1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 12 KLAUBER BROTHERS, INC. Case No. 2:20-cv-07430-AB-AFM 13 Plaintiff, 14 v. STIPULATED PROTECTIVE 15 ORDER1 16 URBAN OUTFITTERS, INC.; et al., 17 Defendants. 18 19 1. A. PURPOSES AND LIMITATIONS 20 Discovery in this action is likely to involve production of confidential, 21 proprietary or private information for which special protection from public disclosure 22 and from use for any purpose other than prosecuting this litigation may be warranted. 23 Accordingly, the parties hereby stipulate to and petition the Court to enter the following 24 Stipulated Protective Order. The parties acknowledge that this Order does not confer 25 blanket protections on all disclosures or responses to discovery and that the protection 26 27 1 This Stipulated Protective Order is based substantially on the model protective order 1 it affords from public disclosure and use extends only to the limited information or 2 items that are entitled to confidential treatment under the applicable legal principles. 3 B. GOOD CAUSE STATEMENT 4 This action is likely to involve trade secrets, customer and pricing lists and other 5 valuable research, development, commercial, financial, technical and/or proprietary 6 information for which special protection from public disclosure and from use for any 7 purpose other than prosecution of this action is warranted. Such confidential and 8 proprietary materials and information consist of, among other things: 9 (a) Information that is the subject of a non-disclosure or confidentiality 10 agreement or obligation; 11 (b) The names, or other information tending to reveal the identity of a 12 party’s supplier, designer, distributor, or customer; 13 (c) Agreements with third-parties, including license agreements, 14 distributor agreements, manufacturing agreements, design agreements, development 15 agreements, supply agreements, sales agreements, or service agreements; 16 (d) Research and development information; 17 (e) Proprietary engineering or technical information, including product 18 design, manufacturing techniques, processing information, drawings, memoranda and 19 reports; 20 (f) Information related to budgets, sales, profits, costs, margins, 21 licensing of technology or designs, product pricing, or other internal 22 financial/accounting information, including non-public information related to financial 23 condition or performance and income or other non-public tax information; 24 (g) Information related to internal operations including personnel 25 information; 26 (h) Information related to past, current and future product 27 development; 1 (i) Information related to past, current and future market analyses and 2 business and marketing development, including plans, strategies, forecasts and 3 competition; and 4 (j) Trade secrets (as defined by the jurisdiction in which the 5 information is located). 6 Accordingly, to expedite the flow of information, to facilitate the prompt 7 resolution of disputes over confidentiality of discovery materials, to adequately protect 8 information the parties are entitled to keep confidential, to ensure that the parties are 9 permitted reasonable necessary uses of such material in preparation for and in the 10 conduct of trial, to address their handling at the end of the litigation, and serve the ends 11 of justice, a protective order for such information is justified in this matter. It is the 12 intent of the parties that information will not be designated as confidential for tactical 13 reasons and that nothing be so designated without a good faith belief that it has been 14 maintained in a confidential, non-public manner, and there is good cause why it should 15 not be part of the public record of this case. 16 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 17 The parties further acknowledge, as set forth in Section 12.3, below, that this 18 Stipulated Protective Order does not entitle them to file confidential information under 19 seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and the 20 standards that will be applied when a party seeks permission from the court to file 21 material under seal. 22 There is a strong presumption that the public has a right of access to judicial 23 proceedings and records in civil cases. In connection with non-dispositive motions, 24 good cause must be shown to support a filing under seal. See Kamakana v. City and 25 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 26 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 27

(E.D. Wis. 1999) (even stipulated protective orders require good 1 proper evidentiary support and legal justification, must be made with respect to 2 Protected Material that a party seeks to file under seal. The parties’ mere designation 3 of Disclosure or Discovery Material as CONFIDENTIAL does not— without the 4 submission of competent evidence by declaration, establishing that the material sought 5 to be filed under seal qualifies as confidential, privileged, or otherwise protectable— 6 constitute good cause. 7 Further, if a party requests sealing related to a dispositive motion or trial, then 8 compelling reasons, not only good cause, for the sealing must be shown, and the relief 9 sought shall be narrowly tailored to serve the specific interest to be protected. See 10 Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2010). For each item 11 or type of information, document, or thing sought to be filed or introduced nder seal in 12 connection with a dispositive motion or trial, the party seeking protection must 13 articulate compelling reasons, supported by specific facts and legal justification, for 14 the requested sealing order. Again, competent evidence supporting the application to 15 file documents under seal must be provided by declaration. 16 Any document that is not confidential, privileged, or otherwise protectable in its 17 entirety will not be filed under seal if the confidential portions can be redacted. If 18 documents can be redacted, then a redacted version for public viewing, omitting only 19 the confidential, privileged, or otherwise protectable portions of the document, shall be 20 filed. Any application that seeks to file documents under seal in their entirety should 21 include an explanation of why redaction is not feasible. 22 2. DEFINITIONS 23 2.1 Action: this pending federal law suit. 24 2.2 Challenging Party: a Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 27 how it is generated, stored or maintained) or tangible things that qualify for 1 Good Cause Statement. 2 2.4 “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY” 3 Information or Items: information (regardless of how it is generated, stored or 4 maintained) or tangible things the disclosure of which might cause competitive harm 5 to the Designating Party. Information and material that may be subject to this 6 protection includes, but is not limited to, technical and/or research and development 7 data, intellectual property, financial, marketing and other sales data, and/or information 8 having strategic commercial value pertaining to the Designating Party’s trade or 9 business. 10 2.5 Designating Party: a Party or Non-Party that designates information or 11 items that it produces in disclosures or in responses to discovery as 12 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 13 ONLY.” 14 2.6 Disclosure or Discovery Material: all items or information, regardless of 15 the medium or manner in which it is generated, stored, or maintained (including, 16 among other things, testimony, transcripts, and tangible things), that are produced or 17 generated in disclosures or responses to discovery in this matter. 18 2.7 Expert: a person with specialized knowledge or experience in a matter 19 pertinent to the litigation who has been retained by a Party or its counsel to serve as 20 an expert witness or as a consultant in this Action. 21 2.8 House Counsel: attorneys who are employees of a party to this Action. 22 House Counsel does not include Outside Counsel of Record or any other outside 23 counsel. 24 2.9 Non-Party: any natural person, partnership, corporation, association, or 25 other legal entity not named as a Party to this action. 26 2.10 Outside Counsel of Record: attorneys who are not employees of a party 27 to this Action but are retained to represent or advise a party to this Action and have 1 has appeared on behalf of that party, and includes support staff. 2 2.11 Party: any party to this Action, including all of its officers, directors, 3 employees, consultants, retained experts, and Outside Counsel of Record (and their 4 support staffs). 5 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 6 Discovery Material in this Action. 7 2.13 Professional Vendors: persons or entities that provide litigation support 8 services (e.g., photocopying, videotaping, translating, preparing exhibits or 9 demonstrations, and organizing, storing, or retrieving data in any form or medium) 10 and their employees and subcontractors. 11 2.14 Protected Material: any Disclosure or Discovery Material that is 12 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 13 EYES ONLY.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 15 from a Producing Party. 16 3. SCOPE 17 The protections conferred by this Stipulation and Order cover not only Protected 18 Material (as defined above), but also (1) any information copied or extracted from 19 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 20 Material; and (3) any testimony, conversations, or presentations by Parties or their 21 Counsel that might reveal Protected Material. 22 Nothing in this order shall prevent or otherwise restrict counsel from rendering 23 advice to their clients regarding this Action and, in the course thereof, relying generally 24 on examination of Protected Material; provided, however, that in rendering such advice 25 and otherwise communicating with such client, counsel shall not make specific 26 disclosure of any Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the trial 1 4. DURATION 2 Once a case proceeds to trial, information that was designated as 3 CONFIDENTIAL or HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY or 4 maintained pursuant to this protective order used or introduced as an exhibit at trial 5 becomes public and will be presumptively available to all members of the public, 6 including the press, unless compelling reasons supported by specific factual findings 7 to proceed otherwise are made to the trial judge in advance of the trial. See Kamakana, 8

(distinguishing “good cause” showing for sealing documents 9 produced in discovery from “compelling reasons” standard when merits-related 10 documents are part of court record). Accordingly, the terms of this protective order do 11 not extend beyond the commencement of the trial. 12 5. DESIGNATING PROTECTED MATERIAL 13 5.1 Exercise of Restraint and Care in Designating Material for Protection. 14 Each Party or Non-Party that designates information or items for protection under this 15 Order must take care to limit any such designation to specific material that qualifies 16 under the appropriate standards. The Designating Party must designate for protection 17 only those parts of material, documents, items, or oral or written communications that 18 qualify so that other portions of the material, documents, items, or communications for 19 which protection is not warranted are not swept unjustifiably within the ambit of this 20 Order. 21 Mass, indiscriminate, or routinized designations are prohibited. Designations 22 that are shown to be clearly unjustified or that have been made for an improper 23 purpose (e.g., to unnecessarily encumber the case development process or to impose 24 unnecessary expenses and burdens on other parties) may expose the Designating 25 Party to sanctions. 26 If it comes to a Designating Party’s attention that information or items that it 27 designated for protection do not qualify for protection, that Designating Party must 1 5.2 Manner and Timing of Designations. Except as otherwise provided in 2 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 3 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 4 under this Order must be clearly so designated before the material is disclosed or 5 produced. 6 Designation in conformity with this Order requires: 7 (a) for information in documentary form (e.g., paper or electronic 8 documents, but excluding transcripts of depositions or other pretrial or trial 9 proceedings), that the Producing Party affix at a minimum, the legend 10 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 11 ONLY” (hereinafter “CONFIDENTIALITY legend”), to each page that contains 12 protected material. If only a portion or portions of the material on a page qualifies for 13 protection, the Producing Party also must clearly identify the protected portion(s) 14 (e.g., by making appropriate markings in the margins). 15 A Party or Non-Party that makes original documents available for inspection 16 need not designate them for protection until after the inspecting Party has indicated 17 which documents it would like copied and produced. During the inspection and 18 before the designation, all of the material made available for inspection shall be 19 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents 20 it wants copied and produced, the Producing Party must determine which documents, 21 or portions thereof, qualify for protection under this Order. Then, before producing 22 the specified documents, the Producing Party must affix the “CONFIDENTIALITY 23 legend” to each page that contains Protected Material. If only a portion or portions of 24 the material on a page qualifies for protection, the Producing Party also must clearly 25 identify the protected portion(s) (e.g., by making appropriate markings in the 26 margins). 27 (b) for testimony given in depositions that the Designating Party 1 deposition all protected testimony. 2 (c) for information produced in some form other than documentary 3 and for any other tangible items, that the Producing Party affix in a prominent place 4 on the exterior of the container or containers in which the information is stored the 5 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY.” If only a portion or portions of the information warrants protection, the 7 Producing Party, to the extent practicable, shall identify the protected portion(s). 8 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 9 failure to designate qualified information or items does not, standing alone, waive the 10 Designating Party’s right to secure protection under this Order for such material. 11 Upon timely correction of a designation, the Receiving Party must make reasonable 12 efforts to assure that the material is treated in accordance with the provisions of this 13 Order. 14 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 15 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 16 designation of confidentiality at any time that is consistent with the Court’s 17 Scheduling Order. 18 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 19 resolution process under Local Rule 37.1 et seq. 20 6.3 The burden of persuasion in any such challenge proceeding shall be on 21 the Designating Party. Frivolous challenges, and those made for an improper 22 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 23 parties) may expose the Challenging Party to sanctions. Unless the Designating 24 Party has waived or withdrawn the confidentiality designation, all parties shall 25 continue to afford the material in question the level of protection to which it is 26 entitled under the Producing Party’s designation until the Court rules on the 27 challenge. 1 7.1 Basic Principles. A Receiving Party may use Protected Material that is 2 disclosed or produced by another Party or by a Non-Party in connection with this 3 Action only for prosecuting, defending or attempting to settle this Action. Such 4 Protected Material may be disclosed only to the categories of persons and under the 5 conditions described in this Order. When the Action has been terminated, a 6 Receiving Party must comply with the provisions of section 13 below (FINAL 7 DISPOSITION). 8 7.2 Protected Material must be stored and maintained by a Receiving Party 9 at a location and in a secure manner that ensures that access is limited to the persons 10 authorized under this Order. 11 7.2.1 Disclosure of “HIGHLY CONFIDENTIAL - ATTORNEYS’ 12 EYES ONLY” Information or Items. Unless otherwise ordered by the court or 13 permitted in writing by the Designating Party, a Receiving Party may disclose any 14 information or item designated “HIGHLY CONFIDENTIAL - ATTORNEYS’ 15 EYES ONLY” only to: 16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 17 as employees of said Outside Counsel of Record to whom it is reasonably necessary to 18 disclose the information for this Action; 19 (b) Experts (as defined in this Order) of the Receiving Party to 20 whom disclosure is reasonably necessary for this Action and who have signed the 21 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 22 (c) the court and its personnel; 23 (d) court reporters and their staff; 24 (e) professional jury or trial consultants, mock jurors, and 25 Professional Vendors to whom disclosure is reasonably necessary for this Action and 26 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 27 (f) the author or recipient of a document containing the information 1 (g) during their depositions, witnesses, and attorneys for witnesses, in 2 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 3 party requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they 4 will not be permitted to keep any confidential information unless they sign the 5 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 6 agreed by the Designating Party or ordered by the court. Pages of transcribed 7 deposition testimony or exhibits to depositions that reveal Protected Material may be 8 separately bound by the court reporter and may not be disclosed to anyone except as 9 permitted under this Stipulated Protective Order; and 10 (h) any mediator or settlement officer, and their supporting personnel, 11 mutually agreed upon by any of the parties engaged in settlement discussions. 12 7.2.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 13 otherwise ordered by the court or permitted in writing by the Designating Party, a 14 Receiving Party may disclose any information or item designated 15 “CONFIDENTIAL” only to: 16 (a) persons permitted to receive information or item designated 17 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY;” and 18 (b) the officers, directors, and employees (including House 19 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for this 20 Action. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 22 OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 26 ONLY,” that Party must: 27 (a) promptly notify in writing the Designating Party. Such 1 (b) promptly notify in writing the party who caused the subpoena or 2 order to issue in the other litigation that some or all of the material covered by the 3 subpoena or order is subject to this Protective Order. Such notification shall include a 4 copy of this Stipulated Protective Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be 6 pursued by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order shall not produce any information designated in this 9 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 10 EYES ONLY” before a determination by the court from which the subpoena or order 11 issued, unless the Party has obtained the Designating Party’s permission. The 12 Designating Party shall bear the burden and expense of seeking protection in that 13 court of its confidential material and nothing in these provisions should be construed 14 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful 15 directive from another court. 16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a 19 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 20 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by 21 Non-Parties in connection with this litigation is protected by the remedies and relief 22 provided by this Order. Nothing in these provisions should be construed as 23 prohibiting a Non-Party from seeking additional protections. 24 (b) In the event that a Party is required, by a valid discovery request, to 25 produce a Non-Party’s confidential information in its possession, and the Party is 26 subject to an agreement with the Non-Party not to produce the Non-Party’s 27 confidential information, then the Party shall: 1 that some or all of the information requested is subject to a confidentiality agreement 2 with a Non-Party; 3 (2) promptly provide the Non-Party with a copy of the Stipulated 4 Protective Order in this Action, the relevant discovery request(s), and a reasonably 5 specific description of the information requested; and 6 (3) make the information requested available for inspection by the 7 Non-Party, if requested. 8 (c) If the Non-Party fails to seek a protective order from this court within 14 9 days of receiving the notice and accompanying information, the Receiving Party may 10 produce the Non-Party’s confidential information responsive to the discovery request. 11 If the Non-Party timely seeks a protective order, the Receiving Party shall not 12 produce any information in its possession or control that is subject to the 13 confidentiality agreement with the Non-Party before a determination by the court. 14 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 15 of seeking protection in this court of its Protected Material. 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 18 Protected Material to any person or in any circumstance not authorized under this 19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 20 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 21 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 22 persons to whom unauthorized disclosures were made of all the terms of this Order, 23 and (d) request such person or persons to execute the “Acknowledgment and 24 Agreement to Be Bound” that is attached hereto as Exhibit A. 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 26 PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 3 may be established in an e-discovery order that provides for production without prior 4 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 5 parties reach an agreement on the effect of disclosure of a communication or 6 information covered by the attorney-client privilege or work product protection, the 7 parties may incorporate their agreement in the stipulated protective order submitted to 8 the court. 9 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 11 person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Protective Order no Party waives any right it otherwise would have to object to 14 disclosing or producing any information or item on any ground not addressed in this 15 Stipulated Protective Order. Similarly, no Party waives any right to object on any 16 ground to use in evidence of any of the material covered by this Protective Order. 17 12.3 Use of Designated Materials by Designating Party. Nothing in this 18 Protective Order shall limit a Designating Party’s use of its own information or 19 materials, or prevent a Designating Party from disclosing its own information or 20 materials to any person. Such disclosure shall not affect any designations made 21 pursuant to the terms of this Protective Order, so long as the disclosure is made in a 22 manner that is reasonably calculated to maintain the confidentiality of the 23 information. 24 12.4 Filing Protected Material. A Party that seeks to file under seal any 25 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 26 only be filed under seal pursuant to a court order authorizing the sealing of the 27 specific Protected Material at issue. If a Party's request to file Protected Material 1 the public record unless otherwise instructed by the court. 2 13. FINAL DISPOSITION 3 After the final disposition of this Action, as defined in paragraph 4, within 60 4 days of a written request by the Designating Party, each Receiving Party must return 5 all Protected Material to the Producing Party or destroy such material. As used in this 6 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 7 summaries, and any other format reproducing or capturing any of the Protected 8 Material. Whether the Protected Material is returned or destroyed, the Receiving 9 Party must submit a written certification to the Producing Party (and, if not the same 10 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 11 (by category, where appropriate) all the Protected Material that was returned or 12 destroyed and (2)affirms that the Receiving Party has not retained any copies, 13 abstracts, compilations, summaries or any other format reproducing or capturing any 14 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 15 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 16 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 17 reports, attorney work product, and consultant and expert work product, even if such 18 materials contain Protected Material. Any such archival copies that contain or 19 constitute Protected Material remain subject to this Protective Order as set forth in 20 Section 4 (DURATION). 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 14. VIOLATION Any violation of this Order may be punished by any and all appropriate 33 ||| Measures including, without limitation, contempt proceedings and/or monetary sanctions. 44 55 66 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

77 DATED: April 5, 2021 By: /s/ Scott Alan Burroughs Scott Alan Burroughs 99 Trevor W. Barrett 10 DONIGER /BURROUGHS Attorneys for Plaintiff / Counter-Defendant 12 . Dated: April 5, 2021 By: /s/ Lara S. Garner 13 M.D. Scully 14 Hazel Mae B. Pangan Lara S. Garner GORDON REES SCULLY MANSUKHANI 16 Attorneys for Defendants / Counterclaimants 17 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 18 19 DATED: 4/5/2021 20 21 22 : 40 y Nox kK es, 23 24 || HON. ALEXANDER F. MACKINNON 95 |} United States Magistrate Judge 26 27 28 -16-

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 ____________________________________ [print or type full address], 6 declare under penalty of perjury that I have read in its entirety and understand the 7 Stipulated Protective Order that was issued by the United States District Court for the 8 Central District of California on [date] in the case of Klauber Brothers, Inc. v. Urban 9 Outfitters, Inc., et al., Case No. 2:20-cv-07430-AB (AFM). I agree to comply with 10 and to be bound by all the terms of this Stipulated Protective Order and I understand 11 and acknowledge that failure to so comply could expose me to sanctions and 12 punishment in the nature of contempt. I solemnly promise that I will not disclose in 13 any manner any information or item that is subject to this Stipulated Protective Order 14 to any person or entity except in strict compliance with the 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 __________________________ [print or 19 type full name] of ___________________________ [print or type 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 sworn and signed: 25 _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________