1 KENDRA S. CANAPE (SBN: 259641) [email protected] 2 JOEL D. BRODFUEHRER (SBN: 343092) 3 [email protected] GORDON REES SCULLY MANSUKHANI, LLP 4 5 Park Plaza, Suite 1100 Irvine, CA 92614 5 Telephone: (949) 255-6950 6 Facsimile: (949) 474-2060

7 Attorneys for Defendant 8 I.Q. DATA INTERNATIONAL, INC.

9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 CECILE LUNETTA-SPARR, an ) NO.: 3:24-cv-02259-JO-BLM individual ) 13 ) Assigned For All Purposes To 14 Plaintiff, ) Honorable Jinsook Ohta ) 15 v. ) Magistrate: Hon. Barbara L. Major

) 16 I.Q. DATA INTERNATIONAL, INC.; IQ DATA INFORMATION ) STIPULATED PROTECTIVE 17 SOLUTIONS,) INC.; EQUIFAX ) ORDER INFORMATION SERVICES, LLC; ) 18 ) TRANS UNION LLC; and DOES 1 ) 19 through 10, inclusive, )

20 Defendants. ) ) 21 ) ) Complaint Filed: 12/4/24 22 ) 23 24 1. INTRODUCTION 25 1.1 PURPOSES AND LIMITATIONS 26 The Court recognizes that at least some of the documents and information 27 being sought through discovery in the above-captioned action are, for competitive 1 reasons, normally kept confidential by the parties. The parties have agreed to be 2 bound by the terms of this Protective Order in this action. 3 Discovery in this action is also 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. 12 1.2 GOOD CAUSE STATEMENT 13 This action is likely to involve materials and information that I.Q. Data 14 International, Inc. (“IQ Data”), Experian Information Solutions, Inc. (“Experian”), 15 Trans Union LLC (“Trans Union”), Equifax Information Services, LLC (“Equifax”) 16 (collectively, the “Defendants”) and Plaintiff Cecille Lunetta-Sparr (“Plaintiff”) 17 maintain as confidential for which special protection from public disclosure and 18 from use for any purpose other than prosecution of this action is warranted. The 19 Defendants may be producing documents to Plaintiff that consist of, among other 20 things, confidential business or financial information, trade secrets, information 21 regarding confidential business practices, or other confidential research, 22 development, or commercial information, information otherwise generally 23 unavailable to the public, or which may be privileged or otherwise protected from 24 disclosure under state or federal statutes, court rules, case decisions, or common law. 25 The Defendants have maintained this information as confidential due to the sensitive 26 nature of the information. The Defendants’ competitors would gain an improper 27 advantage if documents were made public, including but not limited to customer 1 financial information, business plans, business policies, training materials, and other 2 business-related information that are not generally available to the public. The debt 3 collection industry and consumer reporting agencies are highly competitive and 4 require confidentiality of very sensitive consumer information. 5 Plaintiff will also be producing materials relating to or regarding Plaintiff’s 6 debt(s), credit history, credit reports, documents containing Plaintiff’s social security 7 number and DOB. Plaintiff has alleged she has suffered harm that could result in 8 production of sensitive medical information, banking records, personal identity 9 information, income tax returns (including attached schedules and forms), W-2 10 forms and 1099 forms, and personnel or employment records. Plaintiff and/or I.Q. 11 Data will be producing documents from the underlying collection action and as such 12 are authorized to produce the settlement agreement and release from that matter 13 provided that it be marked Confidential as set forth below. 14 Accordingly, to expedite the flow of information, to facilitate the prompt 15 resolution of disputes over confidentiality of discovery materials, to adequately 16 protect information the parties are entitled to keep confidential, to ensure that the 17 parties are permitted reasonable necessary uses of such material in preparation for 18 and in the conduct of trial, to address their handling at the end of the litigation, and 19 serve the ends of justice, a protective order for such information is justified in this 20 matter. It is the intent of the parties that information will not be designated as 21 confidential for tactical reasons and that nothing be so designated without a good 22 faith belief that it has been maintained in a confidential, non-public manner, and 23 there is good cause why it should not be part of the public record of this case. 24 1.3 ACKNOWLEDGMENT OF PROCEDURE FOR FILING UNDER 25 SEAL. 26 The parties further acknowledge, as set forth in Section 12.3, below, that this 27 Stipulated Protective Order does not entitle them to file confidential information 1 the procedures that must be followed and the standards that will be applied when a 2 party seeks permission from the court to file material under seal. 3 There is a strong presumption that the public has a right of access to judicial 4 proceedings and records in civil cases. In connection with non-dispositive motions, 5 good cause must be shown to support a filing under seal. See Kamakana v. City 6 and Cnty. of Honolulu,

, 1176 (9th Cir. 2006), Phillips ex rel. Ests. 7 of Byrd v. Gen. Motors Corp.,

, 1210–11 (9th Cir. 2002), Makar- 8 Welbon v. Sony Elecs., Inc.,

(E.D. Wis. 1999) (even stipulated 9 protective orders require good cause showing), and a specific showing of good 10 cause or compelling reasons with proper evidentiary support and legal justification, 11 must be made with respect to Protected Material that a party seeks to file under seal. 12 The Parties’ mere designation of Disclosure or Discovery Material as 13 CONFIDENTIAL does not—without the submission of competent evidence by 14 declaration, establishing that the material sought to be filed under seal qualifies as 15 confidential, privileged, or otherwise protectable—constitute good cause. 16 Further, if a party requests sealing related to any motions, briefs, pleadings, 17 deposition transcripts, other papers to be filed with the Court incorporate 18 documents or information subject to this Order, or trial, then the party filing such 19 papers shall designate such materials, or portions thereof, as “Confidential,” and 20 then compelling reasons, not only good cause, for the sealing must be shown, and 21 the relief sought shall be narrowly tailored to serve the specific interest to be 22 protected. See Pintos v. Pac. Creditors Ass’n,

, 677–79 (9th Cir. 23 2010). For each item or type of information, document, or thing sought to be filed 24 or introduced under seal in connection with a dispositive motion or trial, the party 25 seeking protection must articulate compelling reasons, supported by specific facts 26 and legal justification, for the requested sealing order. Again, competent evidence 27 supporting the application to file documents under seal must be provided by 1 Any document that is not confidential, privileged, or otherwise protectable 2 in its entirety will not be filed under seal if the confidential portions can be redacted. 3 If documents can be redacted, then a redacted version for public viewing, omitting 4 only the confidential, privileged, or otherwise protectable portions of the document, 5 shall be filed. Any application that seeks to file documents under seal in their 6 entirety should include an explanation of why redaction is not feasible. 7 2. DEFINITIONS 8 2.1 Action: Cecille Lunetta-Sparr. v. I.Q. Data International, Inc. et al. 9 (Case No: 3:24-cv-02259-JO-BLM). 10 2.2 Challenging Party: a Party or Non-Party that challenges the designation 11 of information or items under this Order. 12 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 13 how it is generated, stored or maintained) or tangible things that qualify for 14 protection under Federal Rule of Civil Procedure 26(c), and as specified above 15 in the Good Cause Statement. 16 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as 17 their support staff). 18 2.5 Designating Party: a Party or Non-Party that designates information or 19 items that it produces in disclosures or in responses to discovery as 20 “CONFIDENTIAL.” 21 2.6 Disclosure or Discovery Material: all items or information, regardless 22 of the medium or manner in which it is generated, stored, or maintained 23 (including, among other things, testimony, transcripts, and tangible things), 24 that are produced or generated in disclosures or responses to discovery in this 25 matter. 26 2.7 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 1 2.8 Final Disposition: the later of (1) dismissal of all claims and defenses 2 in this Action, with or without prejudice; and (2) final judgment herein after 3 the completion and exhaustion of all appeals, rehearings, remands, trials, or 4 reviews of this Action, including the time limits for filing any motions or 5 applications for extension of time pursuant to applicable law. 6 2.9 In-House Counsel: attorneys who are employees of a party to this 7 Action. In-House Counsel does not include Outside Counsel of Record or any 8 other outside counsel. 9 2.10 Non-Party: any natural person, partnership, corporation, association, 10 or other legal entity not named as a Party to this action. 11 2.11 Outside Counsel of Record: attorneys who are not employees of a party 12 to this Action but are retained to represent or advise a party to this Action and 13 have appeared in this Action on behalf of that party or are affiliated with a law 14 firm which has appeared on behalf of that party, and includes support staff. 15 2.12 Party: any party to this Action, including all of its officers, directors, 16 employees, consultants, retained experts, and Outside Counsel of Record (and 17 their support staffs). 18 2.13 Producing Party: a Party or Non-Party that produces Disclosure or 19 Discovery Material in this Action. 20 2.14 Professional Vendors: persons or entities that provide litigation support 21 services (e.g., photocopying, videotaping, translating, preparing exhibits or 22 demonstrations, and organizing, storing, or retrieving data in any form or 23 medium) and their employees and subcontractors. 24 2.15 Protected Material: any Disclosure or Discovery Material and all 25 information derived therefrom including, but not limited to, all testimony 26 given in a deposition, declaration or otherwise, that refers, reflects or 27 otherwise discusses any information designated “Confidential” that is 1 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 2 from a Producing Party. 3 3. SCOPE 4 The protections conferred by this Stipulation and Order cover not only 5 Protected Material (as defined above), but also (1) any information copied or 6 extracted from Protected Material; (2) all copies, excerpts, summaries, or 7 compilations of Protected Material; and (3) any testimony, conversations, or 8 presentations by Parties or their Counsel that might reveal Protected Material. 9 Any use of Protected Material at trial will be governed by the orders of the 10 trial judge. This Order does not govern the use of Protected Material at trial. 11 4. TRIAL AND DURATION 12 Even after final disposition of this litigation, the confidentiality obligations 13 imposed by this Order will remain in effect until a Designating Party agrees 14 otherwise in writing or a court order otherwise directs. Final disposition will be 15 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with 16 or without prejudice; and (2) final judgment herein after the completion and 17 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 18 including the time limits for filing any motions or applications for extension of time 19 pursuant to applicable law. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Exercise of Restraint and Care in Designating Material for Protection. 22 Each Party or Non-Party that designates information or items for protection 23 under this Order must take care to limit any such designation to specific 24 material that qualifies under the appropriate standards. The Designating Party 25 must designate for protection only those parts of material, documents, items, 26 or oral or written communications that qualify so that other portions of the 27 material, documents, items, or communications for which protection is not 1 Mass, indiscriminate, or routinized designations are prohibited. Designations 2 that are shown to be clearly unjustified or that have been made for an improper 3 purpose (e.g., to unnecessarily encumber the case development process or to impose 4 unnecessary expenses and burdens on other parties) may expose the Designating 5 Party to sanctions. 6 If it comes to a Designating Party’s attention that information or items that it 7 designated for protection do not qualify for protection, that Designating Party must 8 promptly notify all other Parties that it is withdrawing the inapplicable designation. 9 5.2 Manner and Timing of Designations. Except as otherwise provided in 10 this Order (see, e.g., second paragraph of section 5.2(a) below), or as 11 otherwise stipulated or ordered, Disclosure or Discovery Material that 12 qualifies for protection under this Order must be clearly so designated before 13 the material is disclosed or produced. 14 Designation in conformity with this Order requires: 15 (a) for information in documentary form (e.g., paper or electronic documents, 16 but excluding transcripts of depositions or other pretrial or trial proceedings), 17 that the Producing Party affix at a minimum, the legend “CONFIDENTIAL” 18 to each page that contains protected material. If only a portion or portions of 19 the material on a page qualifies for protection, the Producing Party also must 20 clearly identify the protected portion(s) (e.g., by making appropriate markings 21 in the margins). 22 A Party or Non-Party that makes original documents available for inspection 23 need not designate them for protection until after the inspecting Party has indicated 24 which documents it would like copied and produced. During the inspection and 25 before the designation, all of the material made available for inspection will be 26 deemed “CONFIDENTIAL.” After the inspecting Party has identified the 27 documents it wants copied and produced, the Producing Party must determine which 1 producing the specified documents, the Producing Party must affix the 2 “CONFIDENTIAL” legend to each page that contains Protected Material. If only a 3 portion or portions of the material on a page qualifies for protection, the Producing 4 Party also must clearly identify the protected portion(s) (e.g., by making appropriate 5 markings in the margins). 6 (b) for testimony given in depositions that the Designating Party identify the 7 Disclosure or Discovery Material on the record, before the close of the 8 deposition all protected testimony. Such designation will be made on the 9 record if possible, but the Parties can designate portions of such testimony as 10 Confidential Information by providing written notice of such designation to 11 the opposing Parties within thirty (30) days of receipt of the transcribed 12 testimony by counsel. Until thirty (30) days after receipt of the transcribed 13 testimony, such testimony shall be treated by the Parties as Confidential 14 Information. 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 17 on the exterior of the container or containers in which the information is stored 18 the legend “CONFIDENTIAL.” If only a portion or portions of the 19 information warrants protection, the Producing Party, to the extent 20 practicable, will identify the protected 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, 23 waive the Designating Party’s right to secure protection under this Order for 24 such material. Upon timely correction of a designation, the Receiving Party 25 must make reasonable efforts to assure that the material is treated in 26 accordance with the provisions of this Order. 27 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. In the event a Party disagrees with the designation of 6 Confidential Information, the Parties shall first try to resolve the disagreement 7 in good faith on an informal basis, such as the production of redacted copies. 8 In the event such a dispute cannot be resolved by agreement, a Party may 9 move the Court for modification of the designation of such Confidential 10 Information. The Confidential Information designation shall be maintained 11 pending disposition of such a motion. The Challenging Party will initiate the 12 dispute resolution process (and, if necessary, file a discovery motion) in 13 accordance with the Court’s Civil Procedures. 14 6.3 The burden of persuasion in any such challenge proceeding will be on 15 the Designating Party. Frivolous challenges, and those made for an improper 16 purpose (e.g., to harass or impose unnecessary expenses and burdens on other 17 parties) may expose the Challenging Party to sanctions. Unless the 18 Designating Party has waived or withdrawn the confidentiality designation, 19 all parties will continue to afford the material in question the level of 20 protection to which it is entitled under the Producing Party’s designation until 21 the Court rules on the challenge. 22 7. ACCESS TO AND USE OF PROTECTED MATERIAL 23 7.1 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 25 this Action only for prosecuting, defending, or attempting to settle this Action. 26 Protected Material shall not be used, directly or indirectly, by any person, for 27 any business, commercial or competitive purposes or for any purpose 1 accordance with the provisions of this Order. Such Protected Material may be 2 disclosed only to the categories of persons and under the conditions described 3 in this Order. When the Action has been terminated, a Receiving Party must 4 comply with the provisions of section 13 below (FINAL DISPOSITION). 5 Protected Material must be stored and maintained by a Receiving Party at a 6 location and in a secure manner that ensures that access is limited to the 7 persons authorized under this Order. 8 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 9 otherwise ordered by the court or permitted in writing by the Designating 10 Party, a Receiving Party may disclose any information or item designated 11 “CONFIDENTIAL” only to: 12 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 13 well as employees of said Outside Counsel of Record to whom it is 14 reasonably necessary to disclose the information for this Action; 15 (b) the officers, directors, and employees (including House Counsel) of 16 the Receiving Party to whom disclosure is reasonably necessary for this 17 Action; 18 (c) Experts (as defined in this Order) of the Receiving Party to whom 19 disclosure is reasonably necessary for this Action and who have signed the 20 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 21 (d) the Court and its personnel; 22 (e) court reporters and their staff to whom disclosure is reasonably 23 necessary for this Action and who have signed the “Acknowledgment and 24 Agreement to Be Bound” (Exhibit A); 25 (f) professional jury or trial consultants, mock jurors, and Professional 26 Vendors to whom disclosure is reasonably necessary for this Action and 27 who have signed the “Acknowledgment and Agreement to Be Bound” 1 (g) the author or recipient of a document containing the information or a 2 custodian or other person who otherwise possessed or knew the 3 information; 4 (h) during their depositions, witnesses, and attorneys for witnesses, in the 5 Action to whom disclosure is reasonably necessary provided: (1) the 6 deposing party requests that the witness sign the form attached as Exhibit 7 A hereto; and (2) they will not be permitted to keep any confidential 8 information unless they sign the “Acknowledgment and Agreement to Be 9 Bound” (Exhibit A), unless otherwise agreed by the Designating Party or 10 ordered by the court. Pages of transcribed deposition testimony or exhibits 11 to depositions that reveal Protected Material may be separately bound by 12 the court reporter and may not be disclosed to anyone except as permitted 13 under this Stipulated Protective Order; and 14 (i) any mediator or settlement officer, and their supporting personnel, 15 mutually agreed upon by any of the parties engaged in settlement 16 discussions. 17 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED 18 IN OTHER LITIGATION 19 If a Party is served with a subpoena or a court order issued in other litigation 20 that compels disclosure of any information or items designated in this Action as 21 “CONFIDENTIAL,” that Party must: 22 (a) promptly notify in writing the Designating Party. Such notification will 23 include a copy of the subpoena or court order; 24 (b) promptly notify in writing the party who caused the subpoena or order 25 to issue in the other litigation that some or all of the material covered by 26 the subpoena or order is subject to this Protective Order. Such notification 27 will include a copy of this Stipulated Protective Order; and 1 (c) cooperate with respect to all reasonable procedures sought to be 2 pursued by the Designating Party whose Protected Material may be 3 affected. 4 If the Designating Party timely seeks a protective order, the Party served with 5 the subpoena or court order will not produce any information designated in this 6 action as “CONFIDENTIAL” before a determination by the court from which the 7 subpoena or order issued, unless the Party has obtained the Designating Party’s 8 permission. The Designating Party will bear the burden and expense of seeking 9 protection in that court of its confidential material and nothing in these provisions 10 should be construed as authorizing or encouraging a Receiving Party in this Action 11 to disobey a lawful directive from another court. 12 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 13 PRODUCED IN THIS LITIGATION 14 9.1 Application. The terms of this Order are applicable to 15 information produced by a Non-Party in this Action and designated as 16 “CONFIDENTIAL.” Such information produced by Non-Parties in 17 connection with this litigation is protected by the remedies and relief provided 18 by this Order. Nothing in these provisions should be construed as prohibiting 19 a Non-Party from seeking additional protections. 20 9.2 Notification. In the event that a Party is required, by a valid 21 discovery request, to produce a Non-Party’s confidential information in its 22 possession, and the Party is subject to an agreement with the Non-Party not to 23 produce the Non-Party’s confidential information, then the Party will: 24 (a) promptly notify in writing the Requesting Party and the Non-Party that 25 some or all of the information requested is subject to a confidentiality 26 agreement with a Non-Party; 27 1 (b) promptly provide the Non-Party with a copy of the Stipulated 2 Protective Order in this Action, the relevant discovery request(s), and a 3 reasonably specific description of the information requested; and 4 (c) make the information requested available for inspection by the Non- 5 Party, if requested. 6 9.3 Conditions of Production. If the Non-Party fails to seek a 7 protective order from this court within 14 days of receiving the notice and 8 accompanying information, the Receiving Party may produce the Non- 9 Party’s confidential information responsive to the discovery request. If the 10 Non-Party timely seeks a protective order, the Receiving Party will not 11 produce any information in its possession or control that is subject to the 12 confidentiality agreement with the Non-Party before a determination by the 13 court. Absent a court order to the contrary, the Non-Party will bear the 14 burden and expense of seeking protection in this court of its Protected 15 Material. 16 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 17 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 18 Protected Material to any person or in any circumstance not authorized under this 19 Stipulated Protective Order, the Receiving Party must immediately (a) notify in 20 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts 21 to retrieve all unauthorized copies of the Protected Material, (c) inform the person 22 or persons to whom unauthorized disclosures were made of all the terms of this 23 Order, and (d) request such person or persons to execute the “Acknowledgment and 24 Agreement to Be Bound” that is attached hereto as Exhibit A. 25 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 26 PROTECTED MATERIAL 27 When a Producing Party gives notice to Receiving Parties that certain 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 3 may be established in an e-discovery order that provides for production without prior 4 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 5 the parties reach an agreement on the effect of disclosure of a communication or 6 information covered by the attorney-client privilege or work product protection, the 7 parties may incorporate their agreement in the stipulated protective order submitted 8 to the court. 9 12. MISCELLANEOUS 10 12.1 Right to Further Relief. Nothing in this Order abridges the right of any 11 person to seek its modification by the Court in the future. 12 12.2 Right to Assert Other Objections. By stipulating to the entry of this 13 Protective Order no Party waives any right it otherwise would have to object 14 to disclosing or producing any information or item on any ground not 15 addressed in this Stipulated Protective Order. Similarly, no Party waives any 16 right to object on any ground to use in evidence of any of the material covered 17 by this Protective Order. 18 12.3 Filing Under Seal. Before any materials produced in discovery, answers 19 to interrogatories, responses to requests for admissions, deposition transcripts, 20 or other documents which are designated as Confidential Information are filed 21 with the Court for any purpose, the party seeking to file such material must 22 seek permission of the Court to file the material under seal. No document may 23 be filed under seal, i.e., closed to inspection by the public except pursuant to 24 a Court order that authorizes the sealing of the particular document, or 25 portions of it. A sealing order may issue only upon a showing that the 26 information is privileged or protectable under the law. The request must be 27 narrowly tailored to seek sealing only of the confidential or privileged 1 procedures explained in Section 2.j of the Electronic Case Filing 2 Administrative Policies and Procedures Manual for the United States District 3 Court for the Southern District of California and Civil Local Rule 79.2. In 4 addition, in accordance with Judge Major's preferences, a party must file a 5 ‘public’ version of any document that it seeks to file under seal. In the public 6 version, the party may redact only that information that is deemed 7 “Confidential.” The party should file the redacted document(s) 8 simultaneously with a joint motion or ex parte application requesting that the 9 confidential portions of the document(s) be filed under seal and setting forth 10 good cause for the request.” 11 12.4 Neither the entry of this Order, nor the designation of any information, 12 document, or the like as “Confidential,” nor the failure to make such 13 designation, shall constitute evidence with respect to any issue in this action. 14 12.5 Modification of the Protective Order by the Court. The Court may 15 modify the terms and conditions of the Order for good cause, or in the interest 16 of justice, or on its own order at any time during these proceedings. 17 13. FINAL DISPOSITION 18 After the final disposition of this Action, as defined in paragraph 4, within 60 19 days, each Receiving Party must return all Protected Material to the Producing Party. 20 As used in this subdivision, “all Protected Material” includes all copies, abstracts, 21 compilations, summaries, and any other format reproducing or capturing any of the 22 Protected Material. The Receiving Party must submit a written certification to the 23 Producing Party (and, if not the same person or entity, to the Designating Party) by 24 the 60 day deadline that (1) identifies (by category, where appropriate) all the 25 Protected Material that was returned and (2) affirms that the Receiving Party has not 26 retained any copies, abstracts, compilations, summaries or any other format 27 reproducing or capturing any of the Protected Material. Notwithstanding this 1 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 2 deposition and trial exhibits, expert reports, attorney work product, and consultant 3 and expert work product, even if such materials contain Protected Material. Any 4 such archival copies that contain or constitute Protected Material remain subject to 5 this Protective Order as set forth in Section 4 (DURATION). 6 14. VIOLATION 7 Any willful violation of this Order may be punished by civil or criminal 8 contempt proceedings, financial or evidentiary sanctions, reference to disciplinary 9 authorities, or other appropriate action at the discretion of the Court. 10 11 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 13 DATED: March 5, 2025 /s/ Jeremy Golden (with permission) Jeremy Golden 14 Attorneys for Plaintiff

15 16 DATED: March 5, 2025 /s/Joel D. Brodfuehrer Joel D. Brodfuehrer 17 Kendra S. Canape Attorneys for Defendant 18 IQ DATA INTERNATIONAL, INC.

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20 DATED: March 5, 2025 /s/ Thomas Abbott (with permission) Attorneys for Defendant 21 EXPERIAN INFORMATION SOLUTIONS, INC. 22

23 DATED: March 5, 2025 /s/ Heliane Fabian (with permission) Attorneys for Defendant 24 TRANS UNION, LLC

25 26 DATED: March 5, 2025 /s/ Jennifer Brooks (with permission) Attorneys for Defendant 27 EQUIFAX INFORMATION SERVICES, LLC 1 || FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 3 . 4 Dated: 3/5/2025 , He 5 Hon. Barbara L. Major United States Maaistrate Judae 7 9 10 11

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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 Southern District of California on [date] in the case of 8 ___________ [insert case name and number]. I agree to comply with and to be 9 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 punishment 11 in the nature of contempt. I solemnly promise that I will not disclose in any manner 12 any information or item that is subject to this Stipulated Protective Order to any 13 person or entity except in strict compliance with the provisions of this Order. 14 I further agree to submit to the jurisdiction of the United States District Court 15 for the Southern District of California for the purpose of enforcing the terms of this 16 Stipulated Protective Order, even if such enforcement proceedings occur after 17 termination of this action. I hereby appoint __________________________ [full 18 name] of _______________________________________ [full address and 19 telephone number] as my California agent for service of process in connection with 20 this action or any proceedings related to enforcement of this Stipulated Protective 21 Order. 22

23 Date: ______________________________________ 24 City and State where signed: _________________________________ 25 Printed name: _______________________________ 26 27 Signature: ___________________