1 

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC D/B/A

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v. 

ZTE CORPORATION ET AL, 

Defendant.

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CIVIL ACTION 6:20-CV-00487-ADA

CIVIL ACTION 6:20-CV-00488-ADA

CIVIL ACTION 6:20-CV-00489-ADA

CIVIL ACTION 6:20-CV-00490-ADA

CIVIL ACTION 6:20-CV-00491-ADA

CIVIL ACTION 6:20-CV-00492-ADA

CIVIL ACTION 6:20-CV-00493-ADA

CIVIL ACTION 6:20-CV-00494-ADA

CIVIL ACTION 6:20-CV-00495-ADA

CIVIL ACTION 6:20-CV-00496-ADA

CIVIL ACTION 6:20-CV-00497-ADA

PATENT CASE

JURY TRIAL DEMANDED

PROTECTIVE ORDER

WHEREAS, Plaintiff and Defendants, hereafter referred to as “the Parties,” believe that certain

information that is or will be encompassed by discovery demands by the Parties involves the 

production or disclosure of trade secrets, confidential business information, or other proprietary 

information in this Action1; 

WHEREAS, the Partiesseek a protective order limiting disclosure thereof in accordance with Federal 

Rule of Civil Procedure 26(c): 

THEREFORE, it is hereby stipulated among the Parties and ORDERED that: 

1. Each Party may designate as confidential for protection under this Order, in whole or in part,

any document, information, or material that constitutes or includes, in whole or in part,

confidential or proprietary information or trade secrets of the Party or a Third Party to whom

the Party reasonably believes it owes an obligation of confidentiality with respect to such

1

 Action means the Case Nos. 6:20-cv-0487 through 6:20-cv-00497. 

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 1 of 16
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document, information, or material (“Protected Material”). Protected Material shall be 

designated by the Party producing it by affixing a legend or stamp on such document, 

information, or material as follows: “CONFIDENTIAL,” “CONFIDENTIAL -

ATTORNEYS’ EYES ONLY,” “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES 

ONLY,” or “CONFIDENTIAL - SOURCE CODE” (“DESIGNATED MATERIAL”).

2

The appropriate designation shall be placed clearly on each page of the Protected Material

(except deposition and hearing transcripts) for which such protection is sought. For

deposition and hearing transcripts, the appropriate designation shall be placed on the cover 

page of the transcript (if not already present on the cover page of the transcript when 

received from the court reporter) by each attorney receiving a copy of the transcript

after that attorney receives notice of the designation of some or all of that transcript is 

designated as containing Protected Material.

2. Any document produced before issuance of this Order, including pursuant to the Court’s 

Order Governing Proceedings - Patent Case, with the designation “Confidential” or the like 

shall receive the same treatment as if designated “CONFIDENTIAL” under this order and 

any such documents produced with the designation “Confidential - Outside Attorneys’ 

Eyes Only,” or the like shall receive the same treatment as if designated “CONFIDENTIAL 

- OUTSIDE ATTORNEYS’ EYES ONLY” under this Order, unless and until such 

document is re-designated to have a different classification under this Order.

3. With respect to documents, information, or DESIGNATED MATERIAL (i.e.

2 The term DESIGNATED MATERIAL is used throughout this Protective Order to refer to the 

class of materials designated as “CONFIDENTIAL,” “CONFIDENTIAL - ATTORNEYS’ EYES 

ONLY,” “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL 

- SOURCE CODE,” both individually and collectively.

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 2 of 16
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“CONFIDENTIAL,” “CONFIDENTIAL - ATTORNEYS’ EYES ONLY,” 

“CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL -

SOURCE CODE”) subject to the provisions herein and unless otherwise stated, this Order 

governs, without limitation: (a) all documents, electronically stored information, and/or 

things as defined by the Federal Rules of Civil Procedure; (b) all pretrial, hearing or

deposition testimony, or documents marked as exhibits or for identification in depositions

and hearings; (c) pretrial pleadings, exhibits to pleadings and other court filings; (d)

affidavits; and (e) stipulations. All copies, reproductions, extracts, digests, and complete

or partial summaries prepared from any DESIGNATED MATERIALS shall also be

considered DESIGNATED MATERIAL and treated as such under this Order.

4. A designation of Protected Material (DESIGNATED MATERIAL such as

“CONFIDENTIAL,” “CONFIDENTIAL -ATTORNEYS’ EYES ONLY,”

“CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL -

SOURCE CODE”) may be made at any time. Inadvertent or unintentional production of 

documents, information, or material that has not been designated as DESIGNATED

MATERIAL shall not be deemed a waiver in whole or in part of a claim for confidential

treatment. Any Party that inadvertently or unintentionally produces Protected Material

without designating it as DESIGNATED MATERIAL may request destruction of that

Protected Material by notifying the recipient(s) as soon as reasonably possible after the

producing Party becomes aware of the inadvertent or unintentional disclosure, and 

providing replacement Protected Material that is properly designated. The recipient(s)shall

then destroy all copies of the inadvertently or unintentionally produced Protected Materials

and any documents, information, ormaterial derived from or based thereon.

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5. “CONFIDENTIAL” documents, information, and material may be disclosed only to the 

following persons, except upon receipt of the prior written consent of the designating Party, 

upon order of the Court, or as set forth in paragraph 13 herein:

(a) Outside counsel of record in this Action for the Parties.

(b) Employees of such counsel assigned to and reasonably necessary to assist such 

counsel in the litigation of this Action.

(c) In-house counsel for the Parties who either have responsibility for making decisions 

dealing directly with the litigation of this Action, or who are assisting outside 

counsel in the litigation of this Action.

(d) Up to and including three (3) designated representatives of each of the Parties to the 

extent reasonably necessary for the litigation of this Action, except that any Party

may in good faith request the other Party’s consent to designate one or more 

additional representatives, the other Party shall not unreasonably withhold such 

consent, and the requesting Party may seek leave of Court to designate such 

additional representative(s) if the requesting Party believes the other Party has 

unreasonably withheld such consent.

(e) Outside consultants or experts retained for the purpose of this litigation, provided 

that: (1) such consultants or experts are not presently employed by the Parties or 

of an affiliate of a Party hereto for purposes other than this Action; (2) before access

is given, the consultant or expert has completed the Undertaking attached as

Appendix A hereto and the same is served upon the producing Party with a current

curriculum vitae of the consultant or expert at least ten (10) days before access to

the Protected Material is to be given to that consultant or expert to object to and

notify the receiving Party in writing that it objects to disclosure of Protected

Material to the consultant or expert. The Parties agree to promptly confer and use 

good faith to resolve any such objection. If the Parties are unable to resolve any 

objection, the objecting Party may file a motion with the Court within fifteen (15)

days of receipt of the notice, or within such other time as the Parties may agree,

seeking a protective order with respect to the proposed disclosure. The objecting

Party shall have the burden of proving the need for a protective order. No disclosure

shall occur until all such objections are resolved by agreement or Court order.

(f) Independent litigation support services, including persons working for or as court 

reporters, graphics or design services, jury or trial consulting services, and 

photocopy, document imaging, and database services retained by counsel and 

reasonably necessary to assist counsel with the litigation of this Action.

(g) The Court and its personnel.

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6. A Party shall designate documents, information, or material as “CONFIDENTIAL” only 

upon a good faith belief that the documents, information, or material contains confidential 

or proprietary information or trade secrets of the Party or a Third Party to whom the Party 

reasonably believes it owes an obligation of confidentiality with respect to such documents, 

information, or material.

7. Documents, information, or material produced pursuant to any discovery request in this 

Action, including but not limited to Protected Material designated as DESIGNATED 

MATERIAL, shall be used by the Parties only in the litigation of this Action and shall not 

be used for any other purpose. Any person or entity who obtains access to DESIGNATED 

MATERIAL or the contents thereof pursuant to this Order shall not make any copies, 

duplicates, extracts,summaries, or descriptions ofsuch DESIGNATED MATERIAL or any 

portion thereof except as may be reasonably necessary in the litigation of this Action. Any 

such copies, duplicates, extracts, summaries, or descriptions shall be classified 

DESIGNATED MATERIALS and subject to all of the terms and conditions of this Order.

8. To the extent a producing Party believes that certain Protected Material qualifying to be 

designated CONFIDENTIAL is so sensitive that its dissemination deserves even further 

limitation, the producing Party may designate such Protected Material “CONFIDENTIAL 

- ATTORNEYS’ EYES ONLY,” or to the extentsuch Protected Material includes computer 

source code and/or live data (that is, data as it exists residing in a database or databases) 

(“Source Code Material”), the producing Party may designate such Protected Material as 

“CONFIDENTIAL - SOURCE CODE.”

9. For Protected Material designated CONFIDENTIAL - ATTORNEYS’ EYES ONLY,

access to, and disclosure of, such Protected Material shall be limited to individuals listed 

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 5 of 16
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in paragraphs 5(a–c) and (e–g); provided, however, that access by in-house counsel pursuant

to paragraph 5(c) be limited to in-house counsel who exercise no competitive decisionmaking authority on behalf of the client.

10. For Protected Material designated CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES 

ONLY, access to, and disclosure of, such Protected Material shall be limited to individuals 

listed in paragraphs 5(a–b) and (e–g); provided, however, that the designating Party shall 

accommodate reasonable requests to provide summary information to in-house counsel 

designated pursuant to paragraph 5(c) who exercise no competitive decision-making 

authority on behalf of the client and reasonably require access to such information. 

11. For Protected Material designated “CONFIDENTIAL - SOURCE CODE” (e.g., “Source 

Code Material”), the following additional restrictions apply:

(a) Access to a Party’s Source Code Material shall be provided only on “stand-alone” 

computer(s) (that is, the computer may not be linked to any network, including a 

local area network (“LAN”), an intranet or the Internet). The stand-alone 

computer(s) may be connected to (i) a printer, or (ii) a device capable of 

temporarily storing electronic copies solely for the limited purposes permitted 

pursuant to paragraphs 11(h and k) below. Additionally, except as provided in

paragraph 11(k) below, the stand-alone computer(s) may only be located at the

offices of the producing Party’s outside counsel or its vendors.

(b) The receiving Party shall make reasonable efforts to restrict its requests for such 

access to the stand-alone computer(s) to normal business hours, which for purposes 

of this paragraph shall be 8:00 a.m. through 6:00 p.m. However, upon reasonable 

notice from the receiving Party, the producing Party shall make reasonable effortsto 

accommodate the receiving Party’srequestfor accessto the stand-alone computer(s) 

outside of normal business hours. The Parties agree to cooperate in good faith such 

that maintaining the producing Party’s Source Code Material at the offices of its 

outside counsel or its vendors shall not unreasonably hinder the receiving Party’s 

ability to efficiently and effectively conduct the prosecution or defense of this 

Action.

(c) The producing Party shall provide the receiving Party with information explaining 

how to start, log on to, and operate the stand-alone computer(s) in order to accessthe 

produced Source Code Material on the stand-alone computer(s).

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(d) The producing Party will produce Source Code Material in computer searchable 

format on the stand-alone computer(s) as described above.

(e) Access to Source Code Material shall be limited to outside counsel and up to three 

(3) outside consultants or experts3 (i.e., not existing employees or affiliates of a

Party or an affiliate of a Party or competitor identified by the Producing Party with 

reasonable specificity) retained for the purpose of this litigation and approved to

access such Protected Materials pursuant to paragraph 5(e) above. A receiving

Party may include excerpts of Source Code Material in an exhibit to a pleading, 

expert report, or deposition transcript (collectively, “Source Code Exhibits”),

provided that the Source Code Exhibits are appropriately marked under this Order, 

restricted to those who are entitled to have access to them as specified herein, and,

if filed with the Court, filed under seal in accordance with the Court’s rules, 

procedures, and orders.

(f) To the extent portions of Source Code Material are quoted in a Source Code 

Exhibit, either (1) the entire Source Code Exhibit will be stamped and treated as

CONFIDENTIAL -SOURCE CODE or (2) those pages containing quoted Source 

Code Material will be separately stamped and treated as CONFIDENTIAL -

SOURCE CODE.

(g) Except as set forth in paragraph 11(k) below, no electronic copies of Source Code 

Material shall be made without prior written consent of the producing Party, except 

as necessary to create documents that, pursuant to the Court’s rules, procedures,

and order, must be filed or served electronically.

(h) The receiving Party shall be permitted to make a reasonable number of printouts and 

photocopies of Source Code Material, which shall presumptively be a total of ten

(10), all of which shall be designated and clearly labeled “CONFIDENTIAL -

SOURCE CODE,” and the receiving Party shall maintain a log of all such files that 

are printed or photocopied.

(i) Should such printouts or photocopies be permissibly transferred back to electronic

media, such media shall be labeled “CONFIDENTIAL - SOURCE CODE” and 

shall continue to be treated as such.

(j) If the receiving Party’s outside counsel, consultants, or experts obtain printouts or 

photocopies of Source Code Material, the receiving Party shall ensure that such 

outside counsel, consultants, or experts keep the printouts or photocopies in a 

3 For the purposes of this paragraph, an outside consultant or expert is defined to include the outside 

consultant’s or expert’s direct reports and other support personnel, such that the disclosure to a 

consultant or expert who employs others within his or her firm to help in his or her analysis shall 

count as a disclosure to a single consultant or expert, provided that such personnel helping in the 

analysis of Source Code Material shall be disclosed pursuant to Paragraph 5(e). 

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 7 of 16
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secured locked area in the offices of such outside counsel, consultants, or expert. 

The receiving Partymay also temporarily keep the printouts or photocopies at:(i)the 

Court for any proceedings(s) relating to the Source Code Material, for the dates 

associated with the proceeding(s); (ii) the sites where any deposition(s) relating to 

the Source Code Material are taken, for the dates associated with the deposition(s); 

and (iii) any intermediate location reasonably necessary to transport the printouts or 

photocopies (e.g., a hotel prior to a Court proceeding or deposition).

(k) A producing Party’s SourceCode Material may only be transported by the receiving 

Party at the direction of a person authorized under paragraph 11(e) above to another 

person authorized under paragraph 11(e) above, on paper or removable electronic 

media (e.g., a DVD, CD-ROM, or flash memory “stick”) via hand carry, Federal 

Express, or other similarly reliable courier. Source Code Material may not be 

transported or transmitted electronically over a network of any kind, including a 

LAN, an intranet, or the Internet. Source Code Material may only be transported 

electronically for the purpose of Court proceeding(s) or deposition(s) as set forth

in paragraph 11(j) above and is at all times subject to the transport restrictions set

forth herein. But, for those purposes only, the SourceCode Materials may be loaded

onto a stand-alone computer.

12. Any attorney representing a Party, whether in-house or outside counsel, and any person 

associated with a Party and permitted to receive the other Party’s Protected Material that is 

designated CONFIDENTIAL - ATTORNEYS’ EYES ONLY, CONFIDENTIAL -

OUTSIDE ATTORNEYS’ EYES ONLY, and/or CONFIDENTIAL - SOURCE CODE 

(collectively “HIGHLY SENSITIVE MATERIAL”), who obtains, receives, has access to,

or otherwise learns, in whole or in part, the other Party’s HIGHLY SENSITIVE 

MATERIAL under this Order shall not prepare, prosecute, supervise, or assist in the

preparation or prosecution of any patent application pertaining to the field of the invention 

of the patents-in-suit during the pendency ofthisAction and for one year after its conclusion,

including any appeals. To ensure compliance with the purpose of this provision, each Party

shall create an “Ethical Wall” between those persons with access to HIGHLY SENSITIVE 

MATERIAL and any individuals who prepare, prosecute, supervise or assist in the

preparation or prosecution of any patent application pertaining to the field of invention of 

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 8 of 16
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the patent-in-suit. Nothing in this Order shall prevent a person with access to HIGHLY 

SENSITIVE MATERIAL from participating in a PTO proceeding, e.g., IPR or PGR, 

except for that person shall not participate—directly or indirectly—in the amendment of 

any claim(s).

13. Nothing in this Order shall require production of documents, information, or other material 

that a Party contends is protected from disclosure by the attorney-client privilege, the work 

product doctrine, or other privilege, doctrine, or immunity. If documents, information, or 

other materialsubject to a claim of attorney-client privilege, work product doctrine, or other 

privilege, doctrine, or immunity is inadvertently or unintentionally produced, such 

production shall in no way prejudice or otherwise constitute a waiver of, or estoppel as to, 

any such privilege, doctrine, or immunity. Any Party that inadvertently or unintentionally 

produces documents, information, or other material it reasonably believes are protected

under the attorney-client privilege, work product doctrine, or other privilege, doctrine, or

immunity may obtain the return of such documents, information, or other material by

promptly notifying the recipient(s) and providing a privilege log for the inadvertently or 

unintentionally produced documents, information, or other material. The recipient(s)

shall gather and return all copies of such documents, information, or other material to the 

producingParty, exceptfor any pages containing privileged or otherwise protectedmarkings 

by the recipient(s), which pages shall instead be destroyed and certified as such to the 

producing Party.

14. There shall be no disclosure of any DESIGNATED MATERIAL by any person authorized 

to have access thereto to any person who is not authorized for such access under this Order. 

The Parties are hereby ORDERED to safeguard all such documents, information, and 

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 9 of 16
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material to protect against disclosure to any unauthorized persons or entities.

15. Nothing contained herein shall be construed to prejudice any Party’s right to use any 

DESIGNATED MATERIAL in taking testimony at any deposition or hearing provided that 

the DESIGNATED MATERIAL is only disclosed to a person(s) who is: (i) eligible to have 

access to the DESIGNATED MATERIAL by virtue of his or her employment with the 

designatingParty;(ii)identified in theDESIGNATEDMATERIALas an author, addressee, 

or copy recipient of such information; (iii) although not identified as an author, addressee, 

or copy recipient of such DESIGNATED MATERIAL, has, in the ordinary course of 

business, seen such DESIGNATED MATERIAL; (iv) a current or former officer, director 

or employee of the producing Party or a current or former officer, director, or employee

of a company affiliated with the producing Party; (v) counsel for a Party, including outside 

counsel and in-house counsel (subject to paragraph 9 of this Order); (vi) an independent 

contractor, consultant, and/or expert retained for the purpose of this litigation; (vii) court 

reporters and videographers; (viii) the Court; or (ix) other persons entitled hereunder to 

access to DESIGNATED MATERIAL. DESIGNATED MATERIAL shall not be

disclosed to any other persons unless prior authorization is obtained from counsel

representing the producing Party or from the Court.

16. Parties may, at the deposition or hearing or within thirty (30) days after receipt of a 

deposition or hearing transcript, designate the deposition or hearing transcript or any portion 

thereof as “CONFIDENTIAL,” “CONFIDENTIAL - ATTORNEYS’ EYES ONLY,” 

“CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL -

SOURCE CODE” pursuant to this Order. Accessto the deposition or hearing transcript so

designated shall be limited in accordance with the terms of this Order. Until expiration of

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the 30-day period, the entire deposition or hearing transcript shall be treated as 

CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY.

17. Any DESIGNATED MATERIAL that is filed with the Court shall be filed under seal and 

shallremain underseal untilfurther order oftheCourt. The filing Party shall be responsible 

for informing the Clerk of the Court that the filing should be sealed and for placing the 

legend “FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER” above the 

caption and conspicuously on each page of the filing. Exhibits to a filing shall conform

to the labeling requirements set forth in this Order. If a pretrial pleading filed with the

Court, or an exhibit thereto, discloses or relies on DESIGNATED MATERIAL, such 

confidential portions shall be redacted to the extent necessary and the pleading or exhibit 

filed publicly with the Court.

18. The Order applies to pretrial discovery. Nothing in this Order shall be deemed to prevent 

the Parties from introducing any DESIGNATED MATERIAL into evidence at the trial of 

this Action, or from using any information contained in DESIGNATED MATERIAL at 

the trial of this Action, subject to any pretrial order issued by this Court.

19. A Party may request in writing to the other Party that the designation given to any 

DESIGNATED MATERIAL be modified or withdrawn. If the designating Party does

not agree to re-designation within ten (10) days of receipt of the written request, the

requesting Party may apply to the Court for relief. Upon any such application to the Court,

the burden shall be on the designating Party to show why its classification is proper. Such

application shall be treated procedurally as a motion to compel pursuant to Federal Rule 

of Civil Procedure 37, subject to the Rule’s provisions relating to sanctions. In making 

such application, the requirements of the Federal Rules of Civil Procedure and the Local 

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Rules of the Court shall be met. Pending the Court’s determination of the application, the 

designation of the designating Party shall be maintained.

20. Each outside consultant or expert to whom DESIGNATED MATERIAL is disclosed in 

accordance with the terms of this Order shall be advised by counsel of the terms of this 

Order, shall be informed that they are subject to the terms and conditions of this Order, and

shall sign an acknowledgment that they have received a copy of, have read, and have

agreed to be bound by this Order. A copy of the acknowledgment form is attached as 

Appendix A.

21. To the extent that any discovery is taken of persons who are not Parties to this Action 

(“Third Parties”) and in the event that such Third Parties contend the discovery sought 

involves trade secrets, confidential business information, or other proprietary information, 

then such Third Parties may agree to be bound by this Order.

22. To the extent that discovery or testimony is taken of Third Parties, the Third Parties may 

designate as “CONFIDENTIAL,” “CONFIDENTIAL - ATTORNEYS’ EYES ONLY,” 

or “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” and/or 

“CONFIDENTIAL - SOURCE CODE” any documents, information, or other material, in 

whole or in part, produced by such Third Parties. TheThird Partiesshall have ten (10) days

after production of such documents, information, or other materials to make such a

designation. Until that time period lapses or until such a designation has been made,

whichever occurssooner, all documents,information, or othermaterialso produced or given

shall be treated as “CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY” in

accordance with this Order.

23. Within thirty (30) days of final termination of this Action, including any appeals, all 

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DESIGNATED MATERIAL, including all copies, duplicates, abstracts, indexes, summaries, 

descriptions, and excerpts or extracts thereof (excluding excerpts or extracts incorporated 

into any privileged memoranda of the Parties), shall at the producing Party’s election either 

be returned to the producing Party or be destroyed. The receiving Party shall verify the 

return or destruction by affidavit furnished to the producing Party, upon the producing 

Party’s request.

24. The failure to designate documents, information, or material in accordance with this Order

and the failure to object to a designation at a given time shall not preclude the filing of a

motion at a later date seeking to impose such designation or challenging the propriety

thereof. The entry of this Order and/or the production of documents, information, or

material hereunder shall in no way constitute a waiver of any objection to the furnishing

thereof, all such objections being hereby preserved.

25. Any Party knowing or believing that any other Party is in violation of or intends to violate

this Order and has raised the question of violation or potential violation with the opposing

Party and has been unable to resolve the matter by agreement may move the Court for such

relief as may be appropriate in the circumstances. Pending disposition of the motion by

the Court, the Party alleged to be in violation of or intending to violate this Order shall

discontinue the performance of and/or shall not undertake the further performance of any

action alleged to constitute a violation of this Order.

26. Production of DESIGNATED MATERIAL by any Party shall not be deemed a

publication of the documents, information, or material (or the contents thereof) produced

so asto void or make voidable whatever claim the Parties may have asto the proprietary and

confidential nature of the documents, information, or other material or its contents.

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27. Nothing in this Ordershall be construed to effect an abrogation, waiver, or limitation of any

kind on the rights of each of the Parties to assert any applicable discovery or trial privilege.

28. Each of the Partiesshall also retain the right to file a motion with the Court (a) to modify this

Order to allow disclosure of DESIGNATED MATERIAL to additional persons or entities

if reasonably necessary to prepare and present this Action; and (b) to apply for additional

protection of DESIGNATED MATERIAL.

Signed on June 1st, 2021.

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 14 of 16
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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC D/B/A

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v.

ZTE CORPORATION ET AL, 

Defendant.

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

CIVIL ACTION 6:20-CV-00487-ADA

CIVIL ACTION 6:20-CV-00488-ADA

CIVIL ACTION 6:20-CV-00489-ADA

CIVIL ACTION 6:20-CV-00490-ADA

CIVIL ACTION 6:20-CV-00491-ADA

CIVIL ACTION 6:20-CV-00492-ADA

CIVIL ACTION 6:20-CV-00493-ADA

CIVIL ACTION 6:20-CV-00494-ADA

CIVIL ACTION 6:20-CV-00495-ADA

CIVIL ACTION 6:20-CV-00496-ADA

CIVIL ACTION 6:20-CV-00497-ADA

PATENT CASE

JURY TRIAL DEMANDED

APPENDIX A

UNDERTAKING OF EXPERTS OR CONSULTANTS REGARDING 

PROTECTIVE ORDER

I, ___________________________________________, declare that: 

1. My address is _________________________________________________________.

My current employer is _________________________________________________.

My current occupation is ________________________________________________.

2. I have received a copy of the Protective Order in this action. I have carefully read and

understand the provisions of the Protective Order.

3. I will comply with all of the provisions of the Protective Order. I will hold in confidence,

will not disclose to anyone not qualified under the Protective Order, and will use only for

purposes of this action any information designated as “CONFIDENTIAL,”

“CONFIDENTIAL - ATTORNEYS’ EYES ONLY,” “CONFIDENTIAL - OUTSIDE

ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL - SOURCE CODE” that is

Case 6:20-cv-00491-ADA Document 80 Filed 06/01/21 Page 15 of 16
2 

disclosed to me. 

4. Promptly upon termination of these actions, I will return all documents and things

designated as “CONFIDENTIAL,” “CONFIDENTIAL - ATTORNEYS’ EYES ONLY,”

“CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY,” or “CONFIDENTIAL -

SOURCE CODE” that came into my possession, and all documents and things that I have

prepared relating thereto, to the outside counsel for the Party by whom I am employed.

5. I hereby submit to the jurisdiction of this Court for the purpose of enforcement of the

Protective Order in this action.

I declare under penalty of perjury that the foregoing is true and correct. 

Signature ________________________________________ 

Date ______________________________ 

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