! || LAW OFFICES OF RONALD A. MARRON 2 || RONALD A. MARRON (SBN 175650) [email protected] 3 || LILACH HALPERIN (SBN 323202) 4 || [email protected] 651 Arroyo Drive > San Diego, California 92103 6 || Telephone: (619) 696-9006 Facsimile: (619) 564-6665 Attorneys for Plaintiff and the Proposed Classes 8 . CHRISTINA GUEROLA SARCHIO (pro hac vice) 9 Email: [email protected] DECHERT LLP 10 1900 K Street, N.W. Washington, DC 20006-1110 1] Telephone: +1 202 261 3300 Facsimile: +1 202 261 3333

13 || Attorney for Defendant GSK Consumer Health, Inc. 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 TASHAUNA SEALE, individually 17 and on behalf of all others similarly Case No. 2:23-—cv—00842-AB-MRW ig situated, oe STIPULATED PROTECTIVE 19 Plaintiff, ORDER 20 V. (MRW VERSION 4/19) 2] GSK CONSUMER HEALTH, INC., Check if submitted without dba HALEON, material modifications to MRW form 23 Defendant. 24 25 26 27 28

1 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action is likely to involve production of confidential, 4 proprietary, or private information for which special protection from public 5 disclosure and from use for any purpose other than prosecuting this litigation may 6 be warranted. Accordingly, the parties hereby stipulate to and petition the Court to 7 enter the following Stipulated Protective Order. The parties acknowledge that this 8 Order does not confer blanket protections on all disclosures or responses to 9 discovery and that the protection it affords from public disclosure and use extends 10 only to the limited information or items that are entitled to confidential treatment 11 under the applicable legal principles. The parties further acknowledge, as set forth 12 in Section 12.3, below, that this Stipulated Protective Order does not entitle them to 13 file confidential information under seal; Civil Local Rule 79-5 sets forth the 14 procedures that must be followed and the standards that will be applied when a party 15 seeks permission from the court to file material under seal. 16 1.2 GOOD CAUSE STATEMENT 17 Disclosure and discovery activity in this action are likely to involve production of 18 confidential, proprietary, or private information (e.g., trade secrets, sales data, class 19 member contact information, internal business strategy, and sensitive information). 20 Based on the allegations in the Second Amended Complaint, Defendant anticipates 21 that Plaintiff will seek discovery into numerous of Defendant’s business decisions as 22 it relates to the pricing of the at-issue products, including any purported suggested 23 retail pricing, any evaluation of any suggested pricing, and any evaluation as it 24 relates to the labeling of the at-issue products and how that label could, if at all, 25 impact pricing. Courts have found that good cause and a “compelling reason” to seal 26 data of this nature as it could result in improper use by Defendant’s competitors. See 27 Lucas v. Breg, Inc.,

, at *2 (S.D. Cal. Sept. 28, 2016) (citing 1 2. DEFINITIONS 2 2.1 Action: Seale v. GSK Consumer Health, Inc., dba Haleon, Case No. 3 2:23-cv-00842-AB-MRW. 4 2.2 Challenging Party: a Party or Non-Party that challenges the 5 designation of information or items under this Order. 6 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 7 how it is generated, stored or maintained) or tangible things that qualify for 8 protection under Federal Rule of Civil Procedure 26(c), and as specified above in 9 the Good Cause Statement. 10 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 11 their support staff). 12 2.5 Designating Party: a Party or Non-Party that designates information or 13 items that it produces in disclosures or in responses to discovery as 14 “CONFIDENTIAL.” 15 2.6 Disclosure or Discovery Material: all items or information, regardless 16 of the medium or manner in which it is generated, stored, or maintained (including, 17 among other things, testimony, transcripts, and tangible things), that are produced or 18 generated in disclosures or responses to discovery in this matter. 19 2.7 Expert: a person with specialized knowledge or experience in a matter 20 pertinent to the litigation who has been retained by a Party or its counsel to serve as 21 an expert witness or as a consultant in this Action. 22 2.8 House Counsel: attorneys who are employees of a party to this Action. 23 House Counsel does not include Outside Counsel of Record or any other outside 24 counsel. 25 2.9 Non-Party: any natural person, partnership, corporation, association, or 26 other legal entity not named as a Party to this action. 27 2.10 Outside Counsel of Record: attorneys who are not employees of a 1 have appeared in this Action on behalf of that party or are affiliated with a law firm 2 which has appeared on behalf of that party, and includes support staff. 3 2.11 Party: any party to this Action, including all of its officers, directors, 4 employees, consultants, retained experts, and Outside Counsel of Record (and their 5 support staffs). 6 2.12 Producing Party: a Party or Non-Party that produces Disclosure or 7 Discovery Material in this Action. 8 2.13 Professional Vendors: persons or entities that provide litigation 9 support services (e.g., photocopying, videotaping, translating, preparing exhibits or 10 demonstrations, and organizing, storing, or retrieving data in any form or medium) 11 and their employees and subcontractors. 12 2.14 Protected Material: any Disclosure or Discovery Material that is 13 designated as “CONFIDENTIAL.” 14 2.15 Receiving Party: a Party that receives Disclosure or Discovery 15 Material from a Producing Party. 16 17 3. SCOPE 18 The protections conferred by this Stipulation and Order cover not only 19 Protected Material (as defined above), but also (1) any information copied or 20 extracted from Protected Material; (2) all copies, excerpts, summaries, or 21 compilations of Protected Material; and (3) any testimony, conversations, or 22 presentations by Parties or their Counsel that might reveal Protected Material. 23 Any use of Protected Material at trial will be governed by the orders of the 24 trial judge. This Order does not govern the use of Protected Material at trial. 25 26 4. DURATION 27 1 Even after final disposition of this litigation, the confidentiality obligations 2 imposed by this Order will remain in effect until a Designating Party agrees 3 otherwise in writing or a court order otherwise directs. Final disposition will be 4 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 5 or without prejudice; and (2) final judgment herein after the completion and 6 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 7 including the time limits for filing any motions or applications for extension of time 8 pursuant to applicable law. 9 10 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for Protection. 12 Each Party or Non-Party that designates information or items for protection under 13 this Order must take care to limit any such designation to specific material that 14 qualifies under the appropriate standards. The Designating Party must designate for 15 protection only those materials, documents, items, or oral or written 16 communications that qualify so that other materials, documents, items, or 17 communications for which protection is not warranted are not swept unjustifiably 18 within the ambit of this Order. 19 Mass, indiscriminate, or routinized designations are prohibited. Designations 20 that are shown to be clearly unjustified or that have been made for an improper 21 purpose (e.g., to unnecessarily encumber the case development process or to impose 22 unnecessary expenses and burdens on other parties) may expose the Designating 23 Party to sanctions. 24 If it comes to a Designating Party’s attention that information or items that it 25 designated for protection do not qualify for protection, that Designating Party must 26 promptly notify all other Parties that it is withdrawing the inapplicable designation. 27 5.2 Manner and Timing of Designations. Except as otherwise provided in 1 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 2 under this Order must be clearly so designated before the material is disclosed or 3 produced. 4 Designation in conformity with this Order requires: 5 (a) for information in documentary form (e.g., paper or electronic documents, 6 but excluding transcripts of depositions or other pretrial or trial proceedings), that 7 the Producing Party affix at a minimum, the legend “CONFIDENTIAL” (hereinafter 8 “CONFIDENTIAL legend”), to each page that contains protected material. 9 A Party or Non-Party that makes original documents available for 10 inspection need not designate them for protection until after the inspecting Party has 11 indicated which documents it would like copied and produced. During the 12 inspection and before the designation, all of the material made available for 13 inspection will be deemed “CONFIDENTIAL.” After the inspecting Party has 14 identified the documents it wants copied and produced, the Producing Party must 15 determine which documents qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix the 17 “CONFIDENTIAL legend” to each page that contains Protected Material. 18 (b) for testimony given in depositions that the Designating Party identify the 19 Disclosure or Discovery Material on the record, before the close of the deposition all 20 protected testimony. Alternatively, the Designating Party may provide written notice 21 that clearly identifies the protected portion(s) of the deposition testimony, sent by 22 counsel to all Parties on the same day that any errata would be due under the Federal 23 Rules of Civil Procedure, i.e., 30 days after bring notified by the officer that the 24 transcript or recording is available. 25 (c) for information produced in some form other than documentary and for 26 any other tangible items, that the Producing Party affix in a prominent place on the 27 exterior of the container or containers in which the information is stored the legend 1 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent 2 failure to designate qualified information or items does not, standing alone, waive 3 the Designating Party’s right to secure protection under this Order for such material. 4 Upon timely correction of a designation, the Receiving Party must make reasonable 5 efforts to assure that the material is treated in accordance with the provisions of this 6 Order. 7 8 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 9 6.1 Timing of Challenges. Any Party or Non-Party may challenge a 10 designation of confidentiality at any time that is consistent with the Court’s 11 Scheduling Order. 12 6.2 Meet and Confer. The Challenging Party will initiate the dispute 13 resolution process (and, if necessary, file a discovery motion) under Local Rule 37.1 14 et seq. 15 6.3 The burden of persuasion in any such challenge proceeding will be on 16 the Designating Party. Frivolous challenges, and those made for an improper 17 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 18 parties) may expose the Challenging Party to sanctions. Unless the Designating 19 Party has waived or withdrawn the confidentiality designation, all parties will 20 continue to afford the material in question the level of protection to which it is 21 entitled under the Producing Party’s designation until the Court rules on the 22 challenge. 23 24 7. ACCESS TO AND USE OF PROTECTED MATERIAL 25 7.1 Basic Principles. A Receiving Party may use Protected Material that is 26 disclosed or produced by another Party or by a Non-Party in connection with this 27 Action only for prosecuting, defending, or attempting to settle this Action. Such 1 conditions described in this Order. When the Action has been terminated, a 2 Receiving Party must comply with the provisions of section 13 below (FINAL 3 DISPOSITION). 4 Protected Material must be stored and maintained by a Receiving Party at a 5 location and in a secure manner that ensures that access is limited to the persons 6 authorized under this Order. 7 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 8 otherwise ordered by the court or permitted in writing by the Designating Party, a 9 Receiving Party may disclose any information or item designated 10 “CONFIDENTIAL” only to: 11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 12 well as employees of said Outside Counsel of Record to whom it is reasonably 13 necessary to disclose the information for this Action; 14 (b) the officers, directors, and employees (including House Counsel) of 15 the Receiving Party to whom disclosure is reasonably necessary for this Action; 16 (c) Experts (as defined in this Order) of the Receiving Party to whom 17 disclosure is reasonably necessary for this Action and who have signed the 18 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 19 (d) the Court and its personnel; 20 (e) court reporters and their staff; 21 (f) professional jury or trial consultants, mock jurors, and Professional 22 Vendors to whom disclosure is reasonably necessary for this Action and who have 23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 24 (g) the author or recipient of a document containing the information or a 25 custodian or other person who otherwise possessed or knew the information; 26 (h) during their depositions, witnesses, and attorneys for witnesses, in the 27 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 1 will not be permitted to keep any confidential information unless they sign the 2 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise 3 agreed by the Designating Party or ordered by the court. Pages of transcribed 4 deposition testimony or exhibits to depositions that reveal Protected Material may 5 be separately bound by the court reporter and may not be disclosed to anyone except 6 as permitted under this Stipulated Protective Order; and 7 (i) any mediator or settlement officer, and their supporting personnel, 8 mutually agreed upon by any of the parties engaged in settlement discussions. 9 10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 11 IN OTHER LITIGATION 12 If a Party is served with a subpoena or a court order issued in other litigation 13 that compels disclosure of any information or items designated in this Action as 14 “CONFIDENTIAL,” that Party must: 15 (a) promptly notify in writing the Designating Party within 14 days of its 16 receipt of such subpoena or court order. Such notification will include a copy of the 17 subpoena or court order; 18 (b) promptly notify in writing the party who caused the subpoena or order 19 to issue in the other litigation that some or all of the material covered by the 20 subpoena or order is subject to this Protective Order. Such notification will include 21 a copy of this Stipulated Protective Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be 23 pursued by the Designating Party whose Protected Material may be affected. 24 If the Designating Party timely seeks a protective order, the Party served with 25 the subpoena or court order will not produce any information designated in this 26 action as “CONFIDENTIAL” before a determination by the court from which the 27 subpoena or order issued, unless the Party has obtained the Designating Party’s 1 protection in that court of its confidential material and nothing in these provisions 2 should be construed as authorizing or encouraging a Receiving Party in this Action 3 to disobey a lawful directive from another court. 4 5 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 6 PRODUCED 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.” Such information 9 produced by Non-Parties in connection with this litigation is protected by the 10 remedies and relief provided by this Order. Nothing in these provisions should be 11 construed as prohibiting a Non-Party from seeking additional protections. 12 (b) In the event that a Party is required, by a valid discovery request, to 13 produce a Non-Party’s confidential information in its possession, and the Party is 14 subject to an agreement with the Non-Party not to produce the Non-Party’s 15 confidential information, then the Party will: 16 (1) promptly notify in writing the Requesting Party and the Non-Party 17 that some or all of the information requested is subject to a confidentiality 18 agreement with a Non-Party; 19 (2) promptly provide the Non-Party with a copy of the Stipulated 20 Protective Order in this Action, the relevant discovery request(s), and a reasonably 21 specific description of the information requested; and 22 (3) make the information requested available for inspection by the 23 Non-Party, if requested. 24 (c) If the Non-Party fails to seek a protective order from this court within 25 14 days of receiving the notice and accompanying information, the Receiving Party 26 may produce the Non-Party’s confidential information responsive to the discovery 27 request. If the Non-Party timely seeks a protective order, the Receiving Party will 1 confidentiality agreement with the Non-Party before a determination by the court. 2 Absent a court order to the contrary, the Non-Party will bear the burden and expense 3 of seeking protection in this court of its Protected Material. 4 5 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 6 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 7 Protected Material to any person or in any circumstance not authorized under this 8 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 9 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 10 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or 11 persons to whom unauthorized disclosures were made of all the terms of this Order, 12 and (d) request such person or persons to execute the “Acknowledgment and 13 Agreement to Be Bound” that is attached hereto as Exhibit A. 14 15 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 16 PROTECTED MATERIAL 17 When a Producing Party gives notice to Receiving Parties that certain 18 inadvertently produced material is subject to a claim of privilege or other protection, 19 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 20 Procedure 26(b)(5)(B). This provision is not intended to modify whatever 21 procedure may be established in an e-discovery order that provides for production 22 without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and 23 (e), insofar as the parties reach an agreement on the effect of disclosure of a 24 communication or information covered by the attorney-client privilege or work 25 product protection, the parties may incorporate their agreement in the stipulated 26 protective order submitted to the court. 27 1 12. MISCELLANEOUS 2 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 3 person to seek its modification by the Court in the future. 4 12.2 Right to Assert Other Objections. By stipulating to the entry of this 5 Protective Order no Party waives any right it otherwise would have to object to 6 disclosing or producing any information or item on any ground not addressed in this 7 Stipulated Protective Order. Similarly, no Party waives any right to object on any 8 ground to use in evidence of any of the material covered by this Protective Order. 9 12.3 Filing Protected Material. A Party that seeks to file under seal any 10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may 11 only be filed under seal pursuant to a court order authorizing the sealing of the 12 specific Protected Material at issue. If a Party's request to file Protected Material 13 under seal is denied by the court, then the Receiving Party may file the information 14 in the public record unless otherwise instructed by the court. 15 12.4 Protective Order Not Admission/No Waive of Challenge to 16 Confidential Designation. By agreeing to the entry of this Protective Order, the 17 Parties adopt no position as to the authenticity or admissibility of the documents 18 produced subject to it or waive their right to challenge the Protected Material 19 designation at any point during the course of this litigation. Furthermore, by 20 producing or receiving information or material designated as “CONFIDENTIAL” or 21 by otherwise complying with the terms of this Protective Order, such conduct shall 22 not be construed as an admission as to the relevance, authenticity, foundation or 23 admissibility of any document, material, transcript or other information. 24 25 13. FINAL DISPOSITION 26 After the final disposition of this Action, as defined in paragraph 4, within 60 27 days of a written request by the Designating Party, each Receiving Party must return 1 this subdivision, “all Protected Material” includes all copies, abstracts, compilations, 2 summaries, and any other format reproducing or capturing any of the Protected 3 Material. Whether the Protected Material is returned or destroyed, the Receiving 4 Party must submit a written certification to the Producing Party (and, if not the same 5 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies 6 (by category, where appropriate) all the Protected Material that was returned or 7 destroyed and (2) affirms that the Receiving Party has not retained any copies, 8 abstracts, compilations, summaries or any other format reproducing or capturing any 9 of the Protected Material. Notwithstanding this provision, Counsel are entitled to 10 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing 11 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert 12 reports, attorney work product, and consultant and expert work product, even if such 13 materials contain Protected Material. Any such archival copies that contain or 14 constitute Protected Material remain subject to this Protective Order as set forth in 15 Section 4 (DURATION). 16 17 14. Any willful violation of this Order may be punished by civil or criminal 18 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 19 authorities, or other appropriate action at the discretion of the Court. 20 21 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 22 23 DATED: May 20, 2024 /s/ Ronald A. Marron Ronald A. Marron 24 Attorneys for Plaintiff

25

26 DATED: May 20, 2024 /s/ Christina Guerola Sarchio 27 Christina Guerola Sarchio Attorneys for Defendant 1 ATTESTATION PURSUANT TO CIVIL L.R. 5-4.3.4 2 The filer attests that the other signatories listed, on whose behalf the filing is 3 || also submitted, are registered CM/ECF filers and concur in the filing’s content and 4 || have authorized the filing. > || Dated: May 20, 2024 /s/ Ronald A. Marron 6 Ronald A. Marron 7 8 9 10 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 11 12 _ 13 || DATED: 5/20/2024 A | | A | | HON. MICHAEL WILNER 14 United States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28

1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 4 I, _____________________________ [full name], of _________________ 5 [full address], declare under penalty of perjury that I have read in its entirety and 6 understand the Stipulated Protective Order that was issued by the United States 7 District Court for the Central District of California on [date] in the case of Seale v. 8 GSK Consumer Health, Inc., dba Haleon, Case No. 2:23-cv-00842-AB-MRW. I 9 agree to comply with and to be bound by all the terms of this Stipulated Protective 10 Order and I understand and acknowledge that failure to so comply could expose me 11 to sanctions and punishment in the nature of contempt. I solemnly promise that I 12 will not disclose in any manner any information or item that is subject to this 13 Stipulated Protective Order to any person or entity except in strict compliance with 14 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 __________________________ [full 19 name] of _______________________________________ [full address and 20 telephone number] as my California agent for service of process in connection with 21 this action or any proceedings related to enforcement of this Stipulated Protective 22 Order. 23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 26 Printed name: _______________________________ 27