1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 NETWORK-1 TECHNOLOGIES, Case No. 8:22-CV-02087-CJC-JDE INC., 12 STIPULATION AND PROTECTIVE Plaintiff, ORDER 13 v. Complaint Filed: Nov. 16, 2022 14 DAHUA TECHNOLOGY USA 15 INC., 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 1 1. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than pursuing this litigation may be 5 warranted. Accordingly, the parties hereby stipulate to and petition the Court to 6 enter the following Stipulated Protective Order. The parties acknowledge that this 7 Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. 11 2. GOOD CAUSE STATEMENT 12 This action is likely to involve trade secrets, customer and pricing lists and 13 other valuable research, development, commercial, financial, technical and/or 14 proprietary information for which special protection from public disclosure and 15 from use for any purpose other than prosecution of this action is warranted. Such 16 confidential and proprietary materials and information consist of, among other 17 things, confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, development, or 19 commercial information (including information implicating privacy rights of third 20 parties), information otherwise generally unavailable to the public, or which may be 21 privileged or otherwise protected from disclosure under state or federal statutes, 22 court rules, case decisions, or common law. Accordingly, to expedite the flow of 23 information, to facilitate the prompt resolution of disputes over confidentiality of 24 discovery materials, to adequately protect information the parties are entitled to 25 keep confidential, to ensure that the parties are permitted reasonable necessary uses 26 of such material in preparation for and in the conduct of trial, to address their 27 handling at the end of the litigation, and serve the ends of justice, a Protective Order 28 1 for such information is justified in this matter. It is the intent of the parties that 2 information will not be designated as confidential for tactical reasons and that 3 nothing be so designated without a good faith belief that it has been maintained in a 4 confidential, non-public manner, and there is good cause why it should not be part 5 of the public record of this case. 6 3. ACKNOWLEDGMENT OF UNDER SEAL FILING 7 PROCEDURE 8 The parties further acknowledge, as set forth in Section 14.3, below, that this 9 Stipulated Protective Order does not entitle them to file confidential information 10 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed 11 and the standards that will be applied when a party seeks permission from the Court 12 to file material under seal. There is a strong presumption that the public has a right 13 of access to judicial proceedings and records in civil cases. In connection with non- 14 dispositive motions, good cause must be shown to support a filing under seal. See 15 Kamakana v. City and County of Honolulu,

(9th Cir. 2006), 16 Phillips v. Gen. Motors Corp.,

, 1210-11 (9th Cir. 2002), Makar- 17 Welbon v. Sony Electrics, Inc.,

(E.D. Wis. 1999) (even 18 stipulated protective orders require good cause showing), and a specific showing of 19 good cause or compelling reasons with proper evidentiary support and legal 20 justification, must be made with respect to Protected Material that a party seeks to 21 file under seal. The parties’ mere designation of Disclosure or Discovery Material 22 as CONFIDENTIAL does not— without the submission of competent evidence by 23 declaration, establishing that the material sought to be filed under seal qualifies as 24 confidential, privileged, or otherwise protectable—constitute good cause. 25 Further, if a party requests sealing related to a dispositive motion or trial, 26 then compelling reasons, not only good cause, for the sealing must be shown, and 27 the relief sought shall be narrowly tailored to serve the specific interest to be 28 1 protected. See Pintos v. Pacific Creditors Ass’n.,

(9th Cir. 2 2010). For each item or type of information, document, or thing sought to be filed 3 or introduced under seal, the party seeking protection must articulate compelling 4 reasons, supported by specific facts and legal justification, for the requested sealing 5 order. Again, competent evidence supporting the application to file documents 6 under seal must be provided by declaration. 7 Any document that is not confidential, privileged, or otherwise protectable in 8 its entirety will not be filed under seal if the confidential portions can be redacted. 9 If documents can be redacted, then a redacted version for public viewing, omitting 10 only the confidential, privileged, or otherwise protectable portions of the document, 11 shall be filed. Any application that seeks to file documents under seal in their 12 entirety should include an explanation of why redaction is not feasible. 13 4. DEFINITIONS 14 4.1 Action: Network-1 Technologies, Inc. v. Dahua Technology USA 15 Inc., Case No. 8:22-CV-02087-CJC-JDE. 16 4.2 Challenging Party: a Party or Non-Party that challenges the 17 designation of information or items under this Order. 18 4.3 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE 19 COUNSEL’S EYES ONLY” Information or Items: information (regardless of how 20 it is generated, stored or maintained) or tangible things that qualify for protection 21 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good 22 Cause Statement. 23 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as 24 their support staff). 25 4.5 Designating Party: a Party or Non-Party that designates information or 26 items that it produces in disclosures or in responses to discovery as 27 28 1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S 2 EYES ONLY.” 3 4.6 Disclosure or Discovery Material: all items or information, regardless 4 of the medium or manner in which it is generated, stored, or maintained (including, 5 among other things, testimony, transcripts, and tangible things), that are produced 6 or generated in disclosures or responses to discovery. 7 4.7 Expert: a person with specialized knowledge or experience in a matter 8 pertinent to the litigation who has been retained by a Party or its counsel to serve as 9 an expert witness or as a consultant in this Action. 10 4.8 House Counsel: attorneys who are employees of a party to this Action. 11 House Counsel does not include Outside Counsel of Record or any other outside 12 counsel. 13 4.9 Non-Party: any natural person, partnership, corporation, association, or 14 other legal entity not named as a Party to this action. 15 4.10 Outside Counsel of Record: attorneys who are not employees of a 16 party to this Action but are retained to represent a party to this Action and have 17 appeared in this Action on behalf of that party or are affiliated with a law firm that 18 has appeared on behalf of that party, and includes support staff. 19 4.11 Party: any party to this Action, including all of its officers, directors, 20 employees, consultants, retained experts, and Outside Counsel of Record (and their 21 support staffs). 22 4.12 Producing Party: a Party or Non-Party that produces Disclosure or 23 Discovery Material in this Action. 24 4.13 Professional Vendors: persons or entities that provide litigation 25 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 26 demonstrations, and organizing, storing, or retrieving data in any form or medium) 27 and their employees and subcontractors. 28 1 4.14 Protected Material: any Disclosure or Discovery Material that is 2 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE 3 COUNSEL’S EYES ONLY.” 4 4.15 Receiving Party: a Party that receives Disclosure or Discovery 5 Material from a Producing Party. 6 5. SCOPE 7 The protections conferred by this Stipulation and Order cover not only 8 Protected Material (as defined above), but also (1) any information copied or 9 extracted from Protected Material; (2) all copies, excerpts, summaries, or 10 compilations of Protected Material; and (3) any testimony, conversations, or 11 presentations by Parties or their Counsel that might reveal Protected Material. 12 Any use of Protected Material at trial shall be governed by the orders of the 13 trial judge and other applicable authorities. This Order does not govern the use of 14 Protected Material at trial. 15 6. DURATION 16 Once a case proceeds to trial, information that was designated as 17 CONFIDENTIAL or maintained pursuant to this Protective Order used or 18 introduced as an exhibit at trial becomes public and will be presumptively available 19 to all members of the public, including the press, unless compelling reasons 20 supported by specific factual findings to proceed otherwise are made to the trial 21 judge in advance of the trial. See Kamakana,

(distinguishing 22 “good cause” showing for sealing documents produced in discovery from 23 “compelling reasons” standard when merits-related documents are part of court 24 record). Accordingly, the terms of this Protective Order do not extend beyond the 25 commencement of the trial. 26 7. DESIGNATING PROTECTED MATERIAL 27 7.1 Exercise of Restraint and Care in Designating Material for 28 1 Protection. Each Party or Non-Party that designates information or 2 items for protection under this Order must take care to limit any such designation to 3 specific material that qualifies under the appropriate standards. The Designating 4 Party must designate for protection only those parts of material, documents, items 5 or oral or written communications that qualify so that other portions of the material, 6 documents, items or communications for which protection is not warranted are not 7 swept unjustifiably within the ambit of this Order. 8 Mass, indiscriminate or routinized designations are prohibited. Designations 9 that are shown to be clearly unjustified or that have been made for an improper 10 purpose (e.g., to unnecessarily encumber the case development process or to 11 impose unnecessary expenses and burdens on other parties) may expose the 12 Designating Party to sanctions. 13 If it comes to a Designating Party’s attention that information or items that it 14 designated for protection do not qualify for protection, that Designating Party must 15 promptly notify all other Parties that it is withdrawing the inapplicable designation. 16 7.2 Manner and Timing of Designations. Except as otherwise provided in 17 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material 18 that qualifies for protection under this Order must be clearly so designated before 19 the material is disclosed or 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” or “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S 25 EYES ONLY” (hereinafter “CONFIDENTIAL legend” or “HIGHLY 26 CONFIDENTIAL legend” respectively), to each page that contains protected 27 material. If only a portion of the material on a page qualifies for protection, the 28 1 Producing Party also must clearly identify the protected portion(s) (e.g., by making 2 appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and 6 before the designation, all of the material made available for inspection shall be 7 deemed at least “CONFIDENTIAL.” After the inspecting Party has identified the 8 documents it wants copied and produced, the Producing Party must determine 9 which documents, or portions thereof, qualify for protection under this Order. Then, 10 before producing the specified documents, the Producing Party must affix the 11 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL legend” to each page 12 that contains Protected Material. If only a portion of the material on a page qualifies 13 for protection, the Producing Party also must clearly identify the protected 14 portion(s) (e.g., by making appropriate markings in the margins). 15 (b) for testimony given in depositions that the Designating Party 16 identifies the Disclosure or Discovery Material on the record, before the close of 17 the deposition all protected testimony. 18 (c) for information produced in some form other than documentary and 19 for any other tangible items, that the Producing Party affix in a prominent place on 20 the exterior of the container or containers in which the information is stored the 21 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE 22 COUNSEL’S EYES ONLY.” If only a portion or portions of the information 23 warrants protection, the Producing Party, to the extent practicable, shall identify the 24 protected portion(s). 25 (d) to the extent a Producing Party believes that certain Protective Material 26 qualifying to be designated CONFIDENTIAL is so sensitive that its dissemination 27 deserves even further limitation, including information that is highly confidential 28 1 and/or sensitive in nature, the disclosure of which the Producing Party reasonably 2 believes is likely to cause economic harm or significant competitive disadvantage to 3 the Producing Party or a Non-Party, the Producing Party may designate such 4 Protected Material “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S EYES 5 ONLY.” 6 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 7 failure to designate qualified information or items does not, standing alone, waive 8 the Designating Party’s right to secure protection under this Order for such 9 material. Upon timely correction of a designation, the Receiving Party must make 10 reasonable efforts to assure that the material is treated in accordance with the 11 provisions of this Order. 12 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 8.1. Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s 15 Scheduling Order. 16 8.2 Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Rule 37-1 et seq. 18 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a 19 joint stipulation pursuant to Local Rule 37-2. 20 8.4 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. 28 1 9. ACCESS TO AND USE OF PROTECTED MATERIAL 2 9.1 Basic Principles. A Receiving Party may use Protected Material that is 3 disclosed or produced by another Party or by a Non-Party in connection with this 4 Action only for prosecuting, defending or attempting to settle this Action. Such 5 Protected Material may be disclosed only to the categories of persons and under the 6 conditions described in this Order. When the Action has been terminated, a 7 Receiving Party must comply with the provisions of section 15 below (FINAL 8 DISPOSITION). 9 Protected Material must be stored and maintained by a Receiving Party at a 10 location and in a secure manner that ensures that access is limited to the persons 11 authorized under this Order. 12 9.2 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) the Receiving Party’s Outside Counsel of Record in this Action, as 17 well as employees of said Outside Counsel of Record to whom it is reasonably 18 necessary to disclose the information for this Action; 19 (b) up to and including five (5) designated representatives (including 20 House Counsel) of the Receiving Party to whom disclosure is reasonably necessary 21 for this Action; 22 (c) Experts (as defined in this Order) of the Receiving Party to whom 23 disclosure is reasonably necessary for this Action and who have signed the 24 “Acknowledgment and Agreement to Be Bound” (Exhibit A) ; 25 (d) the court and its personnel; 26 (e) court reporters and their staff; 27 (f) professional jury or trial consultants, mock jurors, and Professional 28 1 Vendors to whom disclosure is reasonably necessary for this Action and who have 2 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 3 (g) the author or recipient of a document containing the information or 4 a custodian or other person who otherwise possessed or knew the information; 5 (h) during their depositions, witnesses, and attorneys for witnesses, in 6 the Action to whom disclosure is reasonably necessary provided: (1) the deposing 7 party requests that the witness sign the form attached as Exhibit A hereto; and (2) 8 they will not be permitted to keep any confidential information unless they sign the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 10 agreed by the Designating Party or ordered by the court. Pages of transcribed 11 deposition testimony or exhibits to depositions that reveal Protected Material may 12 be separately bound by the court reporter and may not be disclosed to anyone 13 except as permitted under this Stipulated Protective Order; and 14 (i) any mediators or settlement officers and their supporting personnel, 15 mutually agreed upon by any of the parties engaged in settlement discussions. 16 9.3 Disclosure of “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S 17 EYES ONLY” Information or Items. Unless otherwise ordered by the court or 18 permitted in writing by the Designating Party, a Receiving Party may disclose any 19 information or item designated “HIGHLY CONFIDENTIAL – OUTSIDE 20 COUNSEL’S EYES ONLY” only to individuals listed in paragraphs 9.2(a), and 21 (c)-(i). 22 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED 23 PRODUCED IN OTHER LITIGATION 24 If a Party is served with a subpoena or a court order issued in other litigation 25 that compels disclosure of any information or items designated in this Action as 26 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S 27 EYES ONLY,” that Party must: 28 1 (a) promptly notify in writing the Designating Party. Such notification 2 shall include a copy of the subpoena or court order; 3 (b) promptly notify in writing the party who caused the subpoena or 4 order to issue in the other litigation that some or all of the material covered by the 5 subpoena or order is subject to this Protective Order. Such notification shall include 6 a copy of this Stipulated Protective Order; and 7 (c) cooperate with respect to all reasonable procedures sought to be 8 pursued by the Designating Party whose Protected Material may be affected. If the 9 Designating Party timely seeks a protective order, the Party served with the 10 subpoena or court order shall not produce any information designated in this action 11 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL’S 12 EYES ONLY” before a determination by the court from which the subpoena or 13 order issued, unless the Party has obtained the Designating Party’s permission. The 14 Designating Party shall bear the burden and expense of seeking protection in that 15 court of its confidential material and nothing in these provisions should be 16 construed as authorizing or encouraging a Receiving Party in this Action to disobey 17 a lawful directive from another court. 18 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO 19 BE PRODUCED IN THIS LITIGATION 20 (a) The terms of this Order are applicable to information produced by a 21 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY 22 CONFIDENTIAL – OUTSIDE COUNSEL’S EYES ONLY.” Such information 23 produced by Non-Parties in connection with this litigation is protected by the 24 remedies and relief provided by this Order. Nothing in these provisions should be 25 construed as prohibiting a Non-Party from seeking additional protections. 26 (b) In the event that a Party is required, by a valid discovery request, to 27 produce a Non-Party’s confidential information in its possession, and the Party is 28 1 subject to an agreement with the Non-Party not to produce the Non-Party’s 2 confidential information, then the Party shall: 3 (1) promptly notify in writing the Requesting Party and the Non-Party 4 that some or all of the information requested is subject to a confidentiality 5 agreement with a Non-Party; 6 (2) promptly provide the Non-Party with a copy of the Stipulated 7 Protective Order in this Action, the relevant discovery request(s), and a reasonably 8 specific description of the information requested; and 9 (3) make the information requested available for inspection by the 10 Non-Party, if requested. 11 (c) If the Non-Party fails to seek a protective order from this court 12 within 14 days of receiving the notice and accompanying information, the 13 Receiving Party may produce the Non-Party’s confidential information responsive 14 to the discovery request. If the Non-Party timely seeks a protective order, the 15 Receiving Party shall not produce any information in its possession or control that 16 is subject to the confidentiality agreement with the Non-Party before a 17 determination by the court. Absent a court order to the contrary, the Non-Party shall 18 bear the burden and expense of seeking protection in this court of its Protected 19 Material. 20 12. UNAUTHORIZED DISCLOSURE OF PROTECTED 21 MATERIAL 22 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 23 Protected Material to any person or in any circumstance not authorized under this 24 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 25 writing the Designating Party of the unauthorized disclosures, (b) use its best 26 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the 27 person or persons to whom unauthorized disclosures were made of all the terms of 28 1 this Order, and (d) request such person or persons to execute the “Acknowledgment 2 and Agreement to Be Bound” attached hereto as Exhibit A. 3 13. INADVERTENT PRODUCTION OF PRIVILEGED OR 4 OTHERWISE PROTECTED MATERIAL 5 When a Producing Party gives notice to Receiving Parties that certain 6 inadvertently produced material is subject to a claim of privilege or other 7 protection, the obligations of the Receiving Parties are those set forth in Federal 8 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify 9 whatever procedure may be established in an e-discovery order that provides for 10 production without prior privilege review. Pursuant to Federal Rule of Evidence 11 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure 12 of a communication or information covered by the attorney-client privilege or work 13 product protection, the parties may incorporate their agreement in the stipulated 14 protective order submitted to the court. 15 Nothing in this Order shall require the production of documents, information 16 or other material that a Party contends is protected from disclosure by the attorney- 17 client privilege, the work product doctrine, or other privilege, doctrine, or 18 immunity. If document, information or other material subject to a claim of attorney- 19 client privilege, work product doctrine, or other privilege, doctrine, or immunity is 20 inadvertently or unintentionally produced, such production shall in no way 21 prejudice or otherwise constitute a waiver of, or estoppel as to, any such privilege, 22 doctrine, or immunity. 23 14. MISCELLANEOUS 24 14.1 Right to Further Relief. Nothing in this Order abridges the right of any 25 person to seek its modification by the Court in the future. 26 14.2 Right to Assert Other Objections. By stipulating to the entry of this 27 28 1 Protective Order, no Party waives any right it otherwise would have to object to 2 disclosing or producing any information or item on any ground not addressed in 3 this Stipulated Protective Order. Similarly, no Party waives any right to object on 4 any ground to use in evidence of any of the material covered by this Protective 5 Order. 6 14.3 Filing Protected Material. A Party that seeks to file under seal any 7 Protected Material must comply with Local Civil Rule 79-5. Protected Material 8 may only be filed under seal pursuant to a court order authorizing the sealing of the 9 specific Protected Material. If a Party’s request to file Protected Material under seal 10 is denied by the court, then the Receiving Party may file the information in the 11 public record unless otherwise instructed by the court. 12 15. FINAL DISPOSITION 13 After the final disposition of this Action, as defined in paragraph 6, within 60 14 days of a written request by the Designating Party, each Receiving Party must 15 return all Protected Material to the Producing Party or destroy such material. As 16 used in this subdivision, “all Protected Material” includes all copies, abstracts, 17 compilations, summaries, and any other format reproducing or capturing any of the 18 Protected Material. Whether the Protected Material is returned or destroyed, the 19 Receiving Party must submit a written certification to the Producing Party (and, if 20 not the same person or entity, to the Designating Party) by the 60-day deadline that 21 (1) identifies (by category, where appropriate) all the Protected Material that was 22 returned or destroyed and (2) affirms that the Receiving Party has not retained any 23 copies, abstracts, compilations, summaries or any other format reproducing or 24 capturing any of the Protected Material. Notwithstanding this provision, Counsel 25 are entitled to retain an archival copy of all pleadings, motion papers, trial, 26 deposition, and hearing transcripts, legal memoranda, correspondence, deposition 27 and trial exhibits, expert reports, attorney work product, and consultant and expert 28 1 || work product, even if such materials contain Protected Material. Any such archival 2 || copies that contain or constitute Protected Material remain subject to this Protective 3 || Order as set forth in Section 6 (DURATION). 4 16. MIOLATION 5 Any violation of this Order may be punished by appropriate measures 6 || including, without limitation, contempt proceedings and/or monetary sanctions. 7 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 8 || DATED: October 25, 2023 Respectfully submitted, ° DOVEL & LUNER LLP 10 11 By:__/s/ Richard Lyon 12 Richard Lyon 13 Counsel for Plaintiff Network-1 Technologies, Inc. 14 ! |! DATED: October 25, 2023 CROWELL & MORING LLP ] By:__/s/ Emily T. Kuwahara 17 Emily T. Kuwahara 18 Counsel for Defendant Dahua Technology USA Inc. 19 ATTESTATION

I, Emily T. Kuwahara, attests all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 23 54 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 95 || DATED: October 25, 2023 if de 26 , J D. EARLY 27 nited States Magistrate Judge 28 STIPULATION AND -16- PROTECTIVE ORDER;

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], declare under penalty of perjury that I 6 have read in its entirety and understand the Stipulated Protective Order that was 7 issued by the United States District Court for the Central District of California on 8 [date] in the case of Network-1 Technologies, Inc. v. Dahua Technology USA Inc., 9 Case No. 8:22-cv-02087-CJC-JDE. I agree to comply with and to be bound by all 10 the terms of this Stipulated Protective Order and I understand and acknowledge that 11 failure to so comply could expose me to sanctions and punishment in the nature of 12 contempt. I solemnly promise that I will not disclose in any manner any 13 information or item that is subject to this Stipulated Protective Order to any person 14 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 type 19 full name] of ____________________________________ [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23

24 Date: _____________________________________________ 25 City and State where sworn and signed: _______________ 26 Printed name: ________________________ 27 Signature: ________________________ 28