CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 11 ooff 1166 PPaaggee IIDD ##::662306 Alexander Chen [SBN 245798] [email protected] Katja M. Grosch [SBN 266935] [email protected] Theodore S. Lee [SBN 281475] [email protected] INHOUSE CO. LAW FIRM 7700 Irvine Center Drive, Suite 800 Irvine, CA 92618 Telephone: 949-250-1555 Facsimile: 714-882-7770

Attorneys for Defendant, Arex Industries, Inc

1

2 3 UNITED STATES DISTRICT COURT 4 CENTRAL DISTRICT OF CALIFORNIA 5 ZHEJIANG YUANZHENG AUTO & 6 Case No. 2:22-cv-01692 MOTORCYCLE ACCESSORIES 7 CO., LTD. STIPULATED PROTECTIVE 8 Plaintiff, ORDER1

9 v.

10 AREX INDUSTRIES, INC.

11 Defendant.

12

13 1. A. PURPOSES AND LIMITATIONS 14 Discovery in this action is likely to involve production of confidential, 15 proprietary, or private information for which special protection from public 16 disclosure and from use for any purpose other than prosecuting this litigation may be 17 warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter 18 19 20 1 This Stipulated Protective Order is substantially based on the model protective 21 order provided under Magistrate Judge Patricia Donahue’s Procedures. 22 23 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 22 ooff 1166 PPaaggee IIDD ##::662317

1 the following Stipulated Protective Order. The parties acknowledge that this Order 2 does not confer blanket protections on all disclosures or responses to discovery and 3 that the protection it affords from public disclosure and use extends only to the 4 limited information or items that are entitled to confidential treatment under the 5 applicable legal principles. 6 B. GOOD CAUSE STATEMENT 7 This action will involve trade secrets, customer and pricing lists and other 8 valuable research, development, commercial, financial, technical and/or proprietary 9 information for which special protection from public disclosure and from use for any 10 purpose other than prosecution of this action is warranted. Such confidential and 11 proprietary materials and information consist of, among other things, confidential 12 business or financial information, information regarding confidential business 13 practices, or other confidential research, development, or commercial information 14 (including information implicating privacy rights of third parties), information 15 otherwise generally unavailable to the public, or which may be privileged or 16 otherwise protected from disclosure under state or federal statutes, court rules, case 17 decisions, or common law. Accordingly, to expedite the flow of information, to 18 facilitate the prompt resolution of disputes over confidentiality of discovery 19 materials, to adequately protect information the parties are entitled to keep 20 confidential, to ensure that the parties are permitted reasonable necessary uses of 21 such material in preparation for and in the conduct of trial, to address their handling 22 at the end of the litigation, and serve the ends of justice, a protective order for such 23 information is justified in this matter. It is the intent of the parties that information 24 will not be designated as confidential for tactical reasons and that nothing be so 25 designated without a good faith belief that it has been maintained in a confidential, 26 non-public manner, and there is good cause why it should not be part of the public 27 record of this case. 28 2 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 33 ooff 1166 PPaaggee IIDD ##::662328

1 2 C. ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER SEAL 3 The parties further acknowledge, as set forth in Section 12.3, below, that this 4 Stipulated Protective Order does not entitle them to file confidential information 5 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed and 6 the standards that will be applied when a party seeks permission from the court to 7 file material under seal. 8 There is a strong presumption that the public has a right of access to judicial 9 proceedings and records in civil cases. In connection with non-dispositive motions, 10 good cause must be shown to support a filing under seal. See Kamakana v. City and 11 County of Honolulu,

(9th Cir. 2006), Phillips v. Gen. Motors 12 Corp.,

, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, 13 Inc.,

(E.D. Wis. 1999) (even stipulated protective orders require 14 good cause showing), and a specific showing of good cause or compelling reasons 15 with proper evidentiary support and legal justification, must be made with respect to 16 Protected Material that a party seeks to file under seal. The parties’ mere designation 17 of Disclosure or Discovery Material as CONFIDENTIAL does not—without the 18 submission of competent evidence by declaration, establishing that the material 19 sought to be filed under seal qualifies as confidential, privileged, or otherwise 20 protectable—constitute good cause. 21 Further, if a party requests sealing related to a dispositive motion or trial, then 22 compelling reasons, not only good cause, for the sealing must be shown, and the 23 relief sought shall be narrowly tailored to serve the specific interest to be protected. 24 See Pintos v. Pacific Creditors Ass’n,

(9th Cir. 2010). For each 25 item or type of information, document, or thing sought to be filed or introduced under 26 seal in connection with a dispositive motion or trial, the party seeking protection 27 must articulate compelling reasons, supported by specific facts and legal 28 justification, for the requested sealing order. Again, competent evidence supporting 3 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 44 ooff 1166 PPaaggee IIDD ##::662339

1 the application to file documents under seal must be provided by declaration. 2 Any document that is not confidential, privileged, or otherwise protectable in 3 its entirety will not be filed under seal if the confidential portions can be redacted. If 4 documents can be redacted, then a redacted version for public viewing, omitting only 5 the confidential, privileged, or otherwise protectable portions of the document, shall 6 be filed. Any application that seeks to file documents under seal in their entirety 7 should include an explanation of why redaction is not feasible. 8 9 2. DEFINITIONS 10 2.1 Action: [this pending federal law suit]. [*Option: consolidated 11 or related actions.] 12 2.2 Challenging Party: a Party or Non-Party that challenges 13 the designation of information or items under this Order. 14 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 15 how it is generated, stored or maintained) or tangible things that qualify for 16 protection under Federal Rule of Civil Procedure 26(c), and as specified above in the 17 Good Cause Statement. 18 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 19 their support staff). 20 2.5 Designating Party: a Party or Non-Party that designates information or 21 items that it produces in disclosures or in responses to discovery as 22 “CONFIDENTIAL.” 23 2.6 Disclosure or Discovery Material: all items or information, regardless 24 of the medium or manner in which it is generated, stored, or maintained (including, 25 among other things, testimony, transcripts, and tangible things), that are produced or 26 generated in disclosures or responses to discovery in this matter. 27 2.7 Expert: a person with specialized knowledge or experience in a matter 28 pertinent to the litigation who has been retained by a Party or its counsel to serve as 4 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 55 ooff 1166 PPaaggee IIDD ##::662440

1 an expert witness or as a consultant in this Action. 2 2.8 House Counsel: attorneys who are employees of a party to this Action. 3 House Counsel does not include Outside Counsel of Record or any other outside 4 counsel. 5 2.9 Non-Party: any natural person, partnership, corporation, association, or 6 other legal entity not named as a Party to this action. 7 2.10 Outside Counsel of Record: attorneys who are not employees of a party 8 to this Action but are retained to represent or advise a party to this Action and have 9 appeared in this Action on behalf of that party or are affiliated with a law firm which 10 has appeared on behalf of that party, and includes support staff. 11 2.11 Party: any party to this Action, including all of its officers, directors, 12 employees, consultants, retained experts, and Outside Counsel of Record (and their 13 support staffs). 14 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 15 Discovery Material in this Action. 16 2.13 Professional Vendors: persons or entities that provide litigation 17 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 18 demonstrations, and organizing, storing, or retrieving data in any form or medium) 19 and their employees and subcontractors. 20 2.14 Protected Material: any Disclosure or Discovery Material that is 21 designated as “CONFIDENTIAL.” 22 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material 23 from a Producing Party. 24 25 3. SCOPE 26 The protections conferred by this Stipulation and Order cover not only 27 Protected Material (as defined above), but also (1) any information copied or 28 extracted from Protected Material; (2) all copies, excerpts, summaries, or 5 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 66 ooff 1166 PPaaggee IIDD ##::662451

1 compilations of Protected Material; and (3) any testimony, conversations, or 2 presentations by Parties or their 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. This Order does not govern the use of Protected Material at trial. 5 6 4. DURATION 7 FINAL DISPOSITION of the action is defined as the conclusion of any 8 appellate proceedings, or, if no appeal is taken, when the time for filing of an appeal 9 has run. Except as set forth below, the terms of this protective order apply through 10 FINAL DISPOSITION of the action. The parties may stipulate that the they will be 11 contractually bound by the terms of this agreement beyond FINAL DISPOSITION, 12 but will have to file a separate action for enforcement of the agreement once all 13 proceedings in this case are complete. 14 Once a case proceeds to trial, information that was designated as 15 CONFIDENTIAL or maintained pursuant to this protective order used or introduced 16 as an exhibit at trial becomes public and will be presumptively available to all 17 members of the public, including the press, unless compelling reasons supported by 18 specific factual findings to proceed otherwise are made to the trial judge in advance 19 of the trial. See Kamakana,

(distinguishing “good cause” 20 showing for sealing documents produced in discovery from “compelling reasons” 21 standard when merits-related documents are part of court record). Accordingly, for 22 such materials, the terms of this protective order do not extend beyond the 23 commencement of the trial. 24

25 5. DESIGNATING PROTECTED MATERIAL 26 5.1 Exercise of Restraint and Care in Designating Material for Protection. 27 Each Party or Non-Party that designates information or items for protection under 28 6 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 77 ooff 1166 PPaaggee IIDD ##::662462

1 this Order must take care to limit any such designation to specific material that 2 qualifies under the appropriate standards. The Designating Party must designate for 3 protection only those parts of material, documents, items, or oral or written 4 communications that qualify so that other portions of the material, documents, items, 5 or communications for which protection is not warranted are not swept unjustifiably 6 within the ambit of this Order. 7 Mass, indiscriminate, or routinized designations are prohibited. Designations 8 that are shown to be clearly unjustified or that have been made for an improper 9 purpose (e.g., to unnecessarily encumber the case development process or to impose 10 unnecessary expenses and burdens on other parties) may expose the Designating 11 Party to sanctions. 12 If it comes to a Designating Party’s attention that information or items that it 13 designated for protection do not qualify for protection, that Designating Party must 14 promptly notify all other Parties that it is withdrawing the inapplicable designation. 15 5.2 Manner and Timing of Designations. Except as otherwise provided in 16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise 17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 18 under this Order must be clearly so designated before the material is disclosed or 19 produced. 20 Designation in conformity with this Order requires: 21 (a) for information in documentary form (e.g., paper or electronic 22 documents, but excluding transcripts of depositions or other pretrial or trial 23 proceedings), that the Producing Party affix at a minimum, the legend 24 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 25 contains protected material. If only a portion or portions of the material on a page 26 qualifies for protection, the Producing Party also must clearly identify the protected 27 portion(s) (e.g., by making appropriate markings in the margins). 28 A Party or Non-Party that makes original documents available for inspection 7 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 88 ooff 1166 PPaaggee IIDD ##::662473

1 need not designate them for protection until after the inspecting Party has indicated 2 which documents it would like copied and produced. During the inspection and 3 before the designation, all of the material made available for inspection shall be 4 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 5 documents it wants copied and produced, the Producing Party must determine which 6 documents, or portions thereof, qualify for protection under this Order. Then, before 7 producing the specified documents, the Producing Party must affix the 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 10 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 11 markings in the margins). 12 (b) for testimony given in depositions that the Designating Party identify 13 the Disclosure or Discovery Material on the record, before the close of the deposition 14 all protected testimony. 15 (c) for information produced in some form other than documentary and for 16 any other tangible items, that the Producing Party affix in a prominent place on the 17 exterior of the container or containers in which the information is stored the legend 18 “CONFIDENTIAL.” If only a portion or portions of the information warrants 19 protection, the Producing Party, to the extent practicable, shall identify the protected 20 portion(s). 21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 22 failure to designate qualified information or items does not, standing alone, waive 23 the Designating Party’s right to secure protection under this Order for such material. 24 Upon timely correction of a designation, the Receiving Party must make reasonable 25 efforts to assure that the material is treated in accordance with the provisions of this 26 Order. 27 28 8 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 99 ooff 1166 PPaaggee IIDD ##::662484

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 3 designation of confidentiality at any time that is consistent with the Court’s 4 Scheduling Order. 5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute 6 resolution process under Local Rule 37.1 et seq. 7 6.3 The burden of persuasion in any such challenge proceeding shall be on 8 the Designating Party. Frivolous challenges, and those made for an improper purpose 9 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may 10 expose the Challenging Party to sanctions. Unless the Designating Party has waived 11 or withdrawn the confidentiality designation, all parties shall continue to afford the 12 material in question the level of protection to which it is entitled under the Producing 13 Party’s designation until the Court rules on the challenge. 14 15 7. ACCESS TO AND USE OF PROTECTED MATERIAL 16 7.1 Basic Principles. A Receiving Party may use Protected Material that is 17 disclosed or produced by another Party or by a Non-Party in connection with this 18 Action only for prosecuting, defending, or attempting to settle this Action. Such 19 Protected Material may be disclosed only to the categories of persons and under the 20 conditions described in this Order. When the Action has been terminated, a 21 Receiving Party must comply with the provisions of section 13 below (FINAL 22 DISPOSITION). 23 Protected Material must be stored and maintained by a Receiving Party at a 24 location and in a secure manner that ensures that access is limited to the persons 25 authorized under this Order. 26 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 27 otherwise ordered by the court or permitted in writing by the Designating Party, a 28 9 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 1100 ooff 1166 PPaaggee IIDD ##::662495

1 Receiving Party may disclose any information or item designated 2 “CONFIDENTIAL” only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well 4 as employees of said Outside Counsel of Record to whom it is reasonably necessary 5 to disclose the information for this Action; 6 (b) the officers, directors, and employees (including House Counsel) of the 7 Receiving Party to whom disclosure is reasonably necessary for this Action; 8 (c) Experts (as defined in this Order) of the Receiving Party to whom 9 disclosure is reasonably necessary for this Action and who have signed the 10 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 11 (d) the court and its personnel; 12 (e) court reporters and their staff; 13 (f) professional jury or trial consultants, mock jurors, and Professional 14 Vendors to whom disclosure is reasonably necessary for this Action and who have 15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 16 (g) the author or recipient of a document containing the information or a 17 custodian or other person who otherwise possessed or knew the information; 18 (h) during their depositions, witnesses ,and attorneys for witnesses, in the 19 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 20 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will 21 not be permitted to keep any confidential information unless they sign the 22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 23 agreed by the Designating Party or ordered by the court. Pages of transcribed 24 deposition testimony or exhibits to depositions that reveal Protected Material may 25 be separately bound by the court reporter and may not be disclosed to anyone except 26 as permitted under this Stipulated Protective Order; and 27 (i) any mediator or settlement officer, and their supporting personnel, 28 mutually agreed upon by any of the parties engaged in settlement discussions. 10 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 1111 ooff 1166 PPaaggee IIDD ##::663406

1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 2 IN OTHER LITIGATION 3 If a Party is served with a subpoena or a court order issued in other litigation 4 that compels disclosure of any information or items designated in this Action as 5 “CONFIDENTIAL,” that Party must: 6 (a) promptly notify in writing the Designating Party. Such notification shall 7 include a copy of the subpoena or court order; 8 (b) promptly notify in writing the party who caused the subpoena or order 9 to issue in the other litigation that some or all of the material covered by the subpoena 10 or order is subject to this Protective Order. Such notification shall include a copy of 11 this Stipulated Protective Order; and 12 (c) cooperate with respect to all reasonable procedures sought to be pursued 13 by the Designating Party whose Protected Material may be affected. 14 If the Designating Party timely seeks a protective order, the Party served 15 with the subpoena or court order shall not produce any information designated in this 16 action as “CONFIDENTIAL” before a determination by the court from which the 17 subpoena or order issued, unless the Party has obtained the Designating Party’s 18 permission. The Designating Party shall bear the burden and expense of seeking 19 protection in that court of its confidential material and nothing in these provisions 20 should be construed as authorizing or encouraging a Receiving Party in this Action 21 to disobey a lawful directive from another court. 22

23 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT 24 TO BE PRODUCED IN THIS LITIGATION 25 (a) The terms of this Order are applicable to information produced by a 26 Non-Party in this Action and designated as “CONFIDENTIAL.” Such information 27 produced by Non-Parties in connection with this litigation is protected by the 28 11 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 1122 ooff 1166 PPaaggee IIDD ##::663417

1 remedies and relief provided by this Order. Nothing in these provisions should be 2 construed as prohibiting a Non-Party from seeking additional protections. 3 (b) In the event that a Party is required, by a valid discovery request, to 4 produce a Non-Party’s confidential information in its possession, and the Party is 5 subject to an agreement with the Non-Party not to produce the Non-Party’s 6 confidential information, then the Party shall: 7 (1) promptly notify in writing the Requesting Party and the Non-Party 8 that some or all of the information requested is subject to a confidentiality agreement 9 with a Non-Party; 10 (2) promptly provide the Non-Party with a copy of the Stipulated 11 Protective Order in this Action, the relevant discovery request(s), and a reasonably 12 specific description of the information requested; and 13 (3) make the information requested available for inspection by the 14 Non-Party, if requested. 15 (c) If the Non-Party fails to seek a protective order from this court within 16 14 days of receiving the notice and accompanying information, the Receiving Party 17 may produce the Non-Party’s confidential information responsive to the discovery 18 request. If the Non-Party timely seeks a protective order, the Receiving Party shall 19 not produce any information in its possession or control that is subject to the 20 confidentiality agreement with the Non-Party before a determination by the court. 21 Absent a court order to the contrary, the Non-Party shall bear the burden and expense 22 of seeking protection in this court of its Protected Material. 23 24 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 25 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 26 Protected Material to any person or in any circumstance not authorized under this 27 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 28 12 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 1133 ooff 1166 PPaaggee IIDD ##::663428

1 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 2 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 3 persons to whom unauthorized disclosures were made of all the terms of this Order, 4 and (d) request such person or persons to execute the “Acknowledgment and 5 Agreement to Be Bound” that is attached hereto as Exhibit A. 6 7 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 8 PROTECTED MATERIAL 9 When a Producing Party gives notice to Receiving Parties that certain 10 inadvertently produced material is subject to a claim of privilege or other protection, 11 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 12 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 13 may be established in an e-discovery order that provides for production without prior 14 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 15 parties reach an agreement on the effect of disclosure of a communication or 16 information covered by the attorney-client privilege or work product protection, the 17 parties may incorporate their agreement in the stipulated protective order submitted 18 to the court. 19

20 12. MISCELLANEOUS 21 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 22 person to seek its modification by the Court in the future. 23 12.2 Right to Assert Other Objections. By stipulating to the entry of this 24 Protective Order no Party waives any right it otherwise would have to object to 25 disclosing or producing any information or item on any ground not addressed in this 26 Stipulated Protective Order. Similarly, no Party waives any right to object on any 27 ground to use in evidence of any of the material covered by this Protective Order. 28 13 CCaassee 22::2222--ccvv--0011669922--JJWWHH--PPDD DDooccuummeenntt 5523 FFiilleedd 1100//2200//2222 PPaaggee 1144 ooff 1166 PPaaggee IIDD ##::663439

1 12.3 Filing Protected Material. A Party that seeks to file under seal any 2 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 3 only be filed under seal pursuant to a court order authorizing the sealing of the 4 specific Protected Material at issue. If a Party's request to file Protected Material 5 under seal is denied by the court, then the Receiving Party may file the information 6 in the public record unless otherwise instructed by the court. 7 8 13. FINAL DISPOSITION 9 After the final disposition of this Action, as defined in paragraph 4, within 60 10 days of a written request by the Designating Party, each Receiving Party must return 11 all Protected Material to the Producing Party or destroy such material. As used in 12 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 13 summaries, and any other format reproducing or capturing any of the Protected 14 Material. Whether the Protected Material is returned or destroyed, the Receiving 15 Party must submit a written certification to the Producing Party (and, if not the same 16 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 17 (by category, where appropriate) all the Protected Material that was returned or 18 destroyed and (2)affirms that the Receiving Party has not retained any copies, 19 abstracts, compilations, summaries or any other format reproducing or capturing any 20 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 21 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 22 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 23 reports, attorney work product, and consultant and expert work product, even if such 24 materials contain Protected Material. Any such archival copies that contain or 25 constitute Protected Material remain subject to this Protective Order as set forth in 26 Section 4 (DURATION). 27 28 14 Case #:22-cv-01692-JWH-PD Document 52 Filed 10/20/22 Page15o0f16 Page ID #:6598

1 || 14. Any violation of this Order may be punished by any and all appropriate 2 || measures including, without limitation, contempt proceedings and/or monetary 3 || sanctions. 5 || IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 7 || DATED: October 20, 2022 9 || /s/ Yu Hao Yao 10 Attorneys for Plaintiff Zhejiang Yuanzheng Auto & Motorcycle Accessories Co., Ltd. 12 3 DATED: October 20, 2022 14 15. || S/AllexanderChen Attorneys for Defendant 16 Arex Industries, Inc. 17 18 '? || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 71 || DATED: October 20, 2022 22 23 hizticcea Denahi 24 || Patric a “onahue 05 United States Magistrate Judge 26 27 28 15

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1 EXHIBIT A ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2

3 I, ________________________ [print or type full name], of 4 _________________ [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issued by the United States District Court for the Central District of California 7 on [date] in the case of __________ [insert formal name of the case and the 8 number and initials assigned to it by the court]. I agree to comply with and to 9 be bound by all the terms of this Stipulated Protective Order and I understand and 10 acknowledge that failure to so comply could expose me to sanctions and 11 punishment in the nature of contempt. I solemnly promise that I will not disclose 12 in any manner any information or item that is subject to this Stipulated Protective 13 Order to any person or entity except in strict compliance with the provisions of this 14 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 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 telephone number] as 20 my California agent for service of process in connection with this action or any 21 proceedings related to enforcement of this Stipulated Protective Order. 22

23 Date: __________________________ 24 City and State where sworn and signed: _____________________________ 25

26 Printed name: ____________________________________ 27

28 Signature: ________________________________ 16