2 3 4 5 UNITED STATES DISTRICT COURT 6 CENTRAL DISTRICT OF CALIFORNIA 7 8 9 THE SLIDING DOOR COMPANY, a ) Case No. 2:20-cv-06736-GW-JEM 10 California limited liability company, ) 11 ) STIPULATED PROTECTIVE Plaintiff, ) ORDER 12 v. ) 13 ) 14 KNR SLIDING DOOR DESIGN, LLC, a ) California limited liability company; ) 15 CHAI KANER, an individual, KEREN ) 16 KANER, an individual, ) ) 17 Defendants. ) 18 A. PURPOSE AND LIMITATIONS 19 Discovery in this action is likely to involve production of confidential, proprietary, 20 or private information for which special protection from public disclosure and from use 21 for any purpose other than prosecuting this litigation may be warranted. Accordingly, the 22 parties hereby stipulate to and petition the Court to enter the following Stipulated 23 Protective Order. The parties acknowledge that this Order does not confer blanket 24 protections on all disclosures or responses to discovery and that the protection it affords 25 from public disclosure and use extends only to the limited information or items that are 26 entitled to confidential treatment under the applicable legal principles. The parties further 27 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 28 does not entitle them to file confidential information under seal; Civil Local Rule 79-5 2 when a party seeks permission from the court to file material under seal. 3 B. GOOD CAUSE STATEMENT 4 This is an action for patent infringement unfair business practices. This action will 5 involve the production, exchange, and examination of confidential information for which 6 special protection from public disclosure and from use for any purpose other than 7 prosecution of this action is warranted. Such confidential and proprietary materials and 8 information consist of, among other things, confidential business or financial 9 information, information regarding confidential business practices including copyright 10 licensing terms and fees, or other confidential research, development, or commercial 11 information (including information implicating privacy rights of third parties), 12 information otherwise generally unavailable to the public, or which may be privileged or 13 otherwise protected from disclosure under state or federal statutes, court rules, case 14 decisions, or common law. 15 By way of example, Plaintiff alleges that it was damaged by Defendants’ 16 infringement of its design patent. Pursuant to

, a successful plaintiff in an 17 action for infringement of a design patent may recover the defendant’s “total profit.” 18 Accordingly, Defendants’ financial information, including their revenue profit numbers, 19 amounts paid in taxes, and internal profit margin calculations, are relevant to the 20 calculation of damages. Defendants contend, and Plaintiff does not dispute, that this type 21 of information is typically held confidential. 22 Accordingly, to expedite the flow of information, to facilitate the prompt resolution 23 of disputes over confidentiality of discovery materials, to adequately protect information 24 the parties are entitled to keep confidential, to ensure that the parties are permitted 25 reasonable necessary uses of such material in preparation for and in the conduct of trial, 26 to address their handling at the end of the litigation, and serve the ends of justice, a 27 protective order for such information is justified in this matter. It is the intent of the 28 parties that information will not be designated as confidential for tactical reasons and that 2 confidential, non-public manner, and there is good cause why it should not be part of the 3 public record of this case. 4 5 I. DEFINITIONS 6 A. Action: this pending federal lawsuit. 7 B. Challenging Party: a Party or Non-Party that challenges the designation of 8 information or items under this Order. 9 C. “CONFIDENTIAL” Information or Items: information (regardless of how 10 it is generated, stored or maintained) or tangible things that qualify for protection under 11 Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause 12 Statement. 13 D. “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” 14 Information or Items: information (regardless of how it is generated, stored or 15 maintained) or tangible things that qualify for protection under Federal Rule of Civil 16 Procedure 26(c), as specified above in the Good Cause Statement, and the disclosure of 17 which would put the Producing Party at a competitive disadvantage. 18 E. Counsel: Outside Counsel of Record (as well as their support staff). 19 F. Designating Party: a Party or Non-Party that designates information or 20 items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” 21 or “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY.” 22 Disclosure or Discovery Material: all items or information, regardless of the medium or 23 manner in which it is generated, stored, or maintained (including, among other things, 24 testimony, transcripts, and tangible things), that are produced or generated in disclosures 25 or responses to discovery in this matter. 26 G. Expert: a person with specialized knowledge or experience in a matter 27 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 28 expert witness or as a consultant in this Action. 2 other legal entity not named as a Party to this action. 3 I. Outside Counsel of Record: attorneys who are not employees of a party to 4 this Action but are retained to represent or advise a party to this Action and have 5 appeared in this Action on behalf of that party or are affiliated with a law firm which has 6 appeared on behalf of that party, and includes support staff. 7 J. Party: any party to this Action, including all of its officers, directors, 8 employees, consultants, retained experts, and Outside Counsel of Record (and their 9 support staffs). 10 K. Producing Party: a Party or Non-Party that produces Disclosure or 11 Discovery Material in this Action. 12 L. Professional Vendors: persons or entities that provide litigation support 13 services (e.g., photocopying, videotaping, translating, preparing exhibits or 14 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 15 their employees and subcontractors. 16 M. Protected Material: any Disclosure or Discovery Material that is designated 17 as “CONFIDENTIAL” or as “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES 18 ONLY.” 19 N. Receiving Party: a Party that receives Disclosure or Discovery Material 20 from a Producing Party. 21 II. SCOPE 22 The protections conferred by this Stipulation and Order cover not only Protected 23 Material (as defined above), but also (1) any information copied or extracted from 24 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 25 Material; and (3) any testimony, conversations, or presentations by Parties or their 26 Counsel that might reveal Protected Material. 27 Any use of Protected Material at trial shall be governed by the orders of the trial 28 judge. This Order does not govern the use of Protected Material at trial. 2 Once a case proceeds to trial, all of the information that was designated as 3 confidential or maintained pursuant to this protective order becomes public and will be 4 presumptively available to all members of the public, including the press, unless 5 compelling reasons supported by specific factual findings to proceed otherwise are made 6 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 7

(9th Cir. 2006) (distinguishing “good cause” showing for sealing 8 documents produced in discovery from “compelling reasons” standard when merits- 9 related documents are part of court record). Accordingly, the terms of this protective 10 order do not extend beyond the commencement of the trial. 11 IV. DESIGNATING PROTECTED MATERIAL 12 A. Exercise of Restraint and Care in Designating Material for Protection. Each 13 Party or Non-Party that designates information or items for protection under this Order 14 must take care to limit any such designation to specific material that qualifies under the 15 appropriate standards. The Designating Party must designate for protection only those 16 parts of material, documents, items, or oral or written communications that qualify so 17 that other portions of the material, documents, items or communications for which 18 protection is not warranted are not swept unjustifiably within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that 20 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 21 to unnecessarily encumber the case development process or to impose unnecessary 22 expenses and burdens on other parties) may expose the Designating Party to sanctions. 23 If it comes to a Designating Party’s attention that information or items that it 24 designated for protection do not qualify for protection, that Designating Party must 25 promptly notify all other Parties that it is withdrawing the inapplicable designation. 26 B. Manner and Timing of Designations. Except as otherwise provided in this 27 Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or 28 ordered, Disclosure or Discovery Material that qualifies for protection under this Order 2 Designation in conformity with this Order requires: 3 a) for information in documentary form (e.g., paper or electronic 4 documents, but excluding transcripts of depositions or other pretrial or trial 5 proceedings), that the Producing Party affix at a minimum, the legend 6 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY 7 CONFIDENTIAL—ATTORNEYS’ EYES ONLY” (hereinafter “HIGHLY 8 CONFIDENTIAL legend”), to each page that contains protected material. If only a 9 portion or portions of the material on a page qualifies for protection, the Producing Party 10 also must clearly identify the protected portion(s) (e.g., by making appropriate markings 11 in the margins). 12 A Party or Non-Party that makes original documents available for inspection need 13 not designate them for protection until after the inspecting Party has indicated which 14 documents it would like copied and produced. During the inspection and before the 15 designation, all of the material made available for inspection shall be deemed “HIGHLY 16 CONFIDENTIAL—ATTORNEYS’ EYES ONLY.” After the inspecting Party has 17 identified the documents it wants copied and produced, the Producing Party must 18 determine which documents, or portions thereof, qualify for protection under this Order. 19 Then, before producing the specified documents, the Producing Party must affix the 20 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL legend” to each page that 21 contains Protected Material. If only a portion or portions of the material on a page 22 qualifies for protection, the Producing Party also must clearly identify the protected 23 portion(s) (e.g., by making appropriate markings in the margins). 24 b) for testimony given in depositions that the Designating Party identify 25 the Disclosure or Discovery Material on the record, before the close of the deposition all 26 protected testimony. 27 c) for information produced in some form other than documentary and 28 for any other tangible items, that the Producing Party affix in a prominent place on the 2 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY.” 3 If only a portion or portions of the information warrants protection, the Producing Party, 4 to the extent practicable, shall identify the protected portion(s). 5 C. Inadvertent Failures to Designate. If timely corrected, an inadvertent failure 6 to designate qualified information or items does not, standing alone, waive the 7 Designating Party’s right to secure protection under this Order for such material. Upon 8 timely correction of a designation, the Receiving Party must make reasonable efforts to 9 assure that the material is treated in accordance with the provisions of this Order. 10 V. CHALLENGING CONFIDENTIALITY DESIGNATIONS 11 A. Timing of Challenges. Any Party or Non-Party may challenge a designation 12 of confidentiality at any time that is consistent with the Court’s Scheduling Order. 13 B. Meet and Confer. The Challenging Party shall initiate the dispute 14 resolution process under Local Rule 37.1 et seq. 15 C. The burden of persuasion in any such challenge proceeding shall be on the 16 Designating Party. Frivolous challenges, and those made for an improper purpose (e.g., 17 to harass or impose unnecessary expenses and burdens on other parties) may expose the 18 Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn 19 the confidentiality designation, all parties shall continue to afford the material in 20 question the level of protection to which it is entitled under the Producing Party’s 21 designation until the Court rules on the challenge. 22 VI. ACCESS TO AND USE OF PROTECTED MATERIAL 23 A. Basic Principles. A Receiving Party may use Protected Material that is 24 disclosed or produced by another Party or by a Non-Party in connection with this Action 25 only for prosecuting, defending, or attempting to settle this Action. Such Protected 26 Material may be disclosed only to the categories of persons and under the conditions 27 described in this Order. When the Action has been terminated, a Receiving Party must 28 comply with the provisions of section 12 below (FINAL DISPOSITION). 2 location and in a secure manner that ensures that access is limited to the persons 3 authorized under this Order. 4 B. Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise 5 ordered by the court or permitted in writing by the Designating Party, a Receiving Party 6 may disclose any information or item designated “CONFIDENTIAL” only to: 7 a) the Receiving Party’s Outside Counsel of Record in this Action, as 8 well as employees of said Outside Counsel of Record to whom it is reasonably necessary 9 to disclose the information for this Action; 10 b) the officers, directors, and employees of the Receiving Party to 11 whom disclosure is reasonably necessary for this Action; 12 c) Experts (as defined in this Order) of the Receiving Party to whom 13 disclosure is reasonably necessary for this Action and who have signed the 14 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 15 d) the court and its personnel; 16 e) court reporters and their staff; 17 f) professional jury or trial consultants, mock jurors, and Professional 18 Vendors to whom disclosure is reasonably necessary for this Action and who have 19 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 20 g) the author or recipient of a document containing the information or 21 a custodian or other person who otherwise possessed or knew the information; 22 h) during their depositions, witnesses, and attorneys for witnesses, in 23 the Action to whom disclosure is reasonably necessary provided: (1) the deposing party 24 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 25 be permitted to keep any confidential information unless they sign the 26 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 27 by the Designating Party or ordered by the court. Pages of transcribed deposition 28 testimony or exhibits to depositions that reveal Protected Material may be separately 2 under this Stipulated Protective Order; and 3 i) any mediator or settlement officer, and their supporting personnel, 4 mutually agreed upon by any of the parties engaged in settlement discussions. 5 C. Disclosure of “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES 6 ONLY” Information or Items. Unless otherwise ordered by the court or permitted in 7 writing by the Designating Party, a Counsel for Receiving Party may disclose any 8 information or item designated “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES 9 ONLY” only to: the individuals listed in section 6(B) above, except for those listed in 10 subsections (b) and (h), 11 unless consented to by the Designating Party or as otherwise permitted by the Court. 12 VII. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN 13 OTHER LITIGATION 14 If a Party is served with a subpoena or a court order issued in other litigation that 15 compels disclosure of any information or items designated in this Action as 16 “CONFIDENTIAL,” that Party must: 17 a) promptly notify in writing the Designating Party. Such notification 18 shall include a copy of the subpoena or court order; 19 b) promptly notify in writing the party who caused the subpoena or 20 order to issue in the other litigation that some or all of the material covered by the 21 subpoena or order is subject to this Protective Order. Such notification shall include a 22 copy of this Stipulated Protective Order; and 23 c) cooperate with respect to all reasonable procedures sought to be 24 pursued by the Designating Party whose Protected Material may be affected. 25 If the Designating Party timely seeks a protective order, the Party served with the 26 subpoena or court order shall not produce any information designated in this action as 27 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” 28 before a determination by the court from which the subpoena or order issued, unless the 2 the burden and expense of seeking protection in that court of its confidential material and 3 nothing in these provisions should be construed as authorizing or encouraging a 4 Receiving Party in this Action to disobey a lawful directive from another court. 5 VIII. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED 6 IN THIS LITIGATION 7 a) The terms of this Order are applicable to information produced by a 8 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 9 CONFIDENTIAL—ATTORNEYS’ EYES ONLY.” Such information produced by 10 Non-Parties in connection with this litigation is protected by the remedies and relief 11 provided by this Order. Nothing in these provisions should be construed as prohibiting 12 a Non-Party from seeking additional protections. 13 b) In the event that a Party is required, by a valid discovery request, to 14 produce a Non-Party’s confidential information in its possession, and the Party is subject 15 to an agreement with the Non-Party not to produce the Non-Party’s confidential 16 information, then the Party shall: 17 (1) promptly notify in writing the Requesting Party and the Non- 18 Party that some or all of the information requested is subject to a confidentiality 19 agreement with a Non-Party; 20 (2) promptly provide the Non-Party with a copy of the Stipulated 21 Protective Order in this Action, the relevant discovery request(s), and a reasonably 22 specific description of the information requested; and 23 (3) make the information requested available for inspection by the 24 Non-Party, if requested. 25 c) If the Non-Party fails to seek a protective order from this court within 26 14 days of receiving the notice and accompanying information, the Receiving Party may 27 produce the Non-Party’s confidential information responsive to the discovery request. If 28 the Non-Party timely seeks a protective order, the Receiving Party shall not produce any 2 contrary, the Non-Party shall bear the burden and expense of seeking protection in this 3 court of its Protected Material. 4 IX. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 5 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 8 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 9 all unauthorized copies of the Protected Material, (c) inform the person or persons to 10 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 11 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 12 that is attached hereto as Exhibit A. 13 X. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 PROTECTED MATERIAL 15 11.1 When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other protection, the 17 obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 18 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 19 established in an e-discovery order that provides for production without prior privilege 20 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach 21 an agreement on the effect of disclosure of a communication or information covered by 22 the attorney-client privilege or work product protection, the parties may incorporate their 23 agreement in the stipulated protective order submitted to the court. 24 11.2 For the purpose of this order, “Protected Information” means documents 25 and information in any form, including electronically stored information (“ESI”), 26 protected from discovery by the attorney-client privilege, the work-product doctrine as 27 defined in the Federal Rules of Civil Procedure and applicable judicial interpretations, 28 and any other recognized privilege or protection with regard to discovery; 2 shall not constitute a waiver of the producing party’s right to assert any privilege or 3 protection with respect to those documents in this or in any other proceeding. The privilege 4 or protection shall be preserved both within and without this litigation, irrespective of the 5 identity of the parties involved in any controversy in which such privilege or protection is 6 challenged, and shall remain intact regardless of whether the individual or organization 7 challenging or defending the applicability of such privilege or protection is a party to this 8 agreement or to this action. Moreover, this order shall be interpreted to provide the 9 maximum protection allowed by Federal Rule of Evidence 502(d). Thus, in order to 10 properly assert a privilege or protection with regard to produced Protected Information, the 11 Producing Party shall not be required to meet the requirements of Fed. R. Evid. 502(b)— 12 i.e., it will not have to show that the production was inadvertent, it will not have to show 13 that it took reasonable steps to prevent disclosure, it will not have to show that it took 14 reasonable steps to rectify the error, and it will not have to show that it acted promptly to 15 provide notice of or otherwise rectify the disclosure. Moreover, the mere production of 16 Protected Information, without further use of that Protected Information in testimony, at 17 trial, or on any motion other than a motion to compel as contemplated by section 13.5, shall 18 not be deemed “intentional” pursuant to Fed. R. Evid. 502(a)(1). 19 11.4 Upon written notice of recall from the Producing Party of the production of 20 Protected Information, the requesting party must—unless it contests the claim of privilege 21 or protection in accordance with section 13.5—within fifteen days of receipt of that recall 22 notice, (i) return or destroy all copies of the produced Protected Information and (ii) 23 provide a written certification of counsel that the produced Protected Information 24 designated in the recall notice has been returned or destroyed. Within ten days of receipt 25 of the notification that the produced Protected Information has been returned or destroyed, 26 the Producing Party shall produce a privilege log with respect to the produced Protected 27 Information;

28 2 recall notice, the requesting party must follow the procedure outlined in Local Rule 37 for 3 bringing a motion to compel. That motion must not assert as a ground for compelling 4 5 disclosure the facts or circumstances of the production, including any discussion of the 6 factors listed in Federal Rule of Evidence 502(b) or evidence supporting or refuting those 7 factors, but may describe any further use made by the Producing Party of the alleged 8 Protected Information. The motion must be accompanied by an appropriate request to the 9 Court to seal any portions of the motion and any exhibits filed therewith that contain 10 Protected Information, in accordance with applicable local rules of this Court. The 11 requesting party must take reasonable measures to prevent any further dissemination of the 12 produced Protected Information pending resolution of the motion to compel. 13 11.6 Within fifteen days of an order denying a motion to compel regarding 14 produced Protected Information, the requesting party must (i) return or destroy all copies 15 of the produced Protected Information and (ii) provide a certification of counsel that the 16 produced Protected Information designated in the notice has been returned or destroyed. 17 Within ten days of the receipt of the notification that the produced Protected Information 18 has been returned or destroyed, the producing party shall produce a privilege log with 19 respect to the produced Protected Information; 20 11.7 If the notice from the Producing Party of the production of attorney-client 21 privileged or work-product protected information is made during or prior to a deposition, 22 the requesting party may not use the produced Protected Information at the deposition in 23 any manner except for the limited purpose of questioning the witness to ascertain the 24 strength of the claim of privilege or protection; 25 11.8 If the Producing Party is required to produce documents previously withheld 26 as Protected Information, and such documents were the subject of an instruction to a 27 deponent not to answer questions at a deposition, that Producing Party will bear the expense 28 of producing the deponent at a re-scheduled deposition to address the document(s) 2 11.9 The Producing Party retains the burden of establishing the privileged or 3 protected nature of the produced Protected Information. Nothing in this Order shall limit 4 the right of either party to petition the Court for an in camera review of the produced 5 Protected Information; 6 11.10 Where the requesting party becomes aware of produced Protected Information 7 on its own review, that party shall promptly notify the Producing Party in writing of such 8 production. Within ten days of the receipt of that notice, the producing party must notify 9 the requesting party in writing whether it intends to recall the produced documents. That 10 recall notice shall be treated as a recall notice as contemplated by section 13.4; 11 11.11 Nothing contained herein is intended to or shall serve to limit a party’s right 12 to conduct a review of documents, ESI, or information (including metadata) for relevance, 13 responsiveness, and/or desegregation of privileged and/or protected information before 14 production. 15 11.12 The Parties may stipulate to extend the time periods set forth in sections 13.4, 16 13.5, 13.6 or 13.10 without filing the stipulation and procuring a court order approving the 17 stipulation. 18 XI. MISCELLANEOUS 19 A. Right to Further Relief. Nothing in this Order abridges the right of any 20 person to seek its modification by the Court in the future. 21 B. Right to Assert Other Objections. By stipulating to the entry of this 22 Protective Order no Party waives any right it otherwise would have to object to 23 disclosing or producing any information or item on any ground not addressed in this 24 Stipulated Protective Order. Similarly, no Party waives any right to object on any ground 25 to use in evidence of any of the material covered by this Protective Order. 26 C. Filing Protected Material. A Party that seeks to file under seal any Protected 27 Material must comply with Civil Local Rule 79-5. Protected Material may only be filed 28 under seal pursuant to a court order authorizing the sealing of the specific Protected 2 the court, then the Receiving Party may file the information in the public record unless 3 otherwise instructed by the court. 4 XII. FINAL DISPOSITION 5 After the final disposition of this Action, as defined in paragraph 4, within 60 days 6 of a written request by the Designating Party, each Receiving Party must return all 7 Protected Material to the Producing Party or destroy such material. As used in this 8 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 9 summaries, and any other format reproducing or capturing any of the Protected Material. 10 Whether the Protected Material is returned or destroyed, the Receiving Party must submit 11 a written certification to the Producing Party (and, if not the same person or entity, to the 12 Designating Party) by the 60 day deadline that (1) identifies (by category, where 13 appropriate) all the Protected Material that was returned or destroyed and (2) affirms that 14 the Receiving Party has not retained any copies, abstracts, compilations, summaries or 15 any other format reproducing or capturing any of the Protected Material. Notwithstanding 16 this provision, Counsel are entitled to retain an archival copy of all pleadings, motion 17 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 18 deposition and trial exhibits, expert reports, attorney work product, and consultant and 19 expert work product, even if such materials contain Protected Material. Any such archival 20 copies that contain or constitute Protected Material remain subject to this Protective 21 Order as set forth in Section 3 above (DURATION). 22 Any violation of this Order may be punished by any and all appropriate measures 23 including, without limitation, contempt proceedings and/or monetary sanctions. 24

25 26 27 28 1 |} FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 4||DATED: 4/6/21 5 6 By: Nedornel 7 ted States Magistrate Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [print or type full name], of 5 __________________________ [print or type full address], declare under penalty of 6 perjury that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the Central District of California on 8 __________ [date] in the case The Sliding Door Company v. KNR Sliding Door Design, 9 LLC, et al., 2:20-cv-06736-GW-JEM . I agree to comply with and to be bound by all the 10 terms of this Stipulated Protective Order and I understand and acknowledge that failure to 11 so comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item that is 13 subject to this Stipulated Protective Order to any person or entity except in strict 14 compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the Central District of California for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint __________________________ [print or type full name] of 19 _______________________________________ [print or type full address and telephone 20 number] as my California agent for service of process in connection with this action or 21 any proceedings related to enforcement of this Stipulated Protective Order. 22 Date: ______________________________________ 23 City and State where sworn and signed: _________________________________ 24 Printed name: _______________________________ 25 Signature: __________________________________

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