Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / stipulated-protective-order.docx
stipulated-protective-order.docx
Parties
NORTHERN DISTRICT OF CALIFORNIA SA
Plaintiff Genome Dx Therapeutics Inc
Harkness LLP
Ridgecrest Durneval LLP
Genome Dx Therapeutics Inc
Canfield Document Solutions LLC
General Motors Corp
Dates
December 5, 2025
December 18, 2025
January 30, 2026
Amounts
Obligations
10,438,271 (entitled "Genomic Classifier for Cancer Prognosis Using Multi-Gene Expression Signatures"), 11,204,893 (entitled "Methods and Systems for Predicting Cancer Recurrence Using Machine-Learning Models"), and 11,891,647 (entitled "Integrated Genomic Classifier Platform with Automated Feature Selection"), and Defendant's accused ProstaSignal™ Genomic Classifier product, including allegations of patent infringement, willful infringement, and induced infringement, as well as Defendant's affirmative defenses and counterclaims of non-infringement, invalidity, and unenforceability; WHEREAS, the parties recognize and acknowledge that discovery in this Action will necessarily involve the disclosure of confidential, proprietary, and trade-secret information of both parties, including but not limited to proprietary genomic classifier algorithms, training data, feature selection methodologies, model architectures and hyperparameters, clinical validation data, regulatory submissions, business plans, financial records, revenue and cost data, licensing agreements and related correspondence, investor materials, board of directors presentations, strategic planning documents, and other commercially sensitive information the unauthorized disclosure of which would cause substantial competitive and commercial harm; WHEREAS, counsel for the parties conducted a meet-and-confer on December 5, 2025, during which they negotiated the terms and provisions of this Protective Order in good faith, consistent with the requirements of Federal Rule of Civil Procedure 26(c), Civil Local Rule 7-1, and this Court's standing orders regarding discovery dispute resolution; WHEREAS, good cause exists under Federal Rule of Civil Procedure 26(c) for the entry of this Order to protect against the disclosure and dissemination of confidential, proprietary, and trade-secret information outside the confines of this litigation, as the information at issue includes trade secrets, proprietary algorithms, and highly sensitive competitive information the public disclosure of which would cause substantial and irreparable harm to the Designating Party; and WHEREAS, the Court, having reviewed the parties' stipulation and the good cause established therefor, finds that entry of this Order is warranted and appropriate to facilitate the efficient and orderly exchange of discovery in this Action while protecting the legitimate confidentiality interests of the parties and non-parties; NOW, THEREFORE, upon the stipulation of the parties, and for good cause shown, IT IS HEREBY ORDERED as follows: 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
The AEO designation is reserved for the most sensitive categories of information and shall not be used where the Confidential designation would provide adequate protection
5 "Designating Party" shall mean the party or non-party that designates information or material as Protected Material under this Order
6 "Receiving Party" shall mean the party or non-party that receives Protected Material designated under this Order
This list is illustrative and not exhaustive, and this Order shall apply to any Non-Party who produces materials in connection with this Action