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STIPULATED PROTECTIVE ORDER — 1

SEA 1878742v2 80188-4

The Honorable James P. Donohue 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

GEMBA RESEARCH, L.L.C., a Washington 

limited liability company, 

 Plaintiff, 

 v. 

ENNA INCORPORATED, a Canadian 

corporation, COLLIN R. McLOUGHLIN, an 

individual, and PHILIP S. GORITSAS, an 

individual, 

 Defendants. 

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No. 06-0359 JPD 

PROTECTIVE ORDER 

This case may require the disclosure of information, either documentary or testimonial 

or both, regarded as confidential. Accordingly, the parties, by and through their respective 

attorneys, have requested entry of an order under Rule 26 of the Federal Rules of Civil 

Procedure to protect confidential information during discovery and trial. 

1. Nondisclosure of Sensitive Information: All documents, information, or 

tangible items produced or furnished by a party during this litigation, which are designated 

as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” 

shall not be given, shown, made available, discussed, or otherwise communicated in any 

manner (“disclosed”), either directly or indirectly, to any person not authorized to receive 

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STIPULATED PROTECTIVE ORDER — 2

SEA 1878742v2 80188-4

the information under the terms of this Protective Order. The parties agree to designate 

information as “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” on a good faith 

basis and not for purposes of harassing the receiving party or for purposes of unnecessarily 

restricting the receiving party’s access to information concerning the lawsuit. 

2. Designation of Documents as Confidential: Documents or tangible items 

shall be designated confidential within the meaning of this Protective Order in the following 

ways: 

(a) In the case of documents and the information contained therein, by 

placing on the document the legend “CONFIDENTIAL” or “HIGHLY 

CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” 

(b) In the case of interrogatory answers and the information contained 

therein, by placing on the pages containing the confidential information the 

legend “CONFIDENTIAL” or “HIGHLY 

CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” 

(c) In the case of tangible items, by visibly marking the item or, if not 

practical, by marking the container or a tag attached to the item, 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 

ONLY.” 

(d) Documents and tangible items may also be labeled with the legend 

“Confidentiality Designation Made By Counsel, Case No. 06-0359 JPD.” 

(e) In producing original files and records for inspection, no marking 

need be made by the producing party in advance of the inspection. For the 

purposes of the inspection, all documents produced shall be considered as 

marked “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY.” After 

the inspecting party selects documents for copying, the producing party shall 

mark as “CONFIDENTIAL” or “HIGHLY 

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STIPULATED PROTECTIVE ORDER — 3

SEA 1878742v2 80188-4

CONFIDENTIAL-ATTORNEYS’ EYES ONLY” the copies of the 

documents that contain confidential information prior to producing the 

copies to the inspecting party. 

3. Use and Designation of Confidential Information During Depositions: 

If depositions require the disclosure of confidential information, counsel for the witness or 

party producing such information may identify, on the record, the portion of the deposition 

which counsel believes may contain confidential information. If such designation is made, 

that portion of the deposition will be taken with no one present except those persons who 

are authorized to have access to such confidential information in accordance with this 

Protective Order, and the reporter. Subject to the terms hereof, “CONFIDENTIAL” or 

“HIGHLY CONFIDENTIAL- ATTORNEYS’ EYES ONLY” information may be 

disclosed by a receiving party in a deposition, to the extent that its use is necessary, only at 

the deposition(s) of: 

(a) the present employees, directors, officers, or Rule 30(b)(6) 

designee(s) of the producing party; 

(b) an author, addressee, or other person indicated as a recipient of a 

document containing the information; 

(c) a person identified through discovery or investigation or by the 

deponent in his or her deposition as an author or recipient of the information 

(without prior disclosure of the specific confidential information). Prior to 

any disclosure under subparagraph (c), notice must be given to the producing 

party of the specific information so that it has a fair opportunity to object to 

the disclosure. Notice may be given at the time of the deposition. However, 

if an objection is made, the confidential information may not be disclosed to 

the deponent until the objection is resolved by the parties or the court 

decides disclosure is warranted. Any party may bring before the court the 

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STIPULATED PROTECTIVE ORDER — 4

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question of whether confidential information may be disclosed to the 

deponent; 

(d) an independent advisor, consultant or expert otherwise qualified 

under this Protective Order to receive such information; or 

(e) any person for whom prior authorization is obtained from the 

producing party or the Court. 

4. Period For Designation Of Deposition Transcripts As Confidential: 

Regardless of whether notice was given at the deposition, deposition transcripts shall be 

considered “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” for twenty-one 

(21) days after delivery of transcripts to the parties. Each party shall have until twenty-one 

(21) days after receipt of the deposition transcript which to inform the other parties to the 

action of the portions of the transcript (by specific page and line reference) to be 

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES 

ONLY.” The right to make such designation shall be waived unless made within the 

twenty-one (21) day period, subject to the inadvertent disclosure provisions of paragraph 

10. The twenty-one (21) day period may be reduced by agreement of the parties and any 

requests for reduction of such time period will not be unreasonably refused. 

5. Filing of Confidential Information With the Court: Any document, 

pleading, or tangible item which contains confidential information, if filed or submitted to 

the Court, shall be filed in a sealed envelope marked “Confidential - Not To Be Opened 

Except By Order Or Direction Of The Court (As per Protective Order entered __________, 

2006).” Upon filing through the ECF system, the party filing such a document or pleading 

shall refer to the docket entry associated with this Protective Order. 

6. Examples of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES 

ONLY” Information: As used in this Protective Order, “HIGHLY CONFIDENTIAL 

ATTORNEYS’ EYES ONLY” means Discovery Material that a party in good faith 

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STIPULATED PROTECTIVE ORDER — 5

SEA 1878742v2 80188-4

believes, following review by counsel, constitutes highly confidential material that 

comprises any highly sensitive information, including but not limited to, certain highly 

sensitive technical information relating to research for and production of current products, 

technical and research information regarding future products, certain highly sensitive 

business or financial information (including customer lists) and marketing plans and 

forecasts, and any similar information. The “HIGHLY CONFIDENTIAL-ATTORNEYS’ 

EYES ONLY” designation is to be used in good faith only to protect the confidential 

materials which meet the above defined criteria. 

7. Persons Entitled to Review “HIGHLY CONFIDENTIAL – 

ATTORNEYS’ EYES ONLY” Information: Disclosure of “HIGHLY 

CONFIDENTIAL-ATTORNEYS’ EYES ONLY” documents or information, including 

summaries thereof, but not including documents with the confidential portions redacted to 

the extent only a portion or portions of a document have been designated as “HIGHLY 

CONFIDENTIAL-ATTORNEY EYES ONLY,” shall be limited to: 

(a) the attorneys who have appeared in this matter and their partners, 

associates, paralegals, secretaries, and office assistants; 

(b) judges, magistrates, any special master appointed by the Court, law 

clerks, and clerical personnel of this Court or any other court where 

discovery or other matters pertaining to this action might lie, as well as any 

court to which an appeal in this action might lie; 

(c) independent consultants or experts, not employees, directors or 

officers of the parties, retained by any of the parties and/or their counsel to 

consult or testify in the case; 

(d) persons entitled to receive the information pursuant to Paragraph 3 

above; 

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STIPULATED PROTECTIVE ORDER — 6

SEA 1878742v2 80188-4

(e) outside vendors who perform photocopying, microfiching, computer 

classification or similar clerical functions, but only so long as necessary to 

perform those services; and 

(f) court reporters, persons operating video equipment in depositions, 

and other person engaged in preparing transcripts of testimony or hearings 

for this action. 

In the event that counsel believes there is a need to disclose documents or 

information marked “HIGHLY CONFIDENTIAL - ATTORNEYS’ EYES ONLY” with 

persons other than those permitted to receive such documents or information by this 

paragraph 7, upon request of such counsel, counsel for the party producing such documents 

or information shall confer with such counsel at the earliest opportunity for the purpose of 

resolving such request in good faith. In the event counsel cannot reach an agreement, any 

party may bring before the Court the questions of whether disclosure of the confidential 

information to such person is warranted. 

8. Persons Entitled To Review “CONFIDENTIAL” Information: 

Disclosure of information designated as “CONFIDENTIAL,” including summaries 

thereof, shall be limited to: 

(a) the persons and entities identified in Paragraphs 3 and 7; and 

(b) the individual defendants, and no more than three employees or 

officers of the nonproducing party who are assisting counsel in litigating this 

matter and who have a need to know the information. 

In the event that counsel believes there is a need to disclose documents or 

information marked “CONFIDENTIAL” with persons other than those permitted to 

receive such documents or information by this paragraph 7, upon request of such counsel, 

counsel for the party producing such documents or information shall confer with such 

counsel at the earliest opportunity for the purpose of resolving such request in good faith. 

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STIPULATED PROTECTIVE ORDER — 7

SEA 1878742v2 80188-4

In the event counsel cannot reach an agreement, any party may bring before the Court the 

questions of whether disclosure of the confidential information to such person is 

warranted. 

9. Procedure For Disclosure Of Confidential Information: Before the nonproducing party discloses any information subject to this Protective Order to any employee 

or officer of the non-producing party (other than the individual defendants, who may 

review information marked “CONFIDENTIAL” by plaintiff), or to any consultant or 

expert retained by the nonproducing party, counsel for the party disclosing the information 

shall obtain a written affidavit, in the form attached hereto as Appendix A, from each 

person to whom disclosure is to be made, acknowledging that any document, information 

or tangible item that has been designated as confidential is subject to this Protective Order, 

that the person has read this Protective Order, that such person agrees to comply with, and 

be bound by, this Protective Order, and that such person is aware that contempt sanctions 

may be entered for violation of this Protective Order. Except as provided for in 

paragraph 3(e), the affidavits shall be provided to opposing counsel ten (10) days in 

advance of the first disclosure of any confidential information to such person. For each 

consultant or expert retained by the non-producing party, a CV shall also be provided to 

opposing counsel ten (10) days in advance of the first disclosure of any confidential 

information to such consultant or expert. If no objection is made to such person receiving 

confidential information within such ten (10) day period, then confidential information 

may be disclosed to such person. If objection is made, confidential information may not be 

disclosed to such person until the objection is resolved by the parties or the Court. Any 

party may bring before the Court the question of whether the confidential information 

maybe disclosed to such person. The ten (10) day period for objections maybe reduced by 

agreement of the parties and any requests for reduction of such time period will not be 

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STIPULATED PROTECTIVE ORDER — 8

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unreasonably refused. All signed affidavits shall be maintained through the conclusion of 

this action. 

10. Inadvertent Disclosure Of Confidential Information: If, through 

inadvertence, a producing party provides confidential information without marking the 

information as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ 

EYES ONLY” information, or if a producing party, through inadvertence, fails to 

designate deposition testimony within the thirty (30) day period as provided in paragraph 

4, the producing party may subsequently inform the receiving party of the 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL-ATTORNEYS’ EYES ONLY” 

nature of the disclosed information or testimony, and the receiving party shall treat the 

disclosed information and/or testimony as “CONFIDENTIAL” or “HIGHLY 

CONFIDENTIAL-ATTORNEYS’ EYES ONLY” information upon receipt of written 

notice from the producing party. 

11. Inadvertent Disclosure Of Privileged or Work Product Information: If, 

through inadvertence, a producing party provides information protected by the 

attorney-client privilege or any other privilege, or information protected from discovery by 

the work product doctrine or other applicable doctrine, the producing party may 

subsequently inform the receiving party of the nature of the disclosed information, and, 

upon receipt of written notice from the producing party, the receiving party shall return the 

information and all copies thereof to the producing party and shall not use the information 

in any way. 

12. Limitation on Applicability of Order: This Protective Order shall have 

no effect upon, and its scope shall not extend to, any party’s use of its own information 

and/or information that was not received from a producing party pursuant to this Protective 

Order. The restrictions set forth in this Protective Order will not apply to information 

which is known to the public before the date of its transmission to the receiving party, or 

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STIPULATED PROTECTIVE ORDER — 9

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which becomes known to the public after the date of its transmission to the receiving party, 

provided that such information does not become publicly known by any act or omission of 

the receiving party, its employees, or agents that would be in violation of this Protective 

Order or other law. If such public information is designated as “CONFIDENTIAL” or 

“HIGHLY CONFIDENTIAL--ATTORNEYS’ EYES ONLY,” counsel for the receiving 

party must inform counsel for the producing party of the pertinent circumstances ten (10) 

days in advance of treating such information as nonconfidential. If no objection is made 

within such ten (10) day period, then such designated information may be treated as 

nonconfidential. If an objection is made, the designated information must be treated as 

subject to this Protective Order until the objection is resolved by the parties or the Court. 

Any party may bring before the Court the question of whether designated information may 

be treated as nonconfidential. The ten (10) day period for objections may be reduced by 

agreement of the parties and any request for reduction of such time period will not be 

unreasonably refused. 

13. Use of Confidential Information: Confidential information received in 

this litigation shall be used only in connection with this case. The use of such information 

at trial or hearing in this case shall be subject to such protection as the Court shall 

determine. 

14. Resolution of Disputes: Acceptance by a party of any information, 

document, or thing designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - 

ATTORNEYS’ EYES ONLY” shall not constitute a concession that the information, 

document or thing is confidential. Either party may contest a claim of confidentiality. If 

any dispute arises with respect to a claim of confidentiality or with respect to any other 

subject matter under this Protective Order, the parties shall try in good faith to resolve such 

dispute on an informal basis. If agreement cannot be reached between counsel, then the 

dispute may be presented to the Court by either party by motion or otherwise, and the 

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parties shall continue to treat the material as confidential and to use the material only in the 

manner authorized by this Protective Order until the Court rules that it may be treated 

otherwise. In the resolution of such matter, the party challenging the confidentiality 

designation must present a prima facie showing that challenged information was 

improperly designated. The burden then shifts to the party making the designation to 

demonstrate that the challenged material was properly designated. 

15. Nonwaiver: This Protective Order shall be without prejudice to the right of 

any party to oppose production of any information on grounds other than confidentiality. 

For example, nothing in this Protective Order shall be construed as requiring disclosure of 

information, documents, or things that are beyond the scope of appropriate discovery in 

this case. Additionally, nothing in this Protective Order shall affect any matter of 

attorney-client privilege, work product doctrine, or other privileges or immunities; such 

matters shall be governed by the applicable law of privilege or immunity. Additionally, 

any party’s designation of any information, document, or thing as “CONFIDENTIAL” or 

“HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY,” or any party’s objections 

or lack of objections thereto, shall not in any way affect or be admissible as to any 

evidentiary matters; such matters shall be governed by the applicable law of evidence. 

Also, any party’s designation of any information, document, or thing as 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY,” 

or any party’s objections or lack of objections thereto, shall not in any way affect or be 

admissible as to any substantive claims and/or defenses that are or may be at issue in this 

case or any other action, such as claims and/or defenses pertaining to trade secrets, and/or 

proprietary rights; such claims and/or defenses shall be governed by the applicable 

statute(s) and/or substantive law. 

16. Subsequent Modifications of Order: This Protective Order shall not 

prevent any party from applying to the Court for relief therefrom, or from applying to the 

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STIPULATED PROTECTIVE ORDER — 11

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Court for further or additional protective orders, or from agreeing among themselves to 

modify or vacate this Protective Order, subject to the approval of the Court. 

17. Disposition of Documents at Conclusion of Action: At the conclusion of 

this action, including any appeals, all “CONFIDENTIAL” and “HIGHLY 

CONFIDENTIAL — ATTORNEYS’ EYES ONLY” information furnished pursuant to 

this Protective Order, and all copies thereof, shall be returned to the producing attorneys of 

record, or, at the producing party’s option, destroyed by counsel for the receiving party. 

The provisions of this Protective Order insofar as it restricts the disclosure, communication 

of, and use of, “CONFIDENTIAL” and “HIGHLY CONFIDENTIAL — ATTORNEYS’ 

EYES ONLY” information produced hereunder shall continue to be binding after the 

conclusion of this action. 

18. Nonparty Reliance on Order: If discovery is sought of a person not a 

party to this action (“nonparty”) requiring disclosure of such nonparty’s confidential 

information, the confidential information disclosed by such nonparty may be designated by 

the nonparty as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ 

EYES ONLY” information, as provided under this Protective Order, and will be subject to 

the same protection and procedures as those governing disclosure of the parties’ 

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL — ATTORNEYS’ EYES ONLY” 

information. 

19. Nonparty Requests for Information Subject to This Order: If any party 

is subpoenaed in another action, served with a demand in another action to which it is a 

party, or is served by any legal process by one not a party to this action, seeking 

information that was designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - 

ATTORNEYS’ EYES ONLY” by someone other than that party, the party shall give 

written notice by hand or facsimile transmission within ten days of receipt of such 

subpoena, demand, or legal process to the party who designated the information, and shall 

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STIPULATED PROTECTIVE ORDER — 12

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object to its production to the extent permitted by law, setting forth the existence and terms 

of this Protective Order. Nothing herein shall be construed as requiring the party or 

anyone else covered by this Protective Order to challenge an appeal any order requiring 

production of information subject to the Protective Order, or subject itself to any penalties 

for noncompliance with any legal process or order, or to seek any relief from this Court. 

 The foregoing is hereby stipulated by and between counsel. 

 STIPULATED TO this 8th day of September, 2006. 

Davis Wright Tremaine LLP 

Date: September 8th, 2006 

By: _s/ Brian G. Bodine 

 Brian G. Bodine, WSBA #22414 

 David H. Deits, WSBA #2350 

 Nigel Avilez, WSBA #36699 

 2600 Century Square 

 1501 Fourth Avenue 

 Seattle, WA 98101-1688 

 Telephone: (206) 628-7623 

 Fax: (206) 903-3723 

 E-mail: brianbodine@dwt.com 

Attorneys for Plaintiff Gemba Research LLC 

Perkins Coie LLP 

Date: September 8th, 2006 By: s/ Michael J. Berchou 

 Amanda J. Beane, WSBA #33070 

 Ramsey Al-Salam, WSBA #18822 

 Perkins Coie LLP 

 1201 Third Avenue, Suite 4800 

 Seattle, WA 98101-3099 

 Telephone: (206) 359-8000 

 Facsimile: (206) 359-9000 

 E-Mail: ABeane@perkinscoie.com 

Attorneys for Defendants Enna Incorporated, 

Collin R. McLoughlin and Philip S. Goritsas 

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STIPULATED PROTECTIVE ORDER — 13

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 - and - 

 Michael J. Berchou, Esq. 

 Phillips Lytle LLP 

 3400 HSBC Center 

 Buffalo, New York 14203-2887 

 Telephone: (716) 847-8400 

 Facsimile: (716) 852-6100 

 E-Mail: mberchou@phillipslytle.com 

 

Attorney for Defendants Enna Incorporated, 

Collin R. McLoughlin and Philip S. Goritsas 

IT IS SO ORDERED this 11th day of September, 2006. 

/s/ JAMES P. DONOHUE

United States Magistrate Judge 

Presented by: 

DAVIS WRIGHT TREMAINE LLP

By_ s/ Brian G. Bodine 

Brian G. Bodine, WSBA #22414 

Attorneys for Plaintiff 

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STIPULATED PROTECTIVE ORDER — 14

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APPENDIX A

The Honorable James P. Donohue 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

GEMBA RESEARCH, L.L.C., a Washington 

limited liability company, 

 Plaintiff, 

 v. 

ENNA INCORPORATED, a Canadian 

corporation, COLLIN R. McLOUGHLIN, an 

individual, and PHILIP S. GORITSAS, an 

individual, 

 Defendants. 

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No. 06-0359 JPD 

[PROPOSED] PROTECTIVE 

ORDER 

STATE OF ) 

 ) ss 

COUNTY OF ) 

 I, __________________________________________________, being duly 

sworn, state that: 

 1. My address is 

. 

 2. My employer is 

. 

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STIPULATED PROTECTIVE ORDER — 15

SEA 1878742v2 80188-4

 3. My present occupation or job description is 

. 

 4. I have reviewed a copy of the Protective Order in this case signed on 

behalf of the U.S. District Court, Western District of Washington on _________________. 

 5. I have carefully read and understand the provisions of the Protective 

Order. 

 6. I will comply with all of the provisions of the Protective Order. 

 7. I will hold in confidence and not disclose to anyone not qualified 

under the Protective Order, any Confidential Matter or any words, substances, summaries, 

abstracts or indices of Confidential Matter disclosed to me. 

 8. I will return all Confidential Matter and summaries, abstracts and 

indices thereof, and copies thereof, which come into my possession, and documents and 

things which I have prepared relating thereto, to counsel for the party by whom I am 

employed or retained. 

 9. I hereby submit to the jurisdiction of the U.S. District Court, 

Western District of Washington for the purpose of enforcement of the Protective Order in 

this case. 

 

 Signature 

 Subscribed and sworn to before me this _____ day of __________________ , 

20__. 

 

 Notary Public 

 My commission expires 

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STIPULATED PROTECTIVE ORDER — 16

SEA 1878742v2 80188-4

CERTIFICATE OF SERVICE 

I hereby certify that on September 11, 2006, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF system which will send notification of such 

filing to the following: 

Ramsey M Al-Salam 

Amanda J Beane 

Michael J Berchou 

 DATED this 11th day of September, 2006. 

By s/ Brian G. Bodine 

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