Merkamerica Inc. v. Dell Marketing LP

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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11 MERKAMERICA INC., a California corporation, Case No. 2:20-cv-05408-ODW 12 (RAOx) Plaintiff,

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v. 14 STIPULATED PROTECTIVE DELL MARKETING LP, a Texas 15 limited partnership, also known as ORDER1 DELL OUTLET; and DOES 1 through 16 100, inclusive,

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18 DELL MARKETING LP, a Texas limited partnership, 19 Counterclaimant, 20 vs. 21 MERKAMERICA INC., a California corporation, 22 Counterdefendant. 23 24 25 26

27 1 This Stipulated Protective Order is substantially based on the model protective 1 1. A. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 …