Fareportal, Inc. v. HNA Group (International) Co., LTD.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 FAREPORTAL, INC., Case No. 21-cv-02841-YGR (TSH)

Plaintiff,

DISCOVERY ORDER

v. Re: Dkt. No. 82 HNA GROUP (INTERNATIONAL) CO., LTD., et al., 11 Defendants. 12 Plaintiff Fareportal, Inc., and Defendant Nishith Kumar have a filed a joint discovery letter brief concerning a dispute they have over a potential protective order. ECF No. 82. Fareportal proposed that the parties stipulate to the Northern District of California’s Model Protective Order for Litigation Involving Patents, Highly Sensitive Confidential Information and/or Trade Secrets (the “Model Order,” which can be found here: https://cand.uscourts.gov/forms/model-protective- orders/). Unmodified, the Model Order would not allow an unrepresented party any access to information designated HC-AEO or HC-Source Code, which would be a problem for Kumar because is pro se. In an effort to accommodate Kumar, Fareportal proposed language that would allow an unrepresented party to retain outside counsel for the…