Producing Party affix 5 in a prominent place on the exterior of the container or containers in which the 6 information is stored the legend “CONFIDENTIAL” or “HIGHLY 7 CONFIDENTIAL ATTORNEY’S EYES ONLY.” If only a portion or 8 portions of the information warrants protection, the Producing Party, to the 9 extent practicable, shall identify the protected portion(s). 10 7.3 Inadvertent Failures to Designate. If timely corrected, an 11 inadvertent failure to designate qualified information or items does not, 12 standing alone, waive the Designating Party’s right to secure protection under 13 this Order for such material. Upon timely correction of a designation, the 14 Receiving Party must make reasonable efforts to assure that the material is 15 treated in accordance with the provisions of this Order. 16 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 17 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 18 designation of confidentiality at any time that is consistent with the Court’s 19 Scheduling Order. 20 21 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 22 resolution process under Local Rule 37-1 et seq. 23 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 24 joint stipulation pursuant to Local Rule 37-2. 25 8.4 The burden of persuasion in any such challenge proceeding shall be 26 on the Designating Party. Frivolous challenges, and those made for an 27 improper purpose (e.g., to harass or impose unnecessary expenses and burdens 28 on other parties) may expose the Challenging Party to sanctions. Unless the 1 Designating Party has waived or withdrawn the confidentiality designation, all 2 parties shall continue to afford the material in question the level of protection 3 to which it is entitled under the Producing Party’s designation until the Court 4 rules on the challenge. 5 9. ACCESS TO AND USE OF PROTECTED MATERIAL 6 9.1 Basic Principles. A Receiving Party may use Protected Material that 7 is disclosed or produced by another Party or by a Non-Party in connection 8 with this Action only for prosecuting, defending or attempting to settle this 9 Action. Such Protected Material may be disclosed only to the categories of 10 persons and under the conditions described in this Order. When the Action has 11 been terminated, a Receiving Party must comply with the provisions of section 12 15 below (FINAL DISPOSITION). 13 Protected Material must be stored and maintained by a Receiving Party 14 at a location and in a secure manner that ensures that access is limited to the 15 persons authorized under this Order. 16 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 17 otherwise ordered by the court or permitted in writing by the Designating 18 Party, a Receiving Party may disclose any information or item designated 19 “CONFIDENTIAL” only to: 20 21 (a) the Receiving Party’s Outside Counsel of Record in this 22 Action, as well as employees of said Outside Counsel of Record to whom it is 23 reasonably necessary to disclose the information for this Action; 24 (b) the officers, directors, and employees (including House 25 Counsel) of the Receiving Party to whom disclosure is reasonably necessary 26 for this Action; 27 (c) Experts (as defined in this Order) of the Receiving Party to 28 whom disclosure is reasonably necessary for this Action and who have signed 1 the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 2 (d) the court and its personnel; 3 (e) court reporters and their staff; 4 (f) professional jury or trial consultants, mock jurors, and 5 Professional Vendors to whom disclosure is reasonably necessary for this 6 Action and who have signed the “Acknowledgment and Agreement to Be 7 Bound” (Exhibit A); 8 (g) the author or recipient of a document containing the 9 information or a custodian or other person who otherwise possessed or knew 10 the information; 11 (h) during their depositions, witnesses, and attorneys for witnesses, 12 in the Action to whom disclosure is reasonably necessary provided: (1) the 13 deposing party requests that the witness sign the form attached as Exhibit A 14 hereto; and (2) they will not be permitted to keep any confidential information 15 unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit 16 A), unless otherwise agreed by the Designating Party or ordered by the court. 17 Pages of transcribed deposition testimony or exhibits to depositions that reveal 18 Protected Material may be separately bound by the court reporter and may not 19 be disclosed to anyone except as permitted under this Stipulated Protective 20 21 Order; and 22 (i) any mediators or settlement officers and their supporting 23 personnel, mutually agreed upon by any of the parties engaged in settlement 24 discussions. 25 9.3 Unless otherwise ordered by the Court or permitting in writing by 26 the Designating Party, a Receiving Party may disclose any information or item 27 designated “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” 28 only to persons identified in Sections 9.2(a) and 9.2(c)-(i) or this Order. 1 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED

PRODUCED IN OTHER LITIGATION

2

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

BE PRODUCED IN THIS LITIGATION

2

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

6 If a Receiving Party learns that, by inadvertence or otherwise, it has 7 disclosed Protected Material to any person or in any circumstance not 8 authorized under this Stipulated Protective Order, the Receiving Party must 9 immediately (a) notify in writing the Designating Party of the unauthorized 10 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the 11 Protected Material, (c) inform the person or persons to whom unauthorized 12 disclosures were made of all the terms of this Order, and (d) request such 13 person or persons to execute the “Acknowledgment an Agreement to Be 14 Bound” attached hereto as Exhibit A. 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 16

OTHERWISE PROTECTED MATERIAL

17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other 19 protection, the obligations of the Receiving Parties are those set forth in 20 21 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to 22 modify whatever procedure may be established in an e-discovery order that 23 provides for production without prior privilege review. Pursuant to Federal 24 Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on 25 the effect of disclosure of a communication or information covered by the 26 attorney-client privilege or work product protection, the parties may 27 incorporate their agreement in the stipulated protective order submitted to the 28 court. 1 14. MISCELLANEOUS 2 14.1 Right to Further Relief. Nothing in this Order abridges the right of 3 any person to seek its modification by the Court in the future. 4 14.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order, no Party waives any right it otherwise would have to object 6 to disclosing or producing any information or item on any ground not 7 addressed in this Stipulated Protective Order. Similarly, no Party waives any 8 right to object on any ground to use in evidence of any of the material covered 9 by this Protective Order. 10 14.3 Filing Protected Material. A Party that seeks to file under seal any 11 Protected Material must comply with Local Civil Rule 79-5. Protected 12 Material may only be filed under seal pursuant to a court order authorizing the 13 sealing of the specific Protected Material. If a Party’s request to file Protected 14 Material under seal is denied by the court, then the Receiving Party may file 15 the information in the public record unless otherwise instructed by the court. 16 15. FINAL DISPOSITION 17 After the final disposition of this Action, as defined in paragraph 6, 18 within 60 days of a written request by the Designating Party, each Receiving 19 Party must return all Protected Material to the Producing Party or destroy such 20 21 material. As used in this subdivision, “all Protected Material” includes all 22 copies, abstracts, compilations, summaries, and any other format reproducing 23 or capturing any of the Protected Material. Whether the Protected Material is 24 returned or destroyed, the Receiving Party must submit a written certification 25 to the Producing Party (and, if not the same person or entity, to the 26 Designating Party) by the 60-day deadline that (1) identifies (by category, 27 where appropriate) all the Protected Material that was returned or destroyed 28 and (2) affirms that the Receiving Party has not retained any copies, abstracts, 1 !}compilations, summaries or any other format reproducing or capturing any of 2 ||the Protected Material. Notwithstanding this provision, Counsel are entitled to 3 retain an archival copy of all pleadings, motion papers, trial, deposition, and 4 || hearing transcripts, legal memoranda, correspondence, deposition and trial > |] exhibits, expert reports, attorney work product, and consultant and expert 6 Il work product, even if such materials contain Protected Material. Any such || archival copies that contain or constitute Protected Material remain subject to 8 this Protective Order as set forth in Section 6 (DURATION). ° 16. VIOLATION 0 Any violation of this Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. 13 14 15 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 16 17 || DATED: June 08, 2023 18 i de 19 L hy ; a 20 J D. EARLY nited States Magistrate Judge 22 23 24 25 26 27 28 16

1 EXHIBIT A 2

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [full name], of _________________ 4 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 U.S. District 7 8 Court for the Central District of California on June 8, 2023, in the case of Alvantor 9 Industry Co., LTD. v. Shenzen Jorda Trading Co., LTD. et al., Case No. 2:22-cv- 10 04844-DOC-JPR. I agree to comply with and to be bound by all terms of this 11 12 Stipulated Protective Order, and I understand and acknowledge that failure to so 13 comply could expose me to sanctions and punishment, including contempt. I 14 15 solemnly promise that I will not disclose in any manner any information or item 16 that is subject to this Stipulated Protective Order to any person or entity except in 17 strict compliance with the provisions of this Order. 18 19 I further agree to submit to the jurisdiction of the U.S. District Court for the 20 Central District of California for the purpose of enforcing the terms of this 21 Stipulated Protective Order, even if such enforcement proceedings occur after 22 23 termination of this action. I hereby appoint __________________________ [full 24 name] of _______________________________________ [full address and 25 26 telephone number] as my California agent for service of process in connection with 27 28 1 this action or any proceedings related to enforcement of this Stipulated Protective 2 Order. 3

4 5 Date: ______________________________________ 6 City and State where signed: _________________________________ 7 8 Printed name: _______________________________ 9 Signature: _________________________________ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28