Contract analysis

Section 1: Definitions As used in this Stipulated Protective Order, the following terms shall have the meanings set forth below: 1.1 "Action" shall mean the civil action captioned Genome Dx Therapeutics Inc. v. Helios Precision Diagnostics, Inc., Case No. 3:25-cv-01847-JWL, pending in the United States District Court for the Northern District of California, including all proceedings, motions, hearings, trials, post-t

Section 2: Scope of the Protective Order 2.1 This Order governs all documents, electronically stored information ("ESI"), deposition testimony, interrogatory responses, responses to requests for admission, responses to requests for production, hearing and trial testimony, exhibits, declarations, expert reports, and any other discovery materials or litigation materials produced, disclosed, exchanged, or filed in this

Section 3: Designation Procedures 3.1 Designation of Documents and ESI. The Designating Party shall designate documents and ESI as Protected Material by marking each page of a document or each item of ESI with the appropriate legend: either "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL — ATTORNEYS' EYES ONLY." Such markings shall be placed in a conspicuous location on each page, such as a header, footer, or Bates-number sta

Section 4: Access to Protected Material — Two-Tier Framework 4.1 "Confidential" Material — Authorized Recipients. Information and materials designated as "Confidential" under this Order may be disclosed only to the following categories of Qualified Persons: (a) Outside Counsel of Record and their professional staff, including attorneys, paralegals, legal assistants, summer associates, law clerks, and other personnel

Section 5: Acknowledgment and Agreement to Be Bound (Exhibit A) 5.1 Before receiving any Protected Material, whether designated as "Confidential" or "Highly Confidential — Attorneys' Eyes Only," each non-counsel recipient identified in Section 4 who is required to sign the Acknowledgment (including In-House Counsel, in-house business employees, Experts, Consultants, e-discovery vendor personnel, and Non-Party deponen

Section 6: Use of Protected Material at Depositions 6.1 Protected Material may be shown to a deponent during a deposition in this Action for purposes of examination, but the deponent must first be informed on the record of the confidentiality designation applicable to the material being displayed. The examining attorney shall state on the record whether the exhibit or document being shown to the witness is designated

Section 7: Filing Protected Material with the Court 7.1 Protected Material shall not be filed on the public docket of this Action. Any filing that includes, incorporates, attaches, quotes from, or refers to the substance of Protected Material shall be filed under seal in accordance with Civil Local Rule 79-5 of the Northern District of California and this Court's standing orders regarding sealed filings. The parties

Section 8: Challenging Designations 8.1 A Receiving Party that believes a designation of material as "Confidential" or "Highly Confidential — Attorneys' Eyes Only" is improper, overbroad, or not supported by good cause may challenge that designation at any time during the pendency of this Action. Nothing in this Order shall be construed to limit or waive a party's right to challenge any designation. 8.2 Meet-and-Conf

Section 9: Inadvertent Production of Privileged Material — Clawback 9.1 The production or disclosure of a document, ESI, or other material in this Action shall not constitute a waiver of any applicable attorney-client privilege, work-product protection, or any other applicable privilege or protection, whether or not the production or disclosure was inadvertent. This provision is entered pursuant to, and shall be enfo

Section 10: Non-Party Productions 10.1 Non-Parties producing documents, ESI, or other information in connection with this Action may designate such material as "Confidential" or "Highly Confidential — Attorneys' Eyes Only" in accordance with the terms and procedures of this Order, as if they were a Designating Party under Section 3. A Non-Party may invoke the protections of this Order by marking its produced material

Section 11: No Use Outside this Action 11.1 Protected Material received by a Receiving Party shall be used solely for the purpose of prosecuting or defending this Action, including pre-trial discovery, motion practice, trial preparation, trial, post-trial proceedings, and appeals. Protected Material shall not be used for any business, commercial, competitive, regulatory, or other purpose unrelated to this Action. 11.

Section 12: Duration and Disposition of Protected Material 12.1 This Order shall remain in full force and effect throughout the pendency of this Action and for a period of two (2) years after the final resolution of this Action, including the exhaustion or expiration of all rights of appeal. The obligations of confidentiality imposed by this Order shall not expire during this period, and all Qualified Persons who hav

Section 13: Modification 13.1 This Order may be modified at any time by written stipulation of the parties, approved by the Court, or by order of the Court upon motion by any party or affected Non-Party. Any stipulated modification shall be filed with the Court and shall not be effective until approved by the Court. 13.2 Any party or Non-Party may seek modification of this Order upon a showing of good cause. Good cau

Section 14: Enforcement 14.1 Any violation of this Order may be addressed by the Court through its contempt power, the imposition of sanctions, the entry of injunctive relief, or any other remedy available under applicable law or the Court's inherent authority. The Court may also consider any violation of this Order in connection with other motions or proceedings in this Action, including motions for sanctions under

Section 15: Miscellaneous 15.1 This Order does not create any presumption as to the discoverability, relevance, or admissibility of any material. The designation of material as Protected Material under this Order does not constitute an admission or concession by any party that the material is relevant, discoverable, or admissible for any purpose. All rights to object to the discoverability, relevance, or admissibilit

1. I have read the Stipulated Protective Order entered by the Court on December 18, 2025, in the above-captioned Action (the "Protective Order") in its entirety, and I understand the terms, conditions, obligations, and restrictions set forth therein.

2. I agree to be bound by all provisions of the Protective Order as if I were a signatory thereto. I understand that the Protective Order restricts the use and disclosure of certain confidential, proprietary, and trade-secret information designated as "Confidential" or "Highly Confidential — Attorneys' Eyes Only" in connection with the above-captioned Action.

3. I agree that I will not disclose, disseminate, copy, or use any Protected Material (as defined in the Protective Order) for any purpose other than the prosecution or defense of the above-captioned Action. I will not discuss the substance or content of Protected Material with any person who is not a Qualified Person authorized to receive such material under the terms of the Protective Order.

4. I agree that I will maintain all Protected Material in a secure manner, will not leave copies of Protected Material unattended in areas accessible to unauthorized persons, and will take reasonable precautions to prevent unauthorized access to Protected Material in both physical and electronic form.

5. I agree that I will return or destroy all Protected Material in my possession, custody, or control upon the completion of my role in the above-captioned Action, upon the conclusion of the Action (as directed by Counsel of Record), or upon the request of the party from whom the Protected Material was received, in accordance with Section 12 of the Protective Order.

6. I submit to the personal jurisdiction of the United States District Court for the Northern District of California for the purpose of any proceeding to enforce the Protective Order. I waive any objection based on lack of personal jurisdiction, improper venue, or inconvenient forum with respect to any such enforcement proceeding.

7. I understand that any violation of the Protective Order may result in sanctions, contempt proceedings, or other penalties imposed by the Court, and that I may be held personally liable for any damages resulting from my violation of the Protective Order. Signature: ________ Printed Name: ________ Title/Position: ________ Employer/Affiliation: ________ Address: ________ Date: ________ GENOME DX THERAPEUTICS INC., a