EXHIBIT 1
c9335)! 3C, 

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Julie E. Schwartz, Bar No. 260624 

J Schwartz@perkinscoie.com 

PERKINS COIE LLP 

3150 Porter Drive 

Palo Alto, CA 94304-1212 F I L D 

Telephone: 650.838.4300 SAN MATEO COUNTY 

Facsimile: 650.838.4350 

0 .T 25 ZUlE 

James R. McCullagh, admitted pro hac vice 

IMcCullagh@perkinscoie.com 

PERKINS COIE LLP 

1201 Third Avenue, Suite 4900 

Seattle, WA 98101-3099 

Telephone: 206.359.8000 

Facsimile: 206.359.9000 

Attorneys for Defendant 

F acebook, Inc. 

SUPERIOR COURT OF THE STATE OF CALIFORNIA 

COUNTY OF SAN MATEO 

SIX4THREE, LLC, a Delaware limited Case No. CIV533328 

liability company, 

STIPULATED [PROPOSED] 

Plaintiff, PROTECTIVE ORDER 

V. 

FACEBOOK, INC., a Delaware 

corporation and DOES 1-50, inclusive, 

Defendant. 

In order to protect confidential information obtained by the parties in connection with this 

case, the pa1ties, by and through their respective undersigned counsel and subject to the approval 

of the Count, hereby agree as follows: 

Part One: Use Of Confidential Material_s In Di_scoverv 

1. Any party or non-party may designate as Confidential Information (by stamping 

the relevant page or as otherwise set forth herein) any document or response to discovery which 

that party or non-party considers in good faith to contain information involving trade secrets, or 

CIV533328 

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Order STIPULATED [PROPOSED] PROTECTIVE ORDER 

231729 ' CASE NO. CIV533328 

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confidential business, financial, or personal information, including personal financial information 

about any individual or entity; information regarding any individual’s or entity’s banking 

relationship with any banking institution, including information regarding financial transactions 

or financial accounts, and any information regarding any individual or entity that is not otherwise 

available to the public, subject to protection under Rules 2.550, 2.551, 2.580, 2.585, 8.160, and 

8.490 of the California Rules of Court or under other provisions of California law. Any party or 

non-party may designate as Highly Confidential Information (by stamping the relevant page or as 

otherwise set forth herein) any document or response to discovery which that party or non-party 

considers in good faith to contain information involving highly sensitive trade secrets or 

confidential business, financial, or personal information, the disclosure of which would result in 

the disclosure of trade secrets or other highly sensitive research, development, production, 

personnel, commercial, market, financial, or business information, or highly sensitive personal 

information, subject to protection under Rules 2.550, 2.551, 2.580, 2585,8160, and 8.490 of the 

California Rules of Court or under other provisions of California law. Where a document or 

response consists of more than one page, the first page and each page on which confidential 

information appears shall be so designated. 

2. A party or non-party may designate information disclosed during a deposition or in 

response to written discovery as Confidential Information or Highly Confidential Information by 

so indicating in said responses or on the record at the deposition and requesting the preparation of 

a separate transcript of such material. In addition, a party or non-party may designate in writing, 

within thirty (30) days after receipt of said responses or of the deposition transcript for which the 

designation is proposed, that specific pages of the transcript and/or specific responses be treated 

as Confidential Information or Highly Confidential Information. Any other party may object to 

such proposal, in writing or on the record. Upon such objection, the parties shall follow the 

procedures described in Paragraph 9 below. Until the thirty (30) day period for designation has 

lapsed, the entirety of each deposition transcript shall be treated as Confidential Information. 

After the thirty (30) day period for designation has lapsed, any documents or information 

designated pursuant to the procedure set forth in this paragraph shall be treated according to the 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

- CASE NO. CIV533328
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designation until the matter is resolved according to the procedures described in Paragraph 9 

below, and counsel for all parties shall be responsible for marking all previously unmarked copies 

of the designated material in their possession or control with the specified designation. A party 

that makes original documents or materials available for inspection need not designate them as 

Confidential Information or Highly Confidential Information until after the inspecting party has 

indicated which materials it would like COpied and produced. During the inspection and before the 

designation and copying, all of the material made available for inspection shall be considered 

Highly Confidential Information. 

‘ 

3. All Confidential Information or Highly Confidential Information produced or 

exchanged in the course of this Case (not including information that is publicly available) shall be 

used by the party or parties to whom the information is produced solely for the purpose of this 

case. Confidential Information or Highly Confidential Information shall not be used for any 

commercial competitive, personal, or other purpose. Confidential Information or Highly 

Confidential Information must be stored and maintained by a receiving party at a location and in a 

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

Protective Order. The protections conferred by this Stipulated Protective Order cover not only 

the Confidential Information or Highly Confidential Information produced or exchanged in this 

case, but also (1) any information copied or extracted from or reflecting the Confidential 

Information or Highly Confidential Information; (2) all copies, excerpts, summaries, or 

compilations of Confidential Information or Highly Confidential Information; and (3) any 

testimony, conversations, or presentations by parties or their counsel that might reveal 

Confidential Information or Highly Confidential Information. However, the protections 

conferred by this Stipulated Protective Order do not cover the following information: (a) any 

information that is in the public domain at the time of disclosure to a receiving party or becomes 

part of the public domain after its disclosure to a receiving party as a result of publication not 

involving a violation of this Stipulated Protective Order, including becoming part of the public 

record through trial or otherwise; and (b) any information known to the receiving party prior to 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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the disclosure or obtained by the receiving party after the disclosure from a source who obtained 

the information lawfully and under no obligation of confidentiality to the designating party. 

4. Except with the prior written consent of the other parties, or upon prior order of 

this Court obtained upon notice to opposing counsel, Confidential Information shall not be 

disclosed to any person other than: 

(a) 

(b) 

(C) 

(e) 

(f) 

(g) 

counsel for the respective parties to this litigation, including in-house 

counsel and co-counsel retained for this litigation; 

employees of such counsel; 

individual parties or officers or employees of a party, to the extent deemed 

necessary by counsel for the prosecution or defense of this litigation; 

(d) consultants or expert witnesses retained for the prosecution or defense of 

this litigation, provided that each such person shall execute a copy of the 

Certification annexed to this Order (which shall be retained by counsel to 

the party so disclosing the Confidential Information and made available 

for inspection by opposing counsel during the pendency or after the 

termination of the action only upon good cause shown and upon order of 

the Court) before being shown or given any Confidential Information, and 

provided that if the party chooses a consultant or expert employed by the 

opposing party or one of its competitors, the party shall notify the 

opposing party, or designating non-party, before disclosing any 

Confidential Information to that individual and shall give the opposing 

party an opportunity to move for a protective order preventing or limiting 

such disclosure; 

any authors or recipients of the Confidential Information or a custodian; 

the Court, court personnel, and court reporters; and 

witnesses (other than persons described in Paragraph 4(e)). A witness shall 

sign the Certification before being shown a confidential document. 

Confidential Information may be disclosed to a witness who will not sign 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIVS33328
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the Certification only in a deposition at which the party who designated 

the Confidential Information is represented or has been given notice that 

Confidential Information produced by the party may be used. At the 

request of any party, the portion of the deposition transcript involving the 

Confidential Information shall be designated “Confidential” pursuant to 

Paragraph 2 above. Witnesses shown Confidential Infonnation shall not be 

allowed to retain copies. 

5. Except with the prior written consent of the other parties, or upon prior order of 

this Court obtained after notice to opposing counsel, Highly Confidential Information shall be 

treated in the same manner as Confidential Information pursuant to Paragraph 4 above, except 

that it shall not be disclosed to individual parties or directors, officers or employees of a party, or 

to witnesses (other than persons described in Paragraph 4(a) or 4(e)). 

6. Any persons receiving Confidential Information or Highly Confidential 

Information shall not reveal or discuss such information to or with any person who is not entitled 

to receive such information, except as set forth herein. If a party or any of its representatives, 

including counsel, inadvertently discloses any Confidential Information or Highly Confidential 

Information to persons who are not authorized to use or possess such material, the party shall 

provide immediate written notice of the disclosure to the party whose material was inadvertently 

disclosed. If a party has actual knowledge that Confidential Information or Highly Confidential 

Information is being used or possessed by a person not authorized to use or possess that material, 

regardless of how the material was disclosed or obtained by such person, the party shall provide 

immediate written notice of the unauthorized use or possession to the party whose material is 

being used or possessed. No party shall have an affirmative obligation to inform itself regarding 

such possible use or possession. 

7. In connection with discovery proceedings as to which a party submits Confidential 

Information or Highly Confidential Information, all documents and chamber copies containing 

Confidential Information or Highly Confidential Information which are submitted to the Court 

shall be filed with the Court in sealed enveIOpes or other appropriate sealed containers. On the 

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STH’ULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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outside of the envelopes, a copy of the first page of the document shall be attached. If 

Confidential Information or Highly Confidential Information is included in the first page attached 

to the outside of the envelopes, it may be deleted from the outside copy. The word 

“CONFIDENTIAL” shall be stamped on the envelope and a statement substantially in the 

following form shall also be printed on the envelope: 

“This envelope is sealed pursuant to Order of the Court, contains Confidential 

Information and is not to be opened or the contents revealed, except by Order of the 

Court or agreement by the parties.” 

8. A party may designate as Confidential Information or Highly Confidential 

Information documents or discovery materials produced by a non-party by providing written 

notice to all parties of the relevant document numbers or other identification within thirty (30) 

days after receiving such documents or discovery materials. Until the thirty (30) day period for 

designation has lapsed, any documents or discovery materials produced by a non-party shall be 

treated at Confidential Information. Any party or non-party may voluntarily disclose to others 

without restriction any information designated by that party or nonparty as Confidential 

Information or Highly Confidential Information, although a document may lose its confidential 

status if it is made public. If a party produces materials designated Confidential Information or 

Highly Confidential Information in compliance with this Order, that production shall be deemed 

to have been made consistent with any confidentiality or privacy requirements mandated by local, 

state or federal laws. 

9. If a party contends that any material is not entitled to confidential treatment, such 

partymay at any time give written notice to the party or non-party who designated the material. 

The party or non-party who designated the material shall have twenty (20) days from the receipt 

of such written notice to apply to the Court for an order designating the material as confidential. 

The party or non-party seeking the order has the burden of establishing that the document is 

entitled to protection. 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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10. Notwithstanding any challenge to the designation of material as Confidential 

Information or Highly Confidential Information, all documents shall be treated as such and shall 

be subject to the provisions hereof unless and until one of the following occurs: 

(a) the party or non-party who claims that the material is Confidential 

Information or Highly Confidential Information withdraws such 

designation in writing; or 

(b) the party or non-party who claims that the material is Confidential 

Information or Highly Confidential Information fails to apply to the Court 

for an order designating the material confidential within the time period 

specified above after receipt of a written challenge to such designation; or 

(c) the Court rules the material is not Confidential Information or Highly 

Confidential Information. 

11. All provisions of this Order restricting the communication or use of Confidential 

Information or Highly Confidential Information shall continue to be binding after the conclusion 

of this action, unless otherwise agreed or ordered. Upon conclusion of the litigation, a party in the 

possession of Confidential Information or Highly Confidential Information shall within sixty (60) 

days either (a) return such documents to counsel for the party or non-party who provided such 

information, or (b) destroy such documents. Whether the Confidential Information or Highly 

Confidential Information is retumed or destroyed, the receiving party must submit a written 

certification to the producing party (and, if not the same person or entity, to the designating party) 

by the 60 day deadline that (1) all the Confidential Information or Highly Confidential 

Information that was returned or destroyed, and (2) affirms that the receiving party has not 

retained any copies, abstracts, compilations, summaries or any other format reproducing or 

capturing any of the Confidential Information or Highly Confidential Information. 

Notwithstanding this provision, counsel are entitled to retain an archival copy of all pleadings, 

motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, 

deposition and trial exhibits, expert reports, attorney work product, and consultant and expert 

work product, even if such materials contain Confidential Information or Highly Confidential 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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Information. Any such archival copies that contain or constitute Confidential Information or 

.Highly Confidential Information remain subject to this Stipulated Protective Order. The 

conclusion of the litigation shall be deemed to be the later of (l) 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. After the conclusion of this action, this Court will retainjurisdiction to enforce 

the terms of this Order. 

12. Nothing herein shall be deemed to waive any applicable privilege or work product 

protection, or to affect the ability of a party to seek relief for an inadvertent disclosure of material 

protected by privilege or work product protection. Any witness or other person, firm or entity 

from which discovery is sought may be informed of and may obtain the protection of this Order 

by written advice to the parties’ respective counsel or by oral advice at the time of any deposition 

or similar proceeding. 

13. In the event that any Confidential Information or Highly Confidential Information 

is inadvertently produced without such designation, the party or non—party that inadvertently 

produced the information without designation shall give written notice of such inadvertent 

production promptly after the party or non-party discovers the inadvertent failure to designate 

(but no later than fourteen (14) calendar days after the party or non-party discovers the 

inadvertent failure to designate), together with a further copy of the subject information 

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” (the “Inadvertent Production 

Notice”). Upon receipt of such Inadvertent Production Notice, the party that received the 

information that was inadvertently produced without designation shall promptly destroy the 

inadvertently produced information and all copies thereof, or, at the expense of the producing 

party or non-party, return such together with all copies of such information to counsel for the 

producing party and shall retain only the newly-produced versions of that information that are 

designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” This provision is not 

intended to apply to any inadvertent production of any information or materials protected by 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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attorney-client or work product privileges, which inadvertent production is governed by Section 

14 below. 

14. In the event that any party or non-party inadvertently produces information that is 

privileged or otherwise protected from disclosure during the discovery process (“Inadvertent 

Production Material”), the following shall apply: 

(a) Such inadvertent production or disclosure shall in no way prejudice or 

otherwise constitute a waiver of, or estoppel as to, any claim of attorney-client privilege, attorney 

work product protection, or other applicable protection in this case or any other federal or state 

proceeding, provided that the producing party shall notify the receiving party in writing of such 

protection or privilege promptly after the producing party discovers such materials have been 

inadvertently produced. 

(b) If a claim of inadvertent production is made, pursuant to this Stipulated 

Protective Order, with respect to discovery material then in the custody of another party, that 

party shall: (i) refrain from any further examination or disclosure of the claimed Inadvertent 

Production Material; (ii) promptly make a good-faith effort to return the claimed Inadvertent 

Production Material and all copies thereof (including summaries and excerpts) to counsel for the 

producing party, or destroy all such claimed Inadvertent Production Material (including 

summaries and excerpts) and certify in writing to that fact; and (iii) not disclose or use the 

claimed Inadvertent Production Material for any purpose until further order of the Cou1t expressly 

authorizing such use. 

(c) A party may move the Court for an order compelling production of the 

Inadvertent Production Material on the ground that it is not, in fact, privileged or protected. The 

motion shall be filed under seal and shall not assert as a ground for entering such an order the fact 

or circumstance of the inadvertent production. The producing party retains the burden of 

establishing the privileged or protected nature of any inadvertently disclosed or produced 

information. While such a motion is pending, the Inadvertent Production Material at issue shall 

be treated in accordance with Paragraph 14(b) above. 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

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(d) If a party, in reviewing discovery material it has received from any other 

party or any non-party, finds anything the reviewing party believes in good faith may be 

Inadvertent Production Material, the reviewing party shall: (i) refrain from any further 

examination or disclosure of the potentially Inadvertent Production Material; (ii) promptly 

identify the material in question to the producing party (by document number or other equally 

precise description); and (iii) give the producing party seven (7) days to respond as to whether the 

producing party will make a claim of inadvertent production. If the producing party makes such a 

claim, the provisions of Paragraphs 14(a)-(c) above shall apply. 

15. The parties agree that should the production of source code become necessary, 

they will need to amend or supplement the terms of this Order. To the extent production of 

source code becomes necessary in this case, the parties will work expeditiously to propose 

amendments to this Order to cover any production of source code. 

16. If a party is served with a subpoena or a court order issued in other litigation that 

compels disclosure of any Confidential Information or Highly Confidential Information, the 

receiving party must: 

(a) promptly notify in writing the designating party. Such notification shall 

include a copy of the subpoena or court order; 

(b) promptly notify in writing the paity 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 Stipulated Protective Order. Such notification shall include a copy of this 

Stipulated Protective Order; and 

(c) cooperate with respect to all reasonable procedures sought to be pursued by 

the designating party whose Confidential Information or Highly Confidential Information may be 

affected. 

If the designating party timely seeks a protective order, the party served with the subpoena 

or court order shall not produce any Confidential Information or Highly Confidential Information 

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 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

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expense of seeking protection in that court of its c0nfidential 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. 

17. The following additional terms apply to non-party discovery material: 

(a) The terms of this Order are applicable to information produced by a nonparty in this action and designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” 

Such information produced by non-parties in connection with this litigation is protected by the 

remedies and relief provided by this Order. Nothing in these provisions should be construed as 

prohibiting a non—party from seeking additional protections. 

(b) 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, then the 

party shall: 

i. promptly notify in writing the requesting party and the non-party 

that some or all of the information requested is subject to a confidentiality agreement with a nonparty; 

ii. promptly provide the non-patty with a copy of the Stipulated 

Protective Order in this litigation, the relevant discovery request(s), and a reasonably specific 

description of the information requested; and 

iii. make the information requested available for inspection by the nonparty. 

(c) If the non-party fails to object or seek a protective order from this Court 

within 28 days of receiving the notice and accompanying information, the receiving party may 

produce the non-party’s confidential information responsive to the discovery request. If the nonparty timely seeks a protective order, the receiving party shall not produce any information in its 

possession or control that is subject to the confidentiality agreement with the non—party before a 

determination by the Court. Absent a court order to the contrary, the non-party shall bear the 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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burden and expense of seeking protection in this Court of its Confidential Information or Highly 

Confidential Information. 

18. Nothing in this Stipulated Protective Order shall be construed to preclude any 

party from asserting in good faith that certain Confidential Information or Highly Confidential 

Information requires additional protections. The parties shall meet and confer to agree upon the 

terms of such additional protection. By stipulating to the entry of this Protective Order no party 

waives any right it otherwise would have to object to disclosing or producing any information or 

item on any ground not addressed in this Stipulated Protective Order. Similarly, no party waives 

any right to object on any ground to use in evidence of any of the material covered by this 

Stipulated Protective Order. Nothing in this Stipulated Protective Order abridges the right of any 

person to seek its modification by the Court in the future. 

Part Two: Use of Confidential Materials in Court 

The following provisions govern the treatment of Confidential Information or Highly 

Confidential Information used at trial or submitted as a basis for adjudication of matters other 

than discovery motions or proceedings. These provisions are subject to Rules 2.550, 2.551, 2.580, 

2.585, 8.160, and 8.490 of the Califomia Rules of Court and must be construed in light of those 

Rules. 

19. A party that files with the Court, or seeks to use at trial, materials designated as 

Confidential Information or Highly Confidential Information, and who seeks to have the record 

containing such information sealed, shall submit to the Court a motion or an application to seal, 

pursuant to California Rule of Court 2.551. 

20. A party that files with the Court, or seeks to use at trial, materials designated as 

Confidential Information or Highly Confidential Information by anyone other than itself, and who 

does not seek to have the record containing such information sealed, shall comply with either of 

the following requirements: 

(a) At least ten (10) business days prior to the filing or use of the Confidential 

Information or Highly Confidential Information, the submitting party shall 

give notice to all other parties, and to any non-party that designated the 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
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21. 

(b) 

materials as Confidential Information or Highly Confidential Information 

pursuant to this Order, of the submitting party’s intention to file or use the 

Confidential Information or Highly Confidential Information, including 

specific identification of the Confidential Information or Highly 

Confidential Information. Any affected party or non-party may then file a 

motion to seal, pursuant to California Rule of Court 2.551(b); or 

At the time of filing or desiring to use the Confidential Information or 

Highly Confidential Information, the submitting party shall submit the 

materials pursuant to the lodging-under-seal provision of California Rule of 

Court 2.551(d). Any affected party or non-party may then file a motion to 

seal, pursuant to the California Rule of Court 2.551(b), within ten (10) 

business days after such lodging. Documents lodged pursuant to California 

Rule of Court 2.551(d) shall bear a legend stating that such materials shall 

be unsealed upon expiration of ten (10) business days, absent the filing of a 

motion to seal pursuant to Rule 2.551(b) or Court order. 

In connection with a request to have materials sealed pursuant to Paragraph 12 or 

Paragraph 13, the requesting party’s declaration pursuant to California Rule of Court 2.55 1(b)( 1) 

shall contain sufficient particularity with respect to the particular Confidential Information or 

Highly Confidential Information and the basis for scaling to enable the Court to make the findings 

required by California Rule of Court 2.550(d). 

IT IS SO STIPULATED. 

DATED: , 2016 

PERKINS COIE LLP 

By: 

Julie E. Schwartz 

Attorneys for Defendant 

Facebook, Inc. 

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STTPIILIXIHEI)[Id{()P()Sli[fl PIKCYFE(III\/EE()RI)EI{ 

CASE NO. CIV533328
N 

WVONM-h-w 

DATED: , 2016 BIRNBAUM & GODKIN, LLP 

By: 

David Godkin 

Attorneys for Plaintiff 

SIX4THREE, LLC 

IT IS SO ORDERED. 

DATED: ”[517 ,2016 am C. (<rw1\ 

JUREFE OF THE SUPERIOR COURT 

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STIPULATED [PROPOSED] PROTECTIVE ORDER 

CASE NO. CIV533328
CERTIFICATION 

I hereby certify my understanding that Confidential Information or Highly Confidential 

Information is being provided to me pursuant to the terms and restrictions of the Stipulation and 

Protective Order Regarding Confidential Information filed on , 2016, in 

Six4Three, LLC v. Facebook, Inc., San Mateo County Superior Court Case No. CIV533328 

(“Order”). I have been given a copy of that Order and read it. 

I agree to be bound by the Order and I understand and acknowledge that failure to so 

comply could expose me to sanctions and punishment in the nature of contempt. I will not reveal 

the Confidential Information or Highly Confidential Information to anyone, except as allowed by 

the Order. I will maintain all such Confidential Information or Highly Confidential Information, 

including copies, notes, or other transcriptions made therefrom, in a secure manner to prevent 

unauthorized access to it. No later than thirty (30) days after the conclusion of this action, I will 

return the Confidential Information or Highly Confidential Information, including copies, notes, 

or other transcriptions made therefrom, to the counsel who provided me with the Confidential 

Information or Highly Confidential Information. I hereby consent to thejurisdiction of the San 

Mateo County Superior Court for the purpose of enforcing the Order, even if such enforcement 

proceedings occur aftertermination of this action. 

I hereby appoint located at the address of 

as my California agent for service of process in 

connection with this action or any proceedings related to enforcement of this Stipulated Protective 

Order. 

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

certificate is executed this _ day of , 2016, at 

By: 

Address: 

Phone: 

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STIPULATED [PROPOSED] PROTECTIVE ORDER

CASE NO. CIV533328

CERTIFICATION

I hereby certify my understanding that Confidential Information or Highly Confidential 

Information is being provided to me pursuant to the terms and restrictions of the Stipulation and 

Protective Order Regarding Confidential Information filed on _______________, 2016, in 

Six4Three, LLC v. Facebook, Inc., San Mateo County Superior Court Case No. CIV533328

(“Order”). I have been given a copy of that Order and read it.

I agree to be bound by the Order and I understand and acknowledge that failure to so 

comply could expose me to sanctions and punishment in the nature of contempt. I will not reveal 

the Confidential Information or Highly Confidential Information to anyone, except as allowed by 

the Order. I will maintain all such Confidential Information or Highly Confidential Information, 

including copies, notes, or other transcriptions made therefrom, in a secure manner to prevent 

unauthorized access to it. No later than thirty (30) days after the conclusion of this action, I will 

return the Confidential Information or Highly Confidential Information, including copies, notes,

or other transcriptions made therefrom, to the counsel who provided me with the Confidential

Information or Highly Confidential Information. I hereby consent to the jurisdiction of the San 

Mateo County Superior Court for the purpose of enforcing the Order, even if such enforcement 

proceedings occur after termination of this action.

I hereby appoint _____________________________________ located at the address of 

______________________________________ as my California agent for service of process in 

connection with this action or any proceedings related to enforcement of this Stipulated Protective 

Order. 

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

certificate is executed this ___ day of ______________, 2016, at ________________________.

By: ________________________________

Address: ____________________________

____________________________

Phone: _____________________________

October 25

____________________________

____________________________

____________________________

____________________________

Basil P. Fthenakis

2225 E. Bayshore Road, Suite 200, Palo Alto

1st December 9:00AM

51 Melcher Street, 7th Floor

Boston, MA 02210

(617) 532 - 0992