Extract to table
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Extract to table / stipulation-protective-order.docx
stipulation-protective-order.docx
Parties
OF CALIFORNIA COUNTY OF SA
RECITALS Plaintiff Lumos Analytics Inc
Harkness LLP
Defendants NovaSpark Technologies Inc
Gerber LLP
Brindoval Digital Forensics LLC
Lumos Analytics Inc
NovaSpark Technologies Inc
Dates
March 15, 2023
January 19, 2023
January 23, 2023
February 17, 2023
March 8, 2023
March 20, 2023
May 15, 2023
April 14, 2023
May 1, 2023
Amounts
Obligations
Discovery will also involve Defendants' proprietary business information, NovaSpark product development records, NovaSpark source code and architecture documents, investor communications and capitalization records, and financial information of the parties and non-parties; WHEREAS, the parties agree that good cause exists for the entry of this Protective Order to prevent the disclosure of confidential, proprietary, and trade-secret information beyond the scope of this litigation, and to establish clear protocols for the designation, handling, storage, and use of such information in a manner consistent with the interests of justice and the parties' legitimate interests in protecting their respective proprietary information; WHEREAS, entry of this Protective Order is consistent with and complementary to the Stipulation and Order Appointing Neutral Forensic Examiner filed March 8, 2023, pursuant to which the parties stipulated to the appointment of Brindoval Digital Forensics LLC as the neutral forensic examiner in this Action, and this Protective Order shall govern all materials produced or generated in connection with that forensic examination as well as all other discovery in this Action; and WHEREAS, the parties have conferred and reached agreement on the terms set forth herein and believe that entry of this Protective Order will facilitate the efficient and orderly conduct of discovery while safeguarding the legitimate confidentiality interests of all parties and non-parties; NOW, THEREFORE, the parties hereby stipulate and respectfully request that the Court enter the following Protective Order: SECTION 1: DEFINITIONS As used in this Protective Order, the following terms shall have the meanings set forth below: 1
1 "Action" shall mean Lumos Analytics Inc
5 "Confidential Information" shall mean any discovery Material that has been designated as "CONFIDENTIAL" pursuant to Section 3 of this Order
6 "Attorneys' Eyes Only Information" shall mean any discovery Material that has been designated as "ATTORNEYS' EYES ONLY" pursuant to Section 3 of this Order
7 "Designating Party" shall mean the party that applies a confidentiality designation to discovery Material under one of the two confidentiality tiers established by this Order
In the case of materials produced by the Neutral Forensic Examiner, the Designating Party shall be the party whose information is contained in or reflected by such materials, or, where the materials reflect information of multiple parties, the parties shall confer and agree upon the appropriate designation in accordance with Section 9