2 kJaesnonne tTh.. pLaarok e(rS@tahtea yBnaers bNooo. n2e8.c8o1m61 ) [email protected] 3 HAYNES AND BOONE, LLP 600 Anton Boulevard, Suite 700 4 Costa Mesa, California 92626 Telephone: (949) 202-3000 5 Facsimile: (949) 202-3001

6 William H. Frankel (IL Bar No. 3127933; admitted pro hac vice) 7 [email protected] Tadashi Horie (IL Bar No. 6256941; 8 admitted pro hac vice) [email protected] 9 Andrew S. McElligott (IL Bar No. 6317538; admitted pro hac vice) 10 [email protected] BRINKS GILSON & LIONE 11 455 N. Cityfront Plaza Drive, Suite 3600 Chicago, Illinois 60611 12 Telephone: (312) 321-4200 Facsimile: (312) 321-4299 13 Jieun Lee (VA Bar No. 92923; 14 admitted pro hac vice) [email protected] 15 BRINKS GILSON & LIONE 1775 Pennsylvania Ave. NW, Suite 900 16 Washington, DC 20006 Telephone: (202) 296-8700 17 Facsimile: (202) 296-8701

18 Attorneys for Plaintiff Panasonic Corporation

19 UNITED STATES DISTRICT COURT 20 CENTRAL DISTRICT OF CALIFORNIA 21

22 PANASONIC CORPORATION, Case No.: 8:19-cv-01118-DOC-DFM 23 Hon. Judge David O. Carter Plaintiff, 24 [Discovery Document: Referred to vs. Magistrate Judge Douglas F. 25 McCormick] GETAC TECHNOLOGY 26 CORPORATION and GETAC, INC., STIPULATED PROTECTIVE 27 ORDER Defendants. 28 1 1. PURPOSES AND LIMITATIONS 2 The parties agree that discovery in this action is likely to involve production 3 of confidential, proprietary or private information for which special protection 4 from public disclosure and from use for any purpose other than pursuing this 5 litigation may be warranted (collectively “Protected Material” as defined below). 6 Accordingly, the parties hereby stipulate to and petition the Court to enter the 7 following Stipulated Protective Order (“Order”). The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. 12 2. GOOD CAUSE STATEMENT 13 This action is likely to involve trade secrets, customer and pricing lists and 14 other valuable and competitively sensitive research, marketing, development, 15 commercial, financial, technical and/or other proprietary information for which 16 special protection from public disclosure and from use for any purpose other than 17 prosecution of this action is warranted. Such confidential and proprietary materials 18 and information consist of, among other things, confidential business or financial 19 information, information regarding confidential business practices, information 20 regarding proprietary product developments, or other confidential research, 21 development, or commercial information (including information implicating 22 privacy rights), information otherwise generally unavailable to the public, or which 23 may be privileged or otherwise protected from disclosure under state or federal 24 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 25 flow of information, to facilitate the prompt resolution of disputes over 26 confidentiality of discovery materials, to adequately protect information the parties 27 are entitled to keep confidential, to ensure that the parties are permitted reasonably 28 necessary uses of such material in preparation for and in the conduct of trial, to 1 address their handling at the end of the litigation, and serve the ends of justice, a 2 protective order for such information is justified in this matter. It is the intent of 3 the parties that information will not be designated as confidential for tactical 4 reasons in this case and that nothing be so designated without a good faith belief 5 that there is good cause why it should not be part of the public record of this case. 6 Unrestricted or unprotected disclosure of confidential information, such as 7 product specifications, design history files, financial information, sales 8 information, business and marketing strategy, or information concerning business 9 operations would result in prejudice or harm to the producing party by revealing 10 the producing party’s competitive confidential information, which has been 11 developed at the expense of the producing party and which represents valuable 12 tangible and intangible assets of that party. Additionally, privacy interests must be 13 safeguarded. Accordingly, the parties respectfully submit that there is good cause 14 for the entry of this Protective Order. 15 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE 16 The parties further acknowledge, as set forth in Section 14.3, below, that this 17 Stipulated Protective Order does not entitle them to file confidential information 18 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 19 and the standards that will be applied when a party seeks permission from the court 20 to file material under seal. There is a strong presumption that the public has a right 21 of access to judicial proceedings and records in civil cases. In connection with 22 non-dispositive motions, good cause must be shown to support a filing under seal. 23 See Kamakana v. City and County of Honolulu,

(9th Cir. 24 2006), Phillips v. Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), 25 Makar-Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 1999) 26 (even stipulated protective orders require good cause showing), and a specific 27 showing of good cause or compelling reasons with proper evidentiary support and 28 legal justification, must be made with respect to Protected Material that a party 1 seeks to file under seal. The parties’ mere designation of Disclosure or Discovery 2 Material as CONFIDENTIAL does not— without the submission of competent 3 evidence by declaration, establishing that the material sought to be filed under seal 4 qualifies as confidential, privileged, or otherwise protectable—constitute good 5 cause. 6 Further, if a party requests sealing related to a dispositive motion or trial, 7 then compelling reasons, not only good cause, for the sealing must be shown, and 8 the relief sought shall be narrowly tailored to serve the specific interest to be 9 protected. See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 10 2010). For each item or type of information, document, or thing sought to be filed 11 or introduced under seal, the party seeking protection must articulate compelling 12 reasons, supported by specific facts and legal justification, for the requested sealing 13 order. Again, competent evidence supporting the application to file documents 14 under seal must be provided by declaration. 15 Any document that is not confidential, privileged, or otherwise protectable 16 in its entirety will not be filed under seal if the confidential portions can be 17 redacted. If documents can be redacted, then a redacted version for public 18 viewing, omitting only the confidential, privileged, or otherwise protectable 19 portions of the document, shall be filed. Any application that seeks to file 20 documents under seal in their entirety should include an explanation of why 21 redaction is not feasible. 22 4. DEFINITIONS 23 The following terms shall have the following meanings in this Order: 24 4.1 Action: Panasonic Corp. v. Getac Technology Corp., et al., Case No. 25 8:19-cv-01118-DOC-DFM (C.D. Cal.) and related cross-action. 26 4.2 Challenging Party: a Party or Non-Party that challenges the 27 designation of information or items under this Order. 28 1 4.3 “Confidential” Information or Items: information (regardless of how 2 generated, stored or maintained) or items not generally known to others, and that 3 (i) the Designating Party would not normally reveal to third parties except in 4 confidence, or has undertaken with others to maintain in confidence; or (ii) are 5 protected by a right to privacy under federal or state law, or any other applicable 6 privilege or right related to confidentiality or privacy. “Confidential” Information 7 or Items may include any form of trade secret or other confidential research, 8 development, or commercial information within the meaning of Fed. R. Civ. P. 9 26(c)(1)(G). 10 4.4 Counsel: Outside Counsel and In-House Counsel (as well as their 11 support staff). 12 4.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as “Confidential” 14 or “Highly Confidential – Outside Attorneys’ Eyes Only.” 15 4.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced 18 or generated in disclosures or responses to discovery. 19 4.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve 21 as an expert witness or as a consultant in this Action. 22 4.8 “Highly Confidential – Outside Attorneys’ Eyes Only” Information or 23 Items: highly sensitive “Confidential” Information or Items, the disclosure of 24 which to another Party or Non-Party would create a substantial risk of competitive 25 injury to the Designating Party, as defined herein. “Highly Confidential – Outside 26 Attorneys’ Eyes Only” designations are to be used for sensitive technical, 27 financial, competitive, or personnel information, which is not known by third 28 parties and that the Designating Party would not normally reveal to third parties or 1 would require third parties to maintain in confidence by agreements, policies, or 2 procedures. 3 4.9 In-House Counsel: attorneys who are employees, contractors, or 4 consultants of a Party for general purposes in addition to this specific Action. In- 5 House Counsel does not include Outside Counsel or any other outside counsel. 6 4.10 Non-Party: any natural person, partnership, corporation, association, 7 or other legal entity not named as a Party to this Action. 8 4.11 Outside Counsel: attorneys who are not employees of a party to this 9 Action but are retained to represent a party to this Action and have appeared in this 10 Action on behalf of that party or are affiliated with a law firm that has appeared on 11 behalf of that party, and includes support staff. 12 4.12 Party: any party to this Action, including all of its officers, directors, 13 employees, consultants, and Outside Counsel (and their support staffs). 14 4.13 Professional Vendors: persons or entities that provide litigation 15 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 16 demonstrations, trial support, trial consulting services, and organizing, storing, or 17 retrieving data in any form or medium) and their employees and subcontractors. 18 4.14 Protected Material: any Disclosure or Discovery Material that is 19 designated as “Confidential” or “Highly Confidential – Outside Attorneys’ Eyes 20 Only,” including any information copied or extracted from Protected Material, and 21 all copies, excerpts, summaries, or compilations of Protected Material. 22 4.15 Receiving Party: a Party that receives Disclosure or Discovery 23 Material from a Designating Party. 24 5. SCOPE 25 The protections conferred by this Order cover not only Protected Material 26 (as defined above), but also (1) any information copied or extracted from Protected 27 Material; (2) all copies, excerpts, summaries, or compilations of Protected 28 1 Material; and (3) any testimony, conversations, or presentations by Parties or their 2 Counsel that might reveal Protected Material. 3 Any use of Protected Material at trial shall be governed by the orders of the 4 trial judge or a separate agreement between the parties. Except where so stated, 5 this Order does not govern the use of Protected Material at trial. 6 The protections conferred by this Order do not cover: (i) any information 7 that is in the public domain at the time of disclosure to a Receiving Party or 8 becomes part of the public domain after its disclosure to a Receiving Party as a 9 result of publication not involving a violation of this Order, unless the publication 10 was inadvertent; and (ii) any information known to the Receiving Party prior to the 11 disclosure or obtained by the Receiving Party after the disclosure from a Non-Party 12 without restriction as to disclosure, provided such Non-Party has the right to make 13 the disclosure to the Receiving Party. 14 6. DURATION 15 Even after final disposition of this Action, the confidentiality obligations 16 imposed by this Order shall remain in effect until a Designating Party agrees 17 otherwise in writing or a court order otherwise directs. Final disposition shall be 18 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 19 with or without prejudice; and (2) final judgment herein after the completion and 20 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 21 including the time limits for filing any motions or applications for extension of 22 time pursuant to applicable law. 23 7. DESIGNATING PROTECTED MATERIAL 24 7.1 Exercise of Restraint and Care in Designating Material for Protection. 25 Each Party or Non-Party that designates information or items for protection under 26 this Order must take care to limit any such designation to specific material that 27 qualifies under the appropriate standards. The Designating Party must designate 28 for protection only that material, documents, items or oral or written 1 communications that qualify so that other material, documents, items or 2 communications for which protection is not warranted are not swept unjustifiably 3 within the ambit of this Order. 4 Mass, indiscriminate or routinized designations are prohibited. Designations 5 that are shown to be clearly unjustified or that have been made for an improper 6 purpose (e.g., to unnecessarily encumber the case development process or to 7 impose unnecessary expenses and burdens on other parties) may expose the 8 Designating Party to sanctions. 9 If it comes to a Designating Party’s attention that information or items that it 10 designated for protection do not qualify for protection, that Designating Party must 11 promptly notify all other Parties that it is withdrawing the inapplicable designation. 12 7.2 Manner and Timing of Designations. Except as otherwise provided in 13 this Order, or as otherwise stipulated or ordered, Protected Material must be 14 designated before the material is disclosed or produced. 15 Designation in conformity with this Order requires: 16 (a) for information in documentary form (e.g., paper or electronic 17 documents, but excluding transcripts of depositions or other pretrial or trial 18 proceedings), that the Designating Party affix the applicable legend 19 (“Confidential” or “Highly Confidential – Outside Attorneys’ Eyes Only”) on each 20 page. 21 A Party or Non-Party that makes original documents or materials available 22 for inspection need not designate them for protection until after the inspecting 23 Party has indicated which documents it would like copied and produced. During 24 the inspection and before the designation, all of the materials made available for 25 inspection shall be deemed “Highly Confidential – Outside Attorneys’ Eyes Only.” 26 There will be no waiver of confidentiality by the inspection of documents or items 27 before they are copied and designated pursuant to this Order. After the Receiving 28 Party has identified the documents it wants copied and produced, before producing 1 these documents, the Designating Party must affix the applicable legend 2 (“Confidential” or “Highly Confidential – Outside Attorneys’ Eyes Only”) on 3 each. 4 (b) for testimony given in depositions, the Designating Party (or the 5 Party or Non-Party whose confidential information is being disclosed by the 6 deponent) may identify the specific portions of the testimony and exhibits as to 7 which protection is sought at the time of the testimony, alternatively if no 8 protective designation of testimony or any exhibits is made during a deposition the 9 transcript of the deposition and all exhibits and attachments shall be considered 10 “Highly Confidential – Outside Attorneys’ Eyes Only” until the deadline for the 11 errata sheet. During that period, either Party may designate the portions of the 12 transcript and any specific exhibits or attachments that are to be treated as 13 protected by electing the appropriate designation of “Confidential” or “Highly 14 Confidential – Outside Attorneys’ Eyes Only.” If a Party elects to apply any 15 designations as described herein, that Party shall advise the other Parties and the 16 stenographer and/or videographer of the specific portions and/or exhibits and the 17 proposed designations in writing, before the deadline for the errata sheet. If no 18 such designations are made, then the entire transcript and exhibits and attachments 19 will be considered unprotected. 20 (c) for information produced in some form other than documentary 21 and for any other tangible items, that the Designating Party affix in a prominent 22 place on the exterior of the container or containers in which the information is 23 stored the applicable legend (“Confidential” or “Highly Confidential – Outside 24 Attorneys’ Eyes Only”). If only a portion or portions of the information warrants 25 protection, the Designating Party, to the extent practicable, shall identify the 26 protected portion(s). 27 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 28 failure to designate Protected Material does not, standing alone, waive the 1 Designating Party’s right to secure protection under this Order for such material. 2 Upon timely correction of a designation, the Receiving Party must make 3 reasonable efforts to assure that the Protected Material is treated in accordance 4 with the provisions of this Order, including seeking the return or destruction of any 5 material previously disclosed. 6 7.4 Inadvertent Production of Work Product or Privileged Information. 7 Consistent with Federal Rule of Evidence 502, the inadvertent production of any 8 information claimed to be subject to the attorney-client privilege, the work-product 9 doctrine, or any other privilege is not a waiver of that privilege, so long as the 10 holder of the privilege took reasonable steps to prevent disclosure and took 11 reasonable steps to rectify the error upon discovery of such error. Upon reasonably 12 prompt written request of the Designating Party, the Receiving Party shall return or 13 destroy the information and any copies it has within five (5) business days of 14 receiving such written request; must not use or disclose the information until the 15 claim is resolved; must take reasonable steps to retrieve the information if the 16 Receiving Party disclosed it before being notified; and, notwithstanding the 17 foregoing, the Receiving Party’s Outside Counsel may retain, in a secure location, 18 one copy of the information for the sole purpose of challenging the assertion of 19 privilege or work product. If the Receiving Party disagrees with the designation of 20 the information as privileged or otherwise protected after conferring with the 21 Designating Party in good faith, the Receiving Party may move the Court for 22 production of the returned documents or materials. If the Court upholds the 23 Designating Party’s claim, the Receiving Party shall return or destroy the 24 information no later than two (2) business days from the Court’s ruling. If the 25 Receiving Party does not file a motion within fifteen (15) days after conferring 26 with the Designating Party, the Receiving Party shall return or destroy the 27 information. 28 1 7.5 Non-Party Designations. A Non-Party may designate as 2 “Confidential” or “Highly Confidential – Outside Attorneys’ Eyes Only,” pursuant 3 to this Order, any document, material, information or testimony produced by the 4 Non-Party during discovery in this case. 5 7.6 Requests for Identification of Specific Protected Material. To 6 facilitate use of confidential information and compliance with the Court’s rules 7 regarding filing under seal, while still encouraging full and efficient production of 8 documents, the Receiving Party may request the Designating Party identify with 9 particularity (i.e. by pages and the specific material on those pages) the material in 10 documents designated under the Order that it considers to be Protected Material. 11 The Designating Party shall provide a response within 5 business days, which may 12 be extended by agreement of the Parties, that indicates which pages in the 13 document, and which portion of the material on those pages, contains Protected 14 Material. The Designating Party also must clearly identify the protected portion(s) 15 (e.g., by making appropriate markings in the margins). 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 8.2 Meet and Confer. The Party or Non-Party challenging confidentiality 21 designations must serve on the Designating Party a written objection to the 22 designation, describing with particularity the document or information in question 23 and the grounds for objection. The Designating Party must respond in writing to 24 the objection within seven (7) days, stating with particularity the grounds for 25 asserting that the document or information is “Confidential” or “Highly 26 Confidential – Outside Attorneys’ Eyes Only.” Counsel for the Designating and 27 challenging Parties and/or Non-Party, shall meet and confer by phone within five 28 (5) business days of such response. If unable to settle their differences in the meet 1 and confer conference, the challenging Party shall initiate the dispute resolution 2 process under Local Rule 37-1 et seq. 3 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 4 joint stipulation pursuant to Local Rule 37-2. 5 8.4 The burden of persuasion in any such challenge proceeding shall be 6 on the Designating Party. Frivolous challenges, and those made for an improper 7 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 8 parties) may expose the Challenging Party to sanctions. Unless the Designating 9 Party has waived or withdrawn the confidentiality designation, all parties shall 10 continue to afford the material in question the level of protection to which it is 11 entitled under the Designating Party’s designation until the Court rules on the 12 challenge. 13 9. ACCESS TO AND USE OF PROTECTED MATERIAL 14 9.1 Basic Principles. A Receiving Party may use Protected Material that 15 is disclosed or produced by another Party or by a Non-Party in connection with this 16 Action only for prosecuting, defending or attempting to settle this Action. Such 17 Protected Material may be disclosed only to the categories of persons and under 18 the conditions described in this Order. Protected Material must be stored and 19 maintained by a Receiving Party at a location and in a secure manner that ensures 20 compliance with this Order. When the Action has been terminated, a Receiving 21 Party must comply with the provisions of section 14 below (FINAL 22 DISPOSITION). 23 9.2 Disclosure of “Confidential” Information or Items. Unless otherwise 24 ordered by the court or permitted in writing by the Designating Party, a Receiving 25 Party may disclose any information or item designated “Confidential” only to: 26 (a) the Receiving Party’s Outside Counsel in this Action, as well as 27 employees of said Outside Counsel to whom it is reasonably necessary to disclose 28 the information for this Action; 1 (b) Up to three (3) officers, directors, and employees (including In- 2 House Counsel) of the Receiving Party to whom disclosure is reasonably necessary 3 for prosecution or defense of this Action, and who execute the “Acknowledgment 4 and Agreement to Be Bound” (Exhibit A); 5 (c) Authorized Experts (as defined in this Order in para. 9.4(b)) of the 6 Receiving Party to whom disclosure is reasonably necessary for this Action and 7 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 8 (d) the Court and its support personnel, jurors, and court reporters in 9 this Action; 10 (e) Professional Vendors to whom disclosure is reasonably necessary 11 for this Action and who have signed the “Acknowledgment and Agreement to Be 12 Bound” (Exhibit A); 13 (f) any designated mediator who is assigned to hear this Action, or 14 who has been selected by the Parties, and his or her supporting personnel; 15 (g) the author or recipient of a document, or the original source of the 16 information or any person who has already seen the document or information 17 (unless that source or person has only seen or had possession of the document or 18 information in violation of this Order or another court order); and 19 (h) any person designated by mutual agreement of the parties who has 20 executed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 21 9.3 Disclosure of “Highly Confidential – Outside Attorneys’ Eyes Only” 22 Information or Items. Unless otherwise ordered by the court or permitted in 23 writing by the Designating Party, a Receiving Party may disclose any information 24 or item designated “Highly Confidential – Outside Attorneys’ Eyes Only” only to: 25 (a) the Receiving Party’s Outside Counsel in this Action, as well as 26 employees of said Outside Counsel to whom it is reasonably necessary to disclose 27 the information for this Action; 28 1 (b) Authorized Experts (as defined in this Order in para. 9.4(b)) of the 2 Receiving Party to whom disclosure is reasonably necessary for this Action and 3 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 4 (c) the Court and its support personnel, jurors, and court reporters in 5 this Action; 6 (d) Professional Vendors to whom disclosure is reasonably necessary 7 for this Action and who have signed the “Acknowledgment and Agreement to Be 8 Bound” (Exhibit A); 9 (e) any designated mediator who is assigned to hear this Action, or 10 who has been selected by the Parties, and his or her supporting personnel; 11 (f) the author or recipient of a document, or the original source of the 12 information or any person who has already seen the document or information 13 (unless that source or person has only seen or had possession of the document or 14 information in violation of this Order or another court order); and 15 (g) any person designated by mutual agreement of the parties who has 16 executed the “Acknowledgment and Agreement to Be Bound” (Exhibit A). 17 9.4 Procedures for Approving Disclosure Of “Confidential” or “Highly 18 Confidential – Outside Attorneys’ Eyes Only” Information or Items to Experts. 19 (a) Unless otherwise ordered by the Court or agreed in writing by 20 the Designating Party, a Receiving Party that seeks to disclose to an Expert any 21 information or item that has been designated “Confidential” or “Highly 22 Confidential – Outside Attorneys’ Eyes Only,” first must ensure the Expert has no 23 conflicts with the representation, and make a written request to the Designating 24 Party seeking permission to disclose such information to the Expert. The written 25 request shall include an executed copy of the Expert’s “Acknowledgment and 26 Agreement to Be Bound” (Exhibit A), a current curriculum vitae, and a description 27 of the Expert’s testifying and litigation consulting engagements within the past 28 four (4) years, including an identification of the party on whose behalf the Expert 1 was retained in such engagements. This written request is not required for the 2 Expert’s staff. The Expert, however, shall take full responsibility to ensure that 3 staff members working under his or her supervision comply with the terms of the 4 Protective Order. 5 (b) An Expert that has complied with the requirements of the 6 preceding paragraph shall be deemed an Authorized Expert; unless, within five (5) 7 business days of delivering the request, the Requesting Party receives a written 8 objection from the Designating Party. Any such objection must set forth in detail 9 the grounds on which it is based. 10 (c) A Receiving Party that receives a timely written objection must 11 meet and confer with the Designating Party to try and resolve the matter by 12 agreement. If no agreement is reached, then the Designating Party shall initiate the 13 dispute resolution process under Local Rule 37-1 et seq. 14 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 15 PRODUCED IN OTHER LITIGATION 16 If a Receiving Party is served with a subpoena or a court order issued in 17 other litigation that compels disclosure of any Protected Material, the Receiving 18 Party must: 19 (a) promptly notify in writing the Designating Party. Such 20 notification shall include a copy of the subpoena or court order; 21 (b) promptly notify in writing the party who caused the subpoena or 22 order to issue in the other litigation that some or all of the material covered by the 23 subpoena or order is subject to this Protective Order. Such notification shall 24 include a copy of this Stipulated Protective Order; and 25 (c) cooperate with respect to all reasonable procedures sought to be 26 pursued by the Designating Party whose Protected Material may be affected. If the 27 Designating Party timely seeks a protective order, the Party served with the 28 subpoena or court order shall not produce any Protected Material before a 1 determination on the protective order by the court from which the subpoena or 2 order issued, unless the Party has obtained the Designating Party’s permission. 3 The Designating Party shall bear the burden and expense of seeking protection in 4 that court of its confidential material and nothing in these provisions should be 5 construed as authorizing or encouraging a Receiving Party in this Action to 6 disobey a lawful directive from another court. 7 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 8 BE PRODUCED IN THIS LITIGATION 9 (a) The terms of this Order are applicable to information produced by 10 a Non-Party in this Action and designated as “Confidential” or “Highly 11 Confidential – Outside Attorneys’ Eyes Only.” Such information produced by 12 Non-Parties in connection with this litigation is protected by the remedies and 13 relief provided by this Order. Nothing in these provisions should be construed as 14 prohibiting a Non-Party from seeking additional protections. 15 (b) In the event that a Party is required, by a valid discovery request, 16 to produce a Non-Party’s confidential information in its possession, and the Party 17 is subject to an agreement with the Non-Party not to produce the Non-Party’s 18 confidential information, then the Party shall: 19 (1) promptly notify in writing the Requesting Party and the 20 Non- Party that some or all of the information requested is subject to a 21 confidentiality agreement with a Non-Party; 22 (2) promptly provide the Non-Party with a copy of the 23 Stipulated Protective Order in this Action, the relevant discovery request(s), and a 24 reasonably specific description of the information requested; and 25 (3) make the information requested available for inspection by 26 the Non-Party, if requested. 27 (c) If the Non-Party fails to seek a protective order from this court 28 within 14 days of receiving the notice and accompanying information, the 1 Receiving Party may produce the Non-Party’s confidential information responsive 2 to the discovery request. If the Non-Party timely seeks a protective order, the 3 Receiving Party shall not produce any information in its possession or control that 4 is subject to the confidentiality agreement with the Non-Party before a 5 determination on the protective order by the court. Absent a court order to the 6 contrary, the Non-Party shall bear the burden and expense of seeking protection in 7 this court of its Protected Material. 8 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 9 MATERIAL 10 If a Receiving Party learns that, by inadvertence or otherwise, it has 11 disclosed Protected Material to any person or in any circumstance not authorized 12 under this Stipulated Protective Order, the Receiving Party must immediately 13 (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use 14 its best efforts to retrieve all unauthorized copies of the Protected Material, 15 (c) inform the person or persons to whom unauthorized disclosures were made of 16 all the terms of this Order, and (d) request such person or persons to execute the 17 “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A. 18 13. MISCELLANEOUS 19 13.1 Right to Further Relief. Nothing in this Order abridges the right of 20 any Party or person to seek its modification by the Court in the future. 21 13.2 Right to Assert Other Objections. By stipulating to the entry of this 22 Order, no Party waives any right it otherwise would have to object to disclosing or 23 producing any information or item. Similarly, no Party waives any right to object 24 on any ground to use in evidence of any of the Protected Material covered by this 25 Order. 26 13.3 Filing Protected Material. A Party that seeks to file under seal any 27 Protected Material must comply with Local Civil Rule 79-5. Protected Material 28 may only be filed under seal pursuant to a court order authorizing the sealing of the 1 specific Protected Material. If a Party’s request to file Protected Material under 2 seal is denied by the court, then the Receiving Party may file the information in the 3 public record unless otherwise instructed by the court. 4 13.4 Right to Advise Client. Nothing in this Order shall restrict Outside 5 Counsel from advising its client with respect to this action. In giving such advice, 6 Outside Counsel may rely upon an examination of Protected Material. Unless 7 otherwise authorized by this Order, Outside Counsel, however, shall not disclose 8 the contents of any Protected Material to its client. 9 13.5 Non-Parties. The terms of this Order shall be applicable to any Non- 10 Party that produces information which is designated by such Non-Party as 11 “Confidential” or “Highly Confidential – Attorneys’ Eyes Only.” 12 13.6 Prosecution Bar. Any person reviewing any of another party’s 13 “Highly Confidential – Attorneys’ Eyes Only” material of a technical nature shall 14 not, for a period commencing upon receipt of such information and ending two 15 years following the conclusion of this case (including any appeals), be involved in 16 the prosecution of design or utility patents or patent applications relating to 17 personal computers, laptop computers, tablets, or “2-in-1s” on behalf of the 18 receiving party or its acquirer, successor, predecessor, or other affiliate, including 19 without limitation the patents asserted in this action and any patent or application 20 claiming priority to or otherwise related to the patents asserted in this action, 21 before any foreign or domestic agency, including the United States Patent and 22 Trademark Office (“the Patent Office”). For purposes of this paragraph, 23 “prosecution” includes directly or indirectly drafting, amending, advising, or 24 otherwise affecting the scope or maintenance of patent claims. For the avoidance 25 of doubt, persons receiving Highly Confidential –Attorneys’ Eyes Only” material 26 are not prohibited from participating in any patent opposition, reissue, inter partes 27 review, post grant review or reexamination proceedings, provided that such 28 persons shall not participate in the drafting or amending of patent claims in any 1 such proceedings. To ensure compliance with the purpose of this provision, each 2 party shall create an “Ethical Wall” between those persons with access to “Highly 3 Confidential – Attorneys’ Eyes Only” material of a technical nature and any 4 individuals who, on behalf of the party or its acquirer, successor, predecessor, or 5 other affiliate, directly or indirectly draft, amend, advise, or otherwise affect the 6 scope or maintenance of patent claims relating to personal computers, laptop 7 computers, tablets, or “2-in-1s,” including without limitation the patents asserted in 8 this action and any patent or application claiming priority to or otherwise related to 9 the patents asserted in this action, before any foreign or domestic agency, including 10 the Patent Office. The parties expressly agree that the prosecution bar set forth 11 herein shall be personal to any attorney who received “Highly Confidential – 12 Attorneys’ Eyes Only” material and shall not be imputed to any other persons or 13 attorneys at the attorney’s law firm. 14 14. FINAL DISPOSITION 15 Unless otherwise ordered or agreed in writing by the Designating Party, 16 within 60 days after the termination of this action, each Receiving Party must 17 return all Protected Material to the Designating Party or destroy such material. As 18 used in this subdivision, “all Protected Material” includes all copies, abstracts, 19 compilations, summaries, and any other format reproducing or capturing any of the 20 Protected Material. Whether the Protected Material is returned or destroyed, the 21 Receiving Party must submit a written certification to the Designating Party by the 22 60-day deadline that (1) identifies (by category, where appropriate) all the 23 Protected Material that was returned or destroyed and (2) affirms that the 24 Receiving Party has not retained any copies, abstracts, compilations, summaries or 25 any other format reproducing or capturing any of the Protected Material. 26 Notwithstanding this provision, Counsel are entitled to retain an archival copy of 27 all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 28 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney 1 || work product, and consultant and expert work product, even if such materials 2 || contain Protected Material. Any such archival copies that contain or constitute 3 || Protected Material remain subject to this Order. 4 15. VIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 || including, without limitation, contempt proceedings and/or monetary sanctions. 7 || STIPULATED BY: 8 || Dated: February 26, 2020 HAYNES AND BOONE, LLP 10 By: _/s/Kenneth G. Parker Kenneth G. Parker 1] Jason T. Lao 0 HAYNES AND BOONE, LLP William H. Frankel 13 Tadashi Horie Andrew S. McElligott 14 Jieun Lee 15 BRINKS GILSON & LIONE

16 Attorneys for Plaintiff Panasonic Corporation 17 18 || Dated: February 26, 2020 KING & SPALDING LLP 19 20 By: /s/Joseph N. Akrotirianakis Christopher C. Campbell 21 Joseph N. Akrotirianakis 22 Attorneys for Defendants Getac 73 Technology Corporation & Getac, Inc. IT IS SO ORDERED. 24 25 DATED: February 28, 2020 26 * 27 Hon. Douglas F. McCormick 28 United States Magistrate Judge

20 DTTT ATED DPATECTIVE OPMREP

1 EXHIBIT A 2 AGREEMENT TO BE BOUND BY PROTECTIVE ORDER 3 4 Panasonic Corp. v. Getac Technology Corp., et al., 5 No. 8:19-cv-01118-DOC-DFM (C.D. Cal.) 6 7 I ____________________________, declare as follows: 8 1. My address is ______________________________________________. 9 2. I am presently employed as _______________________________ by 10 __________________________________________. 11 3. I have received a copy of the Stipulated Protective Order entered in 12 the above action on ___________________, 2019 (the “Protective Order”). I have 13 carefully read and understand the provisions of the Protective Order, and agree to 14 comply with and to be bound by all of its terms. 15 4. I will hold in confidence, and use any and all Protected Material only 16 to the extent permitted by the Protective Order. 17 5. I will return all Protected Material that comes into my possession, 18 custody, or control to Outside Counsel for the party by whom I am employed or 19 retained. 20 6. I understand that any violation of the Protective Order may subject me 21 to sanctions by the Court, civil liabilities, criminal liabilities, or any combination of 22 the above. 23 24 7. I submit to the jurisdiction of this Court for the purposes of 25 enforcement of the Protective Order. 26 // 27 // 28 // 1 I declare under penalty of perjury under the laws of the United States of 2 America that the foregoing is true and correct. 3 Executed on _________________, ______, at _______________________. 4

5 ______________________________ 6 7 ______________________________ 8 Print Name and Sign 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28