Starquest Ventures, Inc. v. Dexcom, Inc.
Starquest Ventures, Inc. v. Dexcom, Inc.
Trial Court Opinion
1 JjsOhHaeNff eJr. @SHfoAxEroFtFhsEcRh i(ldS.BcoNm 1 38331) 2 Meeghan H. Tirtasaputra (SBN 325572) [email protected] 3 FOX ROTHSCHILD LLP 10250 Constellation Boulevard, Suite 900 4 Los Angeles, California 90067 Telephone: 310-598-4150 NOTE: CHANGES MADE BY THE COURT 5 Facsimile: 310-556-9828 6 Attorneys for Plaintiff STARQUEST VENTURES, INC 7
8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 WESTERN DIVISION 12 13 STARQUEST VENTURES INC. dba Case No.: 2:25-cv-05470-AH-JPR Stelo, a California Corporation, Hon. Anne Hwang 14 Plaintiff, STIPULATED PROTECTIVE 15 ORDER 16 v.
17 DEXCOM, INC., a Delaware Corporation; and DOES 1-10, inclusive, 18 Action Filed: June 16, 2025 19 Defendants. Trial Date: None Set
20
21 22 23 24 25 26 27 28 1 1. INTRODUCTION 2 1.1 PURPOSES AND LIMITATIONS 3 Discovery in this action may involve production of confidential, proprietary, or 4 private information for which special protection from public disclosure and from use 5 for any purpose other than prosecuting this litigation may be warranted. Accordingly, 6 the Parties hereby stipulate to and petition the Court to enter the following Stipulated 7 Protective Order. The Parties acknowledge that this Order does not confer blanket 8 protections on all disclosures or responses to discovery and that the protection it 9 affords from public disclosure and use extends only to the limited information or items 10 that are entitled to confidential treatment under the applicable legal principles. The 11 Parties further acknowledge, as set forth in Section 12.3 below, that this Order does 12 not entitle them to file Confidential Information under seal; Civil Local Rule 79-5 sets 13 forth the procedures that must be followed and the standards that will be applied when 14 a Party seeks permission from the Court to file material under seal. 15 1.2 GOOD CAUSE STATEMENT 16 This Action arises out of a trademark dispute, the discovery for which will 17 require the disclosure of the Parties’ various business practices, customer lists, and 18 efforts in coming to using the name “Stelo.” Public disclosure of this information 19 could cause irreparable harm to the Parties (and their customers) in that competitors 20 will have access to the Parties’ future business plans as well as their customer lists, 21 which could harm the Parties in the marketplace. In addition, the Parties anticipate 22 that discovery exchanged and evidence used in the course of this action will include 23 various customer’s identifying information (including name, address, phone number) 24 as well as statements regarding personal health. 25 The Parties wish to respect any relevant privacy considerations related to 26 individual customers. 27 2. DEFINITION 28 2.1 Action: StarQuest Ventures, Inc. v. Dexcom, Inc., USDC Central 1 District Case No. 2:25-cv-05470-AH-JPR. 2 2.2 Challenging Party: a Party or Nonparty that challenges the designation 3 of information or items under this Order. 4 2.3 “CONFIDENTIAL” Information or Items: information (regardless of 5 how it is generated, stored or maintained) or tangible things that qualify for protection 6 under Federal Rule of Civil Procedure 26(c) and as specified above in the Good Cause 7 Statement. 8 2.4 HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 9 Information or Items: extremely sensitive “Confidential Information or Items,” 10 disclosure of which to another Party or Non-Party would create a substantial risk of 11 serious harm that could not be avoided by less restrictive means. This shall include, 12 without limitation, documents containing customer lists, business plans, passwords, 13 user IDs, access codes, and other log-in information as well as customer health 14 information. 15 2.5 Counsel: Outside Counsel of Record and In-House Counsel (as well as 16 their support staff). 17 2.6 Designating Party: a Party or Non-Party that designates information or 18 items that it produces in disclosures or in responses to discovery as 19 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 20 ONLY.” 21 2.7 Disclosure or Discovery Material: all items or information, regardless 22 of the medium or manner in which it is generated, stored, or maintained (including, 23 among other things, testimony, transcripts, and tangible things), that are produced or 24 generated in disclosures or responses to discovery in this matter. 25 2.8 Expert: a person with specialized knowledge or experience in a matter 26 pertinent to the litigation who has been retained by a Party or its counsel to serve as 27 an expert witness or as a consultant in this action. 28 2.9 In-House Counsel: attorneys who are employees of a Party to this 1 Action. In-House Counsel does not include Outside Counsel of Record or any other 2 outside counsel. 3 2.10 Nonparty: any natural person, partnership, corporation, association, or 4 other legal entity not named as a Party to this action. 5 2.11 Outside Counsel of Record: attorneys who are not employees of a Party 6 to this Action but are retained to represent or advise a Party and have appeared in this 7 Action on behalf of that Party or are affiliated with a law firm which has appeared on 8 behalf of that Party, including support staff. 9 2.12 Party: any Party to this Action, including all of its officers, directors, 10 employees, consultants, retained experts, and Outside Counsel of Record (and their 11 support staffs). 12 2.13 Producing Party: a Party or Nonparty that produces Disclosure or 13 Discovery Material in this Action. 14 2.14 Professional Vendors: persons or entities that provide litigation support 15 services (for example, photocopying, videotaping, translating, preparing exhibits or 16 demonstrations, and organizing, storing, or retrieving data in any form or medium) 17 and their employees and subcontractors. 18 2.15 Protected Material: any Disclosure or Discovery Material that is 19 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 20 ATTORNEYS’ EYES ONLY.” 21 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material 22 from a Producing Party. 23 3. SCOPE 24 The protections conferred by this Stipulation and Order cover not only 25 Protected Material (as defined above) but also any information copied or extracted 26 from Protected Material; all copies, excerpts, summaries, or compilations of Protected 27 Material; and any testimony, conversations, or presentations by Parties or their 28 Counsel that might reveal Protected Material. 1 Any use of Protected Material at trial will be governed by the orders of the trial 2 judge. This Order does not govern the use of Protected Material at trial. 3 4. DURATION 4 Once a case proceeds to trial, all the information that was designated as 5 “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 6 ONLY,” or maintained under this Order becomes public and will be presumptively 7 available to all members of the public, including the press, unless the trial judge finds 8 compelling reasons to proceed otherwise. See Kamakana v. City & Cnty. of Honolulu, 9
447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for 10 sealing documents produced in discovery from “compelling reasons” needed for 11 merits-related documents). Accordingly, the terms of this Order do not extend beyond 12 the beginning of trial. 13 Even after final disposition of this litigation, the confidentiality obligations 14 imposed by this Order will remain in effect until a Designating Party agrees otherwise 15 in writing or a court order otherwise directs. Final disposition is the later of (1) 16 dismissal of all claims and defenses in this Action, with or without prejudice; and (2) 17 final judgment after the completion and exhaustion of all appeals, rehearings, 18 remands, trials, or reviews of this Action, including the time limits for filing any 19 motions or applications for extension of time pursuant to applicable law. 20 5. DESIGNATING PROTECTED MATERIAL 21 5.1 Each Party or Nonparty that designates information or items for 22 protection under this Order must take care to limit any such designation to specific 23 material that qualifies under the appropriate standards. To the extent practicable, the 24 Designating Party must designate for protection only those parts of material, 25 documents, items, or oral or written communications that qualify so that other 26 portions of the material, documents, items, or communications for which protection 27 is not warranted are not swept unjustifiably within the ambit of this Order 28 Indiscriminate or routinized designations are prohibited. Designations that are 1 shown to be clearly unjustified or that have been made for an improper purpose (for 2 example, to unnecessarily encumber the case-development process or to impose 3 unnecessary expenses and burdens on other parties) may expose the Designating 4 Party to sanctions. 5 If it comes to a Designating Party’s attention that information or items it 6 designated for protection do not qualify for that level of protection, that Designating 7 Party must promptly notify all other Parties that it is withdrawing the inapplicable 8 designation. 9 5.2 Except as otherwise provided in this Order, Disclosure or Discovery 10 Material that qualifies for protection under this Order must be clearly so designated 11 before the material is disclosed or produced. 12 Designation in conformity with this Order requires the following: 13 (a) for information in documentary form (for example, paper or electronic 14 documents but excluding transcripts of depositions or other pretrial or trial 15 proceedings), that the Producing Party must affix at a minimum the legend 16 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 17 ONLY” to each page that contains Protected Material. If only a portion or portions 18 of the material on a page qualify for protection, the Producing Party should to the 19 extent practicable clearly identify the protected portion(s) (for example, by making 20 appropriate markings in the margins). 21 A Party or Nonparty that makes original documents available for inspection 22 need not designate them for protection until after the inspecting Party has indicated 23 which documents it would like copied and produced. During the inspection and 24 before the designation, all material made available for inspection must be treated as 25 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 26 ONLY.” After the inspecting Party has identified the documents it wants copied and 27 produced, the Producing Party must determine which documents, or portions thereof, 28 qualify for protection under this Order. Then, before producing the specified 1 documents, the Producing Party must affix the “CONFIDENTIAL” or “HIGHLY 2 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” legend to each page that 3 contains Protected Material. If only a portion or portions of the material on a page 4 qualify for protection, the Producing Party should to the extent practical clearly 5 identify the protected portion(s) (for example, by making appropriate markings in the 6 margins). 7 (b) for testimony given in deposition, the Designating Party must identify the 8 Disclosure or Discovery Material that is protected on the record, before the close of 9 the deposition. When it is impractical to identify separately each portion of testimony 10 that is entitled to protection and it appears that substantial portions of the testimony 11 may qualify for protection, the Designating Party may invoke on the record (before 12 the deposition, hearing, or other proceeding is concluded) a right to have up to 7 days 13 to identify the specific portions of the testimony as to which protection is sought. 14 Only those portions of the testimony that are appropriately designated for protection 15 within the 7 days shall be covered by the provisions of this Stipulated Protective 16 Order. Alternatively, a Designating Party may specify, at the deposition or up to 7 17 days afterwards if that period is properly invoked, that the entire transcript shall be 18 treated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 19 EYES ONLY.” The use of a document as an exhibit at a deposition shall not in any 20 way affect its designation as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – 21 ATTORNEYS’ EYES ONLY.” Any transcript that is prepared before the expiration 22 of the 7-day period for designation shall be treated during that period as if it had been 23 designated or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” in its 24 entirety unless otherwise agreed. After the expiration of that period, the transcript 25 shall be treated only as actually designated. 26 (c) for information produced in some form other than documentary and for any 27 other tangible items, that the Producing Party must affix in a prominent place on the 28 exterior of the container or containers in which the information is stored the legend 1 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 2 ONLY.” If only a portion or portions of the information warrant protection, the 3 Producing Party, to the extent practicable, must identify the protected portion(s). 4 5.3 If timely corrected, an inadvertent failure to designate qualified 5 information or items does not, standing alone, waive the Designating Party’s right to 6 secure protection under this Order for that material. On timely correction of a 7 designation, the Receiving Party must make reasonable efforts to assure that the 8 material is treated in accordance with the provisions of this Order. 9 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 10 6.1 Any Party or Nonparty may challenge a designation of confidentiality 11 at any time consistent with the Court’s scheduling order. Unless a prompt challenge 12 to a Designating Party’s confidentiality designation is necessary to avoid foreseeable, 13 substantial unfairness, unnecessary economic burdens, or a significant disruption or 14 delay of the litigation, a Party does not waive its right to challenge a confidentiality 15 designation by electing not to mount a challenge promptly after the original 16 designation is disclosed. 17 6.2 The Challenging Party must initiate the dispute-resolution process (and, 18 if necessary, file a discovery motion) under Local Rule 37. The Challenging Party must 19 provide written notice of each designation it is challenging and describe the basis for 20 each challenge. To avoid ambiguity as to whether a challenge has been made, the 21 written notice must recite that the challenge to confidentiality is being made in 22 accordance with this specific paragraph of the Protective Order as well as Local Rule 23 37. The Parties shall attempt to resolve each challenge in good faith and must begin 24 the process by conferring directly within 7 days of the date of service of notice. In 25 conferring, the Challenging Party must explain the basis for its belief that the 26 confidentiality designation was not proper and must give the Designating Party an 27 opportunity to review the designated material, to reconsider the circumstances, and, 28 if no change in designation is offered, to explain the basis for the chosen designation. 1 A Challenging Party may proceed to the next stage of the challenge process only if it 2 has engaged in this meet and confer process first or establishes that the Designating 3 Party is unwilling to participate in the meet and confer process in a timely manner. 4 6.3 The burden of persuasion in any such proceeding is on the Designating 5 Party. Frivolous challenges, and those made for an improper purpose (for example, 6 to harass or impose unnecessary expenses and burdens on other parties), may expose 7 the Challenging Party to sanctions. Unless the Designating Party has waived the 8 confidentiality designation, all parties must continue to afford the material in 9 question the level of protection to which it is entitled under the Producing Party’s 10 designation until the Court rules on the challenge. 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 12 7.1 A Receiving Party may use Protected Material that is disclosed or 13 produced by another Party or by a Nonparty in connection with this Action only for 14 prosecuting, defending, or attempting to settle this Action. Such Protected Material 15 may be disclosed only to the categories of people and under the conditions described 16 in this Order. When the Action has been terminated, a Receiving Party must comply 17 with the provisions of section 13 below (FINAL DISPOSITION). 18 Protected Material must be stored and maintained by a Receiving Party at a 19 location and in a manner sufficiently secure that access is limited to the people 20 authorized under this Order. 21 7.2 Unless otherwise ordered by the Court or permitted in writing by the 22 Designating Party, a Receiving Party may disclose any information or item 23 designated “CONFIDENTIAL” only to the following people: 24 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well as 25 employees of said Outside Counsel of Record to whom it is reasonably necessary to 26 disclose the information for this litigation and who have signed the 27 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A; 28 (b) the officers, directors, and employees (including In-House Counsel) of the 1 Receiving Party to whom disclosure is reasonably necessary for this Action; 2 (c) Experts (as defined in this Order) of the Receiving Party to whom 3 disclosure is reasonably necessary for this Action and who have signed the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 5 (d) the court and its personnel; 6 (e) court reporters and their staff, 7 (f) professional jury or trial consultants, mock jurors, and Professional 8 Vendors to whom disclosure is reasonably necessary for this Action and who have 9 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (g) the author or recipient of a document containing the information or a 11 custodian or other person who otherwise possessed or knew the information; 12 (h) during their depositions, witnesses and attorneys for witnesses to whom 13 disclosure is reasonably necessary, provided that the deposing party requests that the 14 witness sign the form attached as Exhibit A hereto and the witnesses will not be 15 permitted to keep any confidential information unless they sign the form, unless 16 otherwise agreed by the Designating Party or ordered by the Court. Pages of 17 transcribed deposition testimony or exhibits to depositions that reveal Protected 18 Material may be separately bound by the court reporter and may not be disclosed to 19 anyone except as permitted under this Order; and 20 (i) any mediator or settlement officer, and their supporting personnel, mutually 21 agreed on by any of the Parties engaged in settlement discussions or appointed by the 22 Court. 23 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 24 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in 25 writing by the Designating Party, a Receiving Party may disclose any information or 26 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only 27 to: 28 (a) the Receiving Party’s Outside Counsel of Record in this action, as well 1 as employees of said Outside Counsel of Record to whom it is reasonably necessary 2 to disclose the information for this litigation; 3 (b) Identified In-House Litigation Counsel only of the Receiving Party to 4 whom disclosure is reasonably necessary for this litigation. For Dexcom, such In- 5 House Litigation Counsel under this subsection (b) are Kaare Larson and Kellin 6 Nicoletti. Stelo has no In-House Litigation Counsel; 7 (c) Experts of the Receiving Party to whom disclosure is reasonably 8 necessary for this litigation and who have signed the “Acknowledgment and 9 Agreement to Be Bound” (Exhibit A); 10 (d) the Court and its personnel; 11 (e) Court reporters and their staff, professional jury or trial consultants, and 12 Professional Vendors to whom disclosure is reasonably necessary for this litigation 13 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit 14 A); 15 (f) the author or recipient of a document containing the information, or a 16 custodian or other person, who otherwise possessed or knew the information; and 17 (g) during their depositions, corporate representatives of the Disclosing 18 Party to the extent the “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 19 ONLY” information relates to the topic(s) on which the corporate representative has 20 been designated. 21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED 22 PRODUCED IN OTHER LITIGATION 23 If a Party is served with a subpoena or a court order issued in other litigation 24 that compels disclosure of any information or items designated in this Action as 25 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 26 ONLY,” that Party must 27 (a) promptly notify in writing the Designating Party. Such notification must 28 include a copy of the subpoena or court order unless prohibited by law; 1 (b) promptly notify in writing the party who caused the subpoena or order to 2 issue in the other litigation that some or all of the material covered by the subpoena or 3 order is subject to this Protective Order. Such notification must include a copy of this 4 Order; and 5 (c) cooperate with respect to all reasonable procedures sought to be pursued 6 by the Designating Party whose Protected Material may be affected. 7 If the Designating Party timely seeks a protective order, the Party served with 8 the subpoena or court order should not produce any information designated in this 9 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ 10 EYES ONLY,” before a determination on the protective-order request by the relevant 11 court unless the Party has obtained the Designating Party’s permission. The 12 Designating Party bears the burden and expense of seeking protection of its 13 Confidential Material, and nothing in these provisions should be construed as 14 authorizing or encouraging a Receiving Party in this Action to disobey a lawful 15 directive from another court. 16 9. A NONPARTY’S PROTECTED MATERTIAL SOUGHT TO BE 17 PRODUCED IN THIS LITIGATION 18 (a) The terms of this Order are applicable to information produced by a 19 Nonparty in this Action and designated as “CONFIDENTIAL” or “HIGHLY 20 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information is protected 21 by the remedies and relief provided by this Order. Nothing in these provisions should 22 be construed as prohibiting a Nonparty from seeking additional protections. 23 (b) In the event that a Party is required by a valid discovery request to 24 produce a Nonparty’s Confidential Information in its possession and the Party is 25 subject to an agreement with the Nonparty not to produce the Nonparty’s 26 Confidential Information, then the Party must 27 (1) promptly notify in writing the Requesting Party and the Nonparty 28 that some or all of the information requested is subject to a confidentiality agreement 1 with a Nonparty; 2 (2) promptly provide the Nonparty with a copy of this Order, the 3 relevant discovery request(s), and a reasonably specific description of the 4 information requested; and 5 (3) make the information requested available for inspection by the 6 Nonparty, if requested. 7 (c) If the Nonparty fails to seek a protective order within 21 days of 8 receiving the notice and accompanying information, the Receiving Party may 9 produce the Nonparty’s Confidential Information responsive to the discovery 10 request. If the Nonparty timely seeks a protective order, the Receiving Party must not 11 produce any information in its possession or control that is subject to the 12 confidentiality agreement with the Nonparty before a ruling on the protective-order 13 request. Absent a court order to the contrary, the Nonparty must bear the burden and 14 expense of seeking protection of its Protected Material. 15 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 16 If a Receiving Party learns that by inadvertence or otherwise, it has disclosed 17 Protected Material to any person or in any circumstance not authorized under this 18 Order, the Receiving Party must immediately notify the Designating Party in writing 19 of the unauthorized disclosures, use its best efforts to retrieve all unauthorized copies 20 of the Protected Material, inform the person or people to whom unauthorized 21 disclosures were made of the terms of this Order, and ask that person or people to 22 execute the “Acknowledgment and Agreement to Be Bound” that is attached hereto 23 as Exhibit A. 24 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 25 PROTECTED MATERIAL 26 When a Producing Party gives notice to Receiving Parties that certain 27 inadvertently produced material is subject to a claim of privilege or other protection, 28 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil 1 Procedure 26(b)(5)(B). 2 12. MISCELLANEOUS 3 12.1 Nothing in this Order abridges the right of any person to seek its 4 modification by the Court. 5 12.2 By stipulating to the entry of this Order, no Party waives any right it 6 otherwise would have to object to disclosing or producing any information or item 7 on any ground not addressed in this Order. Similarly, no Party waives any right to 8 object on any ground to use in evidence of any of the material covered by this Order. 9 12.3 A Party that seeks to file under seal any Protected Material must comply 10 with Civil Local Rule 79-5. Protected Material may be filed under seal only pursuant 11 to a court order authorizing the sealing of the specific Protected Material at issue. If 12 a Party's request to file Protected Material under seal is denied, then the Receiving 13 Party may file the information in the public record unless otherwise instructed by the 14 Court. 15 13. FINAL DISPOSITION 16 After the final disposition of this Action, as defined in paragraph 4, within 60 17 days of a written request by the Designating Party, each Receiving Party must return 18 all Protected Material to the Producing Party or destroy such material. As used in this 19 subdivision, “all Protected Material” includes all copies, abstracts, compilations, 20 summaries, and any other format reproducing or capturing any of the Protected 21 Material. Whether the Protected Material is returned or destroyed, the Receiving 22 Party must submit a written certification to the Producing Party (and, if not the same 23 person or entity, to the Designating Party) by the 60-day deadline that identifies (by 24 category, when appropriate) all the Protected Material that was returned or destroyed 25 and affirms that the Receiving Party has not retained any copies, abstracts, 26 compilations, summaries, or any other format reproducing or capturing any of the 27 Protected Material. Notwithstanding this provision, Counsel are entitled to retain an 28 archival copy of all pleadings; motion papers; trial, deposition, and hearing 1 || transcripts; legal memoranda; correspondence; deposition and trial exhibits; expert 2 || reports; attorney work product; and consultant and expert work product even if such 3 || materials contain Protected Material. Any such archival copies that contain or 4 || constitute Protected Material remain subject to this Order as set forth in Section 4 5 || (DURATION). 6 || 14. SANCTIONS 7 Any willful violation of this Order may be punished by civil or criminal 8 || contempt, financial or evidentiary sanctions, reference to disciplinary authorities, or 9 || other appropriate action at the discretion of the Court. 10 11 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD. 12 13 || Rated: August 19, 2025 Fox ROTHSCHILD LLP 14 15 /s/ John J. Shaeffer John J. Shaeffer 16 Meeghan H. Tirtasaputra Attorneys for Plaintiff StarQuest Ventures, Inc. Dated: August 19, 2025 DLA PIPER LLP 18 19 /s/Gina Durham 20 Gina Durham Kristina Fernandez Mabrie 21 Attorneys for Defendant Dexcom, Inc. 22 33 PURSUANT TO STIPULATION, IT IS SO ORDERED
| DATED: 8/21/2025 fe hrohattr Honorable Jean P. Rosenblut 25 United States Magistrate Judge 26 27 28 15
1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, ___________________________________________________[full name], 4 of _____________________________________________________ [full address], 5 declare under penalty of perjury that I have read in its entirety and understand the 6 Stipulated Protective Order that was issued by the United States District Court for 7 the Central District of California on __________________________________, 2025 8 in the case of StarQuest Ventures, Inc. v. Dexcom, Inc., USDC Central District Case 9 No. 2:25-cv-05470-AH-JPR. I agree to comply with and to be bound by all the terms 10 of this Stipulated Protective Order and I understand and acknowledge that failure to 11 so comply could expose me to sanctions and punishment in the nature of contempt. 12 I solemnly promise that I will not disclose in any manner any information or 13 item that is subject to this Stipulated Protective Order to any person or entity except 14 in strict compliance with the provisions of this Order. I further agree to submit to the 15 jurisdiction of the United States District Court for the Central District of California 16 for enforcing the terms of this Stipulated Protective Order, even if such enforcement 17 proceedings occur after termination of this action. 18 I hereby appoint ______________________________ [print or type full 19 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 28 Signature: __________________________________
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