Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 1 of 27
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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.

GOOGLE LLC,

Defendant

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CIVIL ACTION 6:20-CV-00571-ADA 

CIVIL ACTION 6:20-CV-00572-ADA

CIVIL ACTION 6:20-CV-00573-ADA

CIVIL ACTION 6:20-CV-00574-ADA

CIVIL ACTION 6:20-CV-00575-ADA

CIVIL ACTION 6:20-CV-00576-ADA

CIVIL ACTION 6:20-CV-00577-ADA

CIVIL ACTION 6:20-CV-00578-ADA

CIVIL ACTION 6:20-CV-00579-ADA

CIVIL ACTION 6:20-CV-00580-ADA

CIVIL ACTION 6:20-CV-00581-ADA

CIVIL ACTION 6:20-CV-00582-ADA

CIVIL ACTION 6:20-CV-00583-ADA

CIVIL ACTION 6:20-CV-00584-ADA

CIVIL ACTION 6:20-CV-00585-ADA

PATENT CASE

JURY TRIAL DEMANDED

PROTECTIVE ORDER FOR PATENT CASES

WHEREAS, Plaintiff WSOU Investments LLC d/b/a Brazos Licensing and Development

and Defendant Google LLC , 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 

these Actions1;

WHEREAS, the Parties seek 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 or Third Party may designate as confidential for protection under this Order, in 

1 These Actions means the Case Nos. 6:20-cv-0571 through 6:20-cv-00585. 

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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 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.” The word 

“CONFIDENTIAL” shall be placed clearly on each page of the Protected Material (except 

deposition and hearing transcripts and natively produced documents) 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 as is designated as containing Protected Material. For natively produced 

Protected Material, the appropriate designation ” shall be placed on the placeholder image 

bearing the Bates number for the native file and in the filename of each such natively 

produced document. 

2. Any document produced under this Court’s Standing Order Governing Proceedings-Patent 

Case before issuance of this Order with the designation “Confidential” or “Confidential -

Outside Attorneys’ Eyes Only” shall receive the same treatment as if designated 

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

document is redesignated to have a different classification under this Order.

3. With respect to documents, information or material designated “CONFIDENTIAL,” 

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

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SOURCE CODE” (“DESIGNATED MATERIAL”),2 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 (i.e., “CONFIDENTIAL,” “RESTRICTED -

ATTORNEYS’ EYES ONLY,” or “RESTRICTED 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, 

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

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

ONLY,” or “RESTRICTED CONFIDENTIAL SOURCE CODE,” both individually and 

collectively.

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information or material derived from or based thereon.

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 16 herein:

(a) outside counsel of record in these Actions for the Parties and outside counsel 

retained for the purpose of this litigation;

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

counsel in the litigation of this Action;

(c) up to two in-house counsel for the Parties who are members in good standing of at 

least one state bar and have responsibility for making decisions dealing directly 

with the litigation of this Action and who have completed the Undertaking attached 

as Exhibit A3;

(d) up to and including two (2) designated representatives of each of the Parties to the 

extent reasonably necessary for the litigation of this Action, except that either 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; and the designated representatives have 

completed the Undertaking attached as Exhibit A;

(e) outside consultants or experts4 (i.e., not existing employees or affiliates of a Party 

or an affiliate of a Party) retained for the purpose of this litigation, provided that: 

(1) such consultants or experts are not presently employed by the Parties hereto for 

3 The signed undertakings shall be maintained by the Parties but do not need to be served on the 

opposing Party except under 5(e).

4 For any such person, the curriculum vitae shall identify his/her (i) current employer(s), (ii) each 

person or entity from whom s/he has received compensation or funding for work in his or her areas 

of expertise or to whom the s/he has provided professional services, including in connection with 

a litigation, at any time during the preceding five years; (iii) (by name and number of the case, 

filing date, and location of court) any litigation in connection with which s/he has offered expert 

testimony, including through a declaration, report, or testimony at a deposition or trial, during the 

preceding five years. If such consultant or expert believes any of this information is subject to a 

confidentiality obligation to a third-party, then the s/he should provide whatever information can 

be disclosed without violating any confidentiality agreements, and the Party seeking to disclose 

Protected Material to the consultant or expert shall be available to meet and confer with the 

designating Party regarding any such engagement.

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purposes other than this Action5; (2) before access is given, the consultant or expert 

has completed the Undertaking attached as Exhibit A hereto and the same is served 

upon the Producing Party with a current curriculum vitae of the consultant or expert 

at least seven (7) days before access to the Protected Material is to be given to that 

consultant or Undertaking 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 within three business days in good faith to resolve 

any such objection. If the Parties are unable to resolve any objection, the objecting 

Party must file a letter to the court within three (3) business day requesting a 

hearing or other suitable proceeding as soon as possible, 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 order6 or after the time for objecting to such expert has expired;

(f) independent litigation support services, including contract attorneys who have 

completed the Undertaking attached as Exhibit A, 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.

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 

5 For avoidance of doubt, an independent expert or consultant retained (as opposed to employed) 

by a Party on another litigation would not be precluded under this section.

6 A party who has not previously objected to disclosure of Protected Material to an expert or whose 

objection has been resolved with respect to previously produced Protected Material shall not be 

precluded from raising an objection to an expert at a later time with respect to Protected Material 

that is produced after the time for objecting to such expert has expired or if new information about 

that expert is disclosed or discovered. 

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

be used for any other purpose. All produced Protected Material shall be carefully 

maintained so as to preclude access by persons who are not entitled to receive such 

Protected Material, and 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 of such 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. 

Disclosure of DESIGNATED MATERIALS be subject to all applicable laws and 

regulations relating to the export of technical data contained in such DESIGNATED 

MATERIALS including the release of such technical data to foreign persons or nationals 

in the United States or elsewhere. Each party receiving DESIGNATED MATERIALS 

shall comply with all applicable export control statutes and regulations. 

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 “RESTRICTED --

ATTORNEYS’ EYES ONLY,” or to the extent such Protected Material includes computer 

source code [Google Proposal - Default PO: and/or live data (that is, data as it exists 

residing in a database or databases) (“Source Code Material”)] [WSOU Proposal: (“Source 

Code Material”) (i.e., a text listing of computer instructions, commands and data 

definitions expressed in a form suitable for input to an assembler, compiler, or other 

translator)], the Producing Party may designate such Protected Material as “RESTRICTED 

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CONFIDENTIAL SOURCE CODE.”

9. For Protected Material designated RESTRICTED -- 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).

10. For Protected Material designated RESTRICTED CONFIDENTIAL SOURCE CODE, the 

following additional restrictions apply:

a. Access to a Party’s Source Code Material shall be provided on two standalone review 

computers per case available for in-person review as follows: each “stand-alone” 

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

area network (“LAN”), an intranet or the Internet) with a display screen or monitor of 

a size of at least seventeen inches for each review computer in a secured locked room. 

Each stand-alone computer may only be connected to a device capable of temporarily 

storing electronic copies solely for the limited purposes permitted pursuant to 

paragraphs 10(h) and 10(o) below. The stand-alone computers shall, at the Receiving 

Party's request, include reasonable analysis tools for the type of Source Code Material. 

The Receiving Party shall be responsible for providing the tools or licenses to the tools 

that it wishes to use so that the Producing Party may install such tools on the standalone computers. Additionally, except as provided in paragraph 10(o) below, the standalone computers may only be located [WSOU Proposal: in Austin, Texas at the offices 

of the Producing Party’s outside counsel or a location in Austin selected by such outside 

counsel] [Google Proposal - Default PO: at the offices of Producing Party’s outside 

counsel]. The stand-alone computers shall have disk encryption and be password 

protected. Use or possession of any input/output device (e.g., USB memory stick, 

mobile phone or tablet, camera or any camera-enabled device, CD, floppy disk, 

portable hard drive, laptop, or any device that can access the Internet or any other 

network or external system, etc.) is prohibited while accessing the computer containing 

the source code. The hosting facility for the producing Party shall provide a secure 

location to store personal electronic devices, such as cellular telephones, where they 

will be readily accessible to the reviewer outside the review room upon request. The 

reviewing Party or its expert(s) will not attempt to circumvent the security of the review 

computer or confidentiality of the source code displayed;

b. The Producing Party may periodically “check in” on the activities of the Receiving 

Party’s representatives during any stand-alone computer review and may visually 

monitor the activities of the Receiving Party’s representatives from outside the room 

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in which the stand-alone computers are located, but only to ensure that no unauthorized 

electronic records of the Source Code Material and no information concerning the 

Source Code Material are being created or transmitted in any way; such monitoring 

activities being free from any interference that impedes or hinders the representatives’ 

source code review. The producing Party will refrain from any active monitoring 

activities that reveal Attorney Work Product (e.g., viewing the source code review 

notes, monitoring the contents of the review computer’s screen during the review, or 

listening to conversation of the source code reviewer); such monitoring activities will 

not be considered to be reasonable. 

c. The Receiving Party shall make reasonable efforts to restrict its requests for such access 

to the stand-alone computers to normal business hours, which for purposes of this 

paragraph shall be no less than 8:00 a.m. through 6:00 p.m. However, upon reasonable 

notice from the receiving party, the producing Party shall make reasonable efforts to 

accommodate the receiving Party’s request for access to the review computer 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 shall not unreasonably hinder the Receiving Party’s ability to efficiently and 

effectively conduct the prosecution or defense of this Action;

d. The Producing Party shall provide the Receiving Party with information explaining 

how to start, log on to, and operate the stand-alone computers in order to access the 

produced Source Code Material on the stand-alone computers;

e. The Producing Party will produce Source Code Material in computer searchable format 

on the stand-alone computers as described above;

f. Access to Source Code Material shall be limited to outside counsel and up to three (3) 

outside consultants or experts per case7 (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 if 

necessary include excerpts of Source Code Material in a pleading, exhibit, expert 

report, discovery document, deposition transcript, other Court document, provided that 

any such documents are appropriately marked as containing Source Code Material 

under this Order, restricted to those who are entitled to have access to them as specified 

7 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), and further provided that there shall be no more than two such personnel.

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

procedures and orders;

g. To the extent portions of Source Code Material are quoted in an electronic copy or 

image of a document which, pursuant to the Court’s rules, procedures, or order, must 

be filed or served electronically (“Source Code Document”), either (1) the entire Source 

Code Document will be stamped and treated as RESTRICTED CONFIDENTIAL 

SOURCE CODE or (2) those pages containing quoted Source Code Material will be 

separately stamped and treated as RESTRICTED CONFIDENTIAL SOURCE CODE;

h. Except as set forth in paragraph herein, no electronic copies of Source Code Material 

shall be made without prior written consent of the Producing Party, except as necessary 

to create documents which, pursuant to the Court’s rules, procedures and order, must 

be filed or served electronically;

i. The Receiving Party shall only include such excerpts as are reasonably necessary for 

the purposes for which such part of the Source Code Material is used. Images or copies 

of Source Code Material shall not be included in correspondence between the parties 

(references to production numbers shall be used instead) and shall be omitted from 

pleadings and other papers except to the extent permitted herein. The Receiving Party 

may create an electronic image of a selected portion of the Source Code Material only 

when the electronic file containing such image has been encrypted using commercially 

reasonable encryption software including password protection. The communication 

and/or disclosure of electronic files containing any portion of Source Code Material 

shall at all times be limited to individuals who are authorized to see Source Code 

Material under the provisions of this Protective Order. Additionally, all electronic 

copies must be labeled “RESTRICTED CONFIDENTIAL SOURCE CODE.” If 

Source Code Documents are filed with the Court, they must be filed under seal in 

accordance with the Court’s rules, procedures and orders;

j. The Receiving Party may request a reasonable number of pages of Source Code to be 

printed by the Producing Party. The Source Code Computers may be equipped with 

virtual printer software to permit the Receiving Party to print selected portions of 

Source Code to a PDF file that can be printed subsequently by the Producing Party. 

After making printed copies of the PDF, the producing party shall not delete the 

requested PDFs from the source code computers.

k. [Google Proposal: Each print request shall be made in writing to the Producing Party. 

Any print request that consists of more than twenty-five (25) pages of a continuous 

block of Source Code shall be presumed to be excessive, and the burden shall be on the 

Receiving Party to demonstrate the need for such a printed copy. The Receiving Party 

may request printed Source Code of no more than one thousand (1000) pages total, 

subject to further agreement between the Producing Party and Receiving Party or order 

by the Court.] [WSOU Proposal: do not include Google’s proposal] The Receiving 

Party shall not request printed Source Code to review Source Code elsewhere in the 

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first instance, i.e., as an alternative to reviewing that Source Code electronically on the 

Source Code Computer. To the extent the Receiving Party requires an aggregate total 

of more than [Google Proposal: 1000 pages of Source Code] [WSOU Proposal: 1000 

pages of Source Code for any software release, limited by a contiguous block of no 

more than one-hundred (100) pages], the Receiving Party shall make such request, and 

the Parties shall meet and confer in an effort to reach an agreement to produce an agreed 

number of additional pages. The Producing Party shall Bates number, copy, and label 

“RESTRICTED CONFIDENTIAL SOURCE CODE” any pages requested by the 

Receiving Party;

l. Within [WSOU Proposal: one (1) business day] [Google Proposal: no later than two 

(2) business days] of receiving a print request, the Producing Party shall either (i) 

provide to the Receiving Party five (5) Bates stamped hard copies of the requested 

Source Code, which at the Producing Party’s sole discretion may be provided on 

watermarked paper (“Original Copies”) or (ii) inform the Requesting Party that it 

objects to the print request or portions thereof as inconsistent with this Order. The 

Parties shall immediately meet and confer and raise the issue with the Court if they 

cannot resolve the objection. 

m. Should such printouts or photocopies be transferred back to electronic media, such 

media shall be labeled “RESTRICTED CONFIDENTIAL SOURCE CODE” and shall 

continue to be treated as such;

n. If the Receiving Party’s outside counsel, consultants, or experts obtain Source Code 

Printouts, the Receiving Party shall ensure that such outside counsel, consultants, or 

experts keep the Source Code Printouts under their direct control in a secured locked 

area in the offices of such outside counsel, consultants, or expert. The Receiving Party 

may also temporarily keep the Source Code Printouts 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 Source Code Printouts to a 

Court proceeding or deposition, provided that the printouts or photocopies are kept in 

a secure manner that ensures access is limited to the persons authorized under this 

Order. [WSOU Proposal – Default PO: 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 

“HIGHLY CONFIDENTIAL – SOURCE CODE,” and the receiving Party shall 

maintain a log of all such files that are printed or photocopied.] [Google Proposal: do 

not include WSOU’s proposal] 

o. A Producing Party’s Source Code Material may only be transported [WSOU Proposal 

– Default PO: by the Receiving Party at the direction of a person authorized under 

paragraph 10(f) above to another person authorized under paragraph 10(f) above, on 

paper via hand carry, Federal Express or other similarly reliable courier.] [Google 

Proposal: by the Receiving Party at the direction of a person authorized under 

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paragraph 10(f) above to another person authorized under paragraph 10(f) above, and 

on paper via hand carry (including via a hand carry courier service).] Source Code 

Material may not be transported or transmitted electronically over a network of any 

kind, including a LAN, an intranet, or the Internet, except as expressly permitted herein. 

Source Code Material may only be transported electronically via removable electronic 

media (e.g., a DVD, CD-ROM, or flash memory “stick”) for the purpose of Court 

proceeding(s) or deposition(s) as set forth in paragraphs 10(h-i) above and is at all times 

subject to the transport restrictions set forth herein. But, for those purposes only, the 

Source Code Materials may be loaded onto a stand-alone computer.

p. The Receiving Party’s outside counsel and/or expert shall be entitled to take notes 

relating to the source code but may not copy any portion of the source code into the 

notes. No copies of all or any portion of the source code may leave the room in which 

the source code is inspected except as otherwise provided herein. Further, no other 

written or electronic record of the source code is permitted except as otherwise 

provided herein. No notes shall be made or stored on the inspection computer, or left 

behind at the site where the inspection computer is made available, and any such notes 

shall be deleted or destroyed by the Producing Party, without reviewing the substance 

of the notes, upon discovery. Notwithstanding the foregoing, any such notes shall be 

stamped and treated as “RESTRICTED CONFIDENTIAL SOURCE CODE” The log 

of such notes need not be produced to any other party absent Court Order (e.g. 

potentially in connection with a Protective Order violation motion). If during the course 

of a review the receiving Party has stored electronic print-outs of Source Code Material 

(for example a pdf file) on the review computer, the receiving Party may request the 

producing Party provide the receiving Party with a Bates-labeled and appropriately 

designated paper copy of the electronic print-outs to the Receiving Party within 

[WSOU Proposal: one business day] [Google Proposal: no later than two business 

days]. The producing Party will not delete such stored electronic print-outs from the 

review computer.

q. The Producing Party will notify the Receiving party when the Source Code production 

is complete and ready for inspection. A list of names of persons who will review Source 

Code Material on the stand- alone computers will be provided to the Producing Party 

in conjunction with any written (including email) notice requesting inspection. Prior to 

the first inspection of any Source Code Material on the stand-alone computers, the 

Receiving Party shall provide five (5) business days’ notice to schedule the initial 

inspection with the Producing Party. The Receiving Party shall provide two (2) 

business days’ notice8 in advance of scheduling any additional inspections. Any single 

inspection may span multiple days based on the same notice if the notice details the 

8 The counting of business days is inclusive of the day notice is provided if the notice is provided 

by 6pm CT. For example, for a Monday inspection, notice must be provided by 6pm CT on the 

preceding Thursday.

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number of days. Such notice shall include the names and titles for every individual 

from the Receiving Party who will attend the inspection. The Producing Party may 

maintain a daily log of the names of persons who enter the locked room to view the 

source code and when they enter and depart;

r. The Receiving Party’s outside counsel shall maintain a log of all copies of the Source 

Code Printouts (received from a Producing Party) that are delivered by the Receiving 

Party to any person and a log of any electronic images of Source Code Material. The 

log shall include the names of the recipients and reviewers of copies and locations 

where the copies are stored. Upon request by the Producing Party, the Receiving Party 

shall provide reasonable assurances and/or descriptions of the security measures 

employed by the Receiving Party and/or person that receives a copy of any portion of 

the source code; and

s. All copies of any portion of the Source Code Printouts in whatever form shall be 

securely destroyed. Copies of Source Code Printouts that are marked as deposition 

exhibits shall not be provided to the Court Reporter or attached to deposition 

transcripts; rather, the deposition record will identify the exhibit by its production 

numbers.

11. [WSOU: Any person permitted to receive the other Party’s Designated Material that is 

designated RESTRICTED -- ATTORNEYS’ EYES ONLY and/or RESTRICTED 

CONFIDENTIAL – SOURCE CODE and directed to technical information relevant to the 

case, but excluding financial data or non-technical business information (collectively 

“HIGHLY SENSITIVE MATERIAL”), who obtains, receives, 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 Field of Invention of the patents-in-suit on behalf of the 

Receiving Party or its acquirer, successor, predecessor, or other affiliate during the 

pendency of this Action and for one year after its conclusion, including any appeals, or 

two years after such person last reviewed the HIGHLY SENSITIVE TECHNICAL 

MATERIAL, whichever is earlier. Nothing in this Order shall prevent a person with access 

to HIGHLY SENSITIVE MATERIAL from participating in a PTO proceeding, e.g., IPR 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 13 of 27
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or PGR, except for that person shall not participate—directly or indirectly—in the 

amendment of any claim(s). Each Party shall create an “Ethical Wall” between those 

persons with access to HIGHLY SENSITIVE TECHNICAL MATERIAL, and any 

individuals who, on behalf of the Party or its acquirer, successor, predecessor, or other 

affiliate, prepare, prosecute, supervise, or assist in the preparation or prosecution of any 

patent application pertaining to the field of invention of the patent-in-suit.] [Google 

Proposal – Default PO: 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 of this Action 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 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).]

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12. [Google Proposal: Absent written consent from the designating Party, any individual 

affiliated with Plaintiff who obtains, receives, has access to, or otherwise learns, in whole 

or in part, the any other Party’s HIGHLY SENSITIVE MATERIAL under this Order shall 

not be involved in any activity related to: (i) the acquisition of patents or patent 

applications relating to the Field of Invention or (ii) the advising or counseling clients 

regarding the same. This Acquisition Bar shall begin when such HIGHLY SENSITIVE 

MATERIAL is first received by the affected individual and shall end after the conclusion 

of this Action, including any appeals.] [WSOU Proposal – Default PO: no acquisition bar]

13. Disclosure of Protected Material shall be subject to all applicable laws and regulations 

relating to the export of technical data contained in such Protected Material, including the 

release of such technical data to foreign persons or nationals in the United States or 

elsewhere. Each party receiving Protected Material shall comply with all applicable 

export control statutes and regulations. See, e.g., 15 CFR 734. [Google Proposal: No 

Protected Material may leave the territorial boundaries of the United States of America. 

Without limitation, this prohibition extends to Protected Material (including copies) in 

physical and electronic form. The viewing of Protected Material through electronic means 

outside the territorial limits of the United States of America is similarly prohibited. 

Notwithstanding this prohibition, Protected Material, exclusive of material designated 

RESTRICTED CONFIDENTIAL ‐ SOURCE CODE, and to the extent otherwise 

permitted by law, may be taken outside the territorial limits of the United States if it is 

reasonably necessary for a deposition taken in a foreign country. The restrictions 

contained within this paragraph may be amended through the consent of the Producing 

Party to the extent that such agreed to procedures conform with applicable export control 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 15 of 27
15

laws and regulations.] [WSOU Proposal – Default PO: do not include]

14. If a Party is served with a subpoena or a court order issued in other litigation that compels 

disclosure of any information or items designated in this Action as “CONFIDENTIAL,” 

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

CONFIDENTIAL – SOURCE CODE,” that Party must:(a) promptly notify in writing the 

designating Party. Such notification shall include a copy of the subpoena or court order if 

allowed under applicable protective orders in the other litigation;(b) promptly notify in 

writing the party who caused the subpoena or order to issue in the other litigation that 

some or all of the material covered by the subpoena or order is subject to this Protective 

Order. Such notification shall include a copy of this Order. If the designating Party timely 

seeks a protective order, the Party served with the subpoena or court order shall not 

produce any information designated in this Action as “CONFIDENTIAL,” “HIGHLY 

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

SOURCE CODE” before a determination by the court from which the subpoena or order 

issued, unless the Party has obtained the designating Party’s permission. The designating 

Party shall bear the burden and expense of seeking protection in that court of its 

confidential material – and nothing in these provisions should be construed as authorizing 

or encouraging a receiving Party in this Action to disobey a lawful directive from another 

court.

15. [Google Proposal - Default PO: Do not include this section] [WSOU Proposal: include 

this section: In the event that a Party is required, by a valid discovery request, to produce 

a Non-Party’s confidential information in its possession, and the Party is subject to an 

agreement with the Non-Party not to produce the Non-Party’s confidential information, 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 16 of 27
16

then the Party shall:

1. within three (3) business days notify in writing the Requesting Party and 

the Non-Party simultaneously that some or all of the information requested is 

subject to a confidentiality agreement with a Non-Party; 

2. promptly provide the Non-Party with a copy of this Order, the relevant 

discovery request(s), and a reasonably specific description of the information 

requested; and

3. make the information requested available for inspection by the Non-Party. 

If the Non-Party fails to object and seek a protective order from this court within 

14 calendar days of receiving the notice and accompanying information, the Party 

shall produce the Non-Party’s confidential information responsive to the discovery 

request. If the Party maintains it cannot produce the Non-Party’s confidential 

information even after the notice and accompanying information have been 

provided, the Party may prepare a joint motion in which the Party and the 

Requesting Party ask that the court order expedited production of the Non-Party’s 

confidential information in response to the discovery request. If the Non-Party 

timely seeks a protective order, the Party shall not produce any information in its 

possession or control that is subject to the confidentiality agreement with the NonParty before a determination by the court. Absent a court order to the contrary, the 

Non-Party shall bear the burden and expense of seeking protection in this court of 

its Protected Material.]

16. 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 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 17 of 27
17

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

or other material subject 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 

notifying the recipient(s) and providing a privilege log for the produced documents, 

information or other material. The recipient(s) shall gather and return all copies of such 

documents, information or other material to the Producing Party, except for any pages 

containing privileged or otherwise protected markings by the recipient(s), which pages 

shall instead be destroyed and certified as such to the Producing Party. After notice is 

provided, no use shall be made of such material during deposition or at trial, or for any 

other purpose or in any other manner, nor shall such material be shown to anyone except 

as necessary to facilitate the return or destruction of such documents or information. If any 

such inadvertently produced material has been used in any other document generated in 

connection with the Action, including deposition transcripts, exhibits, and court filings, to 

the extent reasonably possible, the material shall be expunged or destroyed.

17. 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 

material to protect against disclosure to any unauthorized persons or entities. If a receiving 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 18 of 27
18

Party or person authorized to access DESIGNATED MATERIAL (“Authorized 

Recipient”) discovers any loss of DESIGNATED MATERIAL or a breach of security, 

including any actual or suspected unauthorized access, relating to another party’s 

DESIGNATED MATERIAL, the receiving Party or Authorized Recipient shall: (1) 

promptly stop the unauthorized breach; (2) promptly (within 72 hours) provide written 

notice to designating Party of such breach, including information regarding the size and 

scope of the breach; and (3) investigate and make reasonable efforts to remediate the 

effects of the breach. In any event, the receiving Party or Authorized Recipient shall 

promptly take all necessary and appropriate corrective action to terminate any 

unauthorized access.

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

DESIGNATED MATERIAL in taking testimony at any deposition or at any 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 designating Party; (ii) identified in the DESIGNATED MATERIAL 

as 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 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 19 of 27
19

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.9 For 

depositions of Google fact witnesses taken remotely, unless the parties agree otherwise, 

the parties shall use Google Meet and Drive. For depositions of WSOU fact witnesses 

taken remotely, unless the parties agree otherwise, the parties shall use Zoom. Parties 

shall give the other Parties reasonable notice (a minimum of two business days) if they 

reasonably expect a deposition, hearing or other proceeding to include Protected Material 

so that the other Parties can ensure that only authorized individuals are present at those 

proceedings. Subject to any challenge to a particular designation under paragraph 20, the 

Parties will not oppose any reasonable request by the designating Party that the courtroom 

be sealed, if allowed by the Court, during the presentation of any testimony, evidence, or 

argument relating to or involving the use of any Protected Material.

19. 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,” “RESTRICTED - ATTORNEYS’ EYES ONLY,” 

or “RESTRICTED CONFIDENTIAL - SOURCE CODE” pursuant to this Order. Access 

to the deposition or hearing transcript so designated shall be limited in accordance with 

the terms of this Order. Until expiration of the 30-day period, the entire deposition or 

9 In the event a non-Party witness is authorized to receive Protected Material that is to be used 

during his/her deposition but is represented by an attorney not authorized under this Order to 

receive such Protected Material, the attorney must provide prior to commencement of the 

deposition an executed Undertaking attached as Exhibit A. In the event such attorney declines to 

sign the Undertaking prior to the examination, the Parties, by their attorneys, shall jointly seek a 

protective order from the Court prohibiting the attorney from disclosing Protected Material in order 

for the deposition to proceed.

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 20 of 27
20

hearing transcript shall be treated as “RESTRICTED - ATTORNEYS’ EYES ONLY”.

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

shall remain under seal until further order of the Court. 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 confidential documents, information or 

material, such confidential portions shall be redacted to the extent necessary and the 

pleading or exhibit filed publicly with the Court. At any point, (other than during a 

deposition) a Party may seek to designate and protect previously produced DESIGNATED 

MATERIAL as Highly Sensitive Documents/Information (HSD/HSI). The Parties will 

follow any applicable court orders regarding the procedures for HSD/HSI. 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.

21. 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 redesignation 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 Rules of Civil 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 21 of 27
21

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 Rules 

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

designation of the designating Party shall be maintained.

22. 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 he or she is subject to the terms and conditions of this Order, 

and shall sign an acknowledgment that he or she has received a copy of, has read, and has 

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

Appendix A.

23. 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.

24. To the extent that discovery or testimony is taken of Third Parties, the Third Parties or any 

Party may designate as “CONFIDENTIAL” or “RESTRICTED -- ATTORNEYS’ EYES 

ONLY” any documents, information or other material, in whole or in part, produced or 

given by such Third Parties. The Third Parties and any Party shall have seven (7) business 

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 occurs sooner, all documents, information or other material so produced or 

given shall be treated as “RESTRICTED -- ATTORNEYS’ EYES ONLY” in accordance 

with this Order. Where a Third Party designates any documents, information or other 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 22 of 27
22

material as provided herein, experts previously disclosed and approved hereunder prior to 

said Third Party’s production of any Protected Material need not be disclosed to said Third 

Party. Subsequently disclosed experts need not be disclosed to said Third Party before that 

Third Party’s Protected Material may be disclosed thereto.

25. Any person in possession of DESIGNATED MATERIAL will maintain appropriate 

administrative, technical, and organizational safeguards (“Safeguards”) that protect the 

security and privacy of DESIGNATED MATERIAL. The Safeguards will meet or exceed 

relevant industry standards and limit the collection, storage, disclosure, use of, or access to 

DESIGNATED MATERIAL solely to personnel and purposes authorized by this Order. 

As part of these Safeguards, each person will use a secure transfer method for all transfers 

or communication of DESIGNATED MATERIAL, and take reasonable measures to 

password protect and encrypt DESIGNATED MATERIAL. Each person will ensure that 

anyone acting on that person’s behalf is subject to the Safeguards or otherwise provides 

equivalent or greater protections for the security and privacy of DESIGNATED 

MATERIAL.

26. Even after final disposition of this litigation, the confidentiality obligations imposed by this 

Order shall remain in effect until the designating Party agrees otherwise in writing or a 

court order otherwise directs. Final disposition shall be deemed to be the later of (1) 

dismissal of all claims and defenses in this Action, with or without prejudice; and (2) final 

judgment herein after the completion and exhaustion of all appeals, rehearings, remands, 

trials, or reviews of this Action, including the time limits for filing any motions or 

applications for extension of time pursuant to applicable law. 

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

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 23 of 27
23

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

summaries, descriptions, and excerpts or extracts thereof (excluding materials which have 

been admitted into evidence in this Action), 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.

28. 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 and 

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

thereof, all such objections being hereby preserved.

29. 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.

30. Production of DESIGNATED MATERIAL by each of the Parties shall not be deemed a 

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

so as to void or make voidable whatever claim the Parties may have as to the proprietary 

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

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 24 of 27
24

31. Nothing in this Order shall 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.

32. Each of the Parties shall 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.

33. This Order shall be binding upon the Parties hereto, their attorneys, and their successors, 

executors, personal representatives, administrators, heirs, legal representatives, assigns, 

subsidiaries, divisions, employees, agents, retained consultants and experts, and any 

persons or organizations over which they have direct control.

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 25 of 27
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.

GOOGLE LLC,

Defendant

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

§

CIVIL ACTION 6:20-CV-00571-ADA 

CIVIL ACTION 6:20-CV-00572-ADA

CIVIL ACTION 6:20-CV-00573-ADA

CIVIL ACTION 6:20-CV-00574-ADA

CIVIL ACTION 6:20-CV-00575-ADA

CIVIL ACTION 6:20-CV-00576-ADA

CIVIL ACTION 6:20-CV-00577-ADA

CIVIL ACTION 6:20-CV-00578-ADA

CIVIL ACTION 6:20-CV-00579-ADA

CIVIL ACTION 6:20-CV-00580-ADA

CIVIL ACTION 6:20-CV-00581-ADA

CIVIL ACTION 6:20-CV-00582-ADA

CIVIL ACTION 6:20-CV-00583-ADA

CIVIL ACTION 6:20-CV-00584-ADA

CIVIL ACTION 6:20-CV-00585-ADA

PATENT CASE

JURY TRIAL DEMANDED

APPENDIX A

ACKNOWLEDGEMENT & AGREEMENT TO BE BOUND BY

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 

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 26 of 27
2

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

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

SOURCE CODE” that is disclosed to me.

4. Promptly upon termination of this Action, I will return all documents and things 

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

or “RESTRICTED 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 ____________________________________________

Case 6:20-cv-00571-ADA Document 49-1 Filed 09/02/21 Page 27 of 27