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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

RAVENWHITE LICENSING LLC,

 Plaintiff,

v.

THE HOME DEPOT, INC. et al.,

 Defendants.

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CIVIL ACTION NO. 2:23-CV-423-JRG-RSP

(Lead Case)

PROTECTIVE ORDER 

WHEREAS, Plaintiff RavenWhite Licensing, LLC and Defendants The Home Depot, Inc., 

Home Depot USA, Inc., Walmart Inc., and Wal-Mart Stores Texas, 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;

WHEREAS, thePartiesseek a protective orderlimiting disclosure thereofin accordancewith 

Federal Rule of Civil Procedure 26(c):

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

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

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

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

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

document, information or material (“Protected Material”). Protected Material shall be

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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 native files and 

deposition and hearing transcripts) for which such protection is sought. For native files, the 

word “CONFIDENTIAL” shall be included in the file name of the designated native files 

or in the slip sheet associated with the native file in the party’s production. For deposition 

and hearing transcripts, the word “CONFIDENTIAL” 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 “CONFIDENTIAL.”

2. Any document produced under Patent Rules 2-2, 3-2, and/or 3-4 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 isredesignated 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 

SOURCE CODE” (“DESIGNATED MATERIAL”),1 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

1 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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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 

DESIGNATEDMATERIALmay request destruction ofthatProtectedMaterial bynotifying 

the recipient(s), as soon as reasonably possible after the producing Party becomes aware of 

the inadvertent or unintentional disclosure, and providing replacement Protected Material 

that is properly designated. The recipient(s)shall then destroy all copies of the inadvertently 

or unintentionally produced Protected Materials and any documents, information 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 12 herein:

(a) outside counsel of record in this Action for the Parties;

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

counsel in the litigation of this Action;

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

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

counsel in the litigation of this Action;

(d) up to and including three 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;

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

an affiliate of a Party) retained for the purpose of this litigation and who are not 

presently employed by the Parties hereto for purposes other than this Action, 

provided that at least ten (10) days before access to the Protected Material is to be 

given to that consultant or expert, the Party seeking such disclosure must serve to 

the producing Party: (1) the full name of the consultant or expert and the city and 

state of his or her primary residence, a copy of the (2) a current curriculum vitae of 

the consultant or expert, (3) the consultant or expert’s current employer, (4) a list 

of each person or entity from whom the consultant or expert has received 

compensation or funding for work in his or her areas of expertise or to whom the 

consultant or expert has provided professional services (including in connection 

with litigation) at any time during the preceding five years,2 and (5) a list of all 

other cases in which, during the previous four years, the consultant or expert has 

testified as an expert at trial or by deposition, and (6) a copy of the Undertaking 

attached as Exhibit A hereto executed by the consultant or expert. The producing 

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

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

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

any objection, the objecting Party may file a motion with the Court within fifteen

(15) days of the notice, or within such other time as the Parties may agree,seeking a 

protective order with respect to the proposed disclosure. The objecting Party shall 

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

until all such objections are resolved by agreement or Court order;

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

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

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

2 If the consultant or expert believes any of thisinformation issubject to a confidentiality obligation 

to a third-party, then the consultant or expert should provide whatever information he or she 

believes can be disclosed without violating any confidentiality agreements, and the Party seeking 

to disclose to the consultant or expert shall be available to meet and confer with the producing 

Party regarding any such engagement.

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reasonably necessary to assist counsel with the litigation of this Action; and

(g) the Court and its personnel;

(h) mock jurors who have signed an undertaking or agreement agreeing not to publicly 

disclose Protected Material or keep any information concerning Protected Material 

confidential; and

(i) any mediator who is assigned to hear this matter, and his or her staff, subject to 

their agreement to maintain confidentiality to the same degree as required by this 

Order.

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 believesit owes an obligation of confidentiality with respect to such documents, 

information or material.

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

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

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

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

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

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

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

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

DESIGNATED MATERIALS and subject to all of the terms and conditions of thisOrder.

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 -

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

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

as “RESTRICTED 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-c) and (e-i); provided, however, that access by in-house counsel pursuant to 

paragraph 5(c) be limited to in-house counsel who exercise no competitive decision-making 

authority on behalf of the client.

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

following additional restrictions apply in addition to the restrictions set forth in paragraph 

9 for Protected Material designated “RESTRICTED – ATTORNEYS’ EYES ONLY”:

(a) Access to a Party’s Source Code shall be provided only on a “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). The stand-alone computer may 

be connected to (i) a printer, or (ii) a device capable of temporarily storing 

electronic copies solely for the limited purposes permitted pursuant to paragraphs 

10 (h and k) below. Additionally, except as provided in paragraph 10(k) below, the 

stand-alone computer may only be located at the offices of the producing Party’s 

outside counsel.

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

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

of this paragraph shall be 9:00 a.m. through 5:00 p.m local time. 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 

stand-alone computer(s) outside of normal business hours. The Parties agree to 

cooperate in good faith such that maintaining the producing Party’s Source Code 

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.

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

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

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

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

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

(e) Access to each producing Party’s Protected Material designated RESTRICTED 

CONFIDENTIAL - SOURCE CODE shall be limited to outside counsel and up to 

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

Party or an affiliate of a Party) retained for the purpose of this litigation and 

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

receiving Party may include excerpts of Source Code in a pleading, exhibit, expert 

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

that the Source Code Documents are appropriately marked under this Order, 

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

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

procedures, and orders. The producing Party will provide a stand-alone computer 

that does not contain Source Code for the purpose of typing notes and a dedicated 

printer connected to said stand-alone notetaking computer. Each person authorized 

to access Source Code may use the stand-alone notetaking computer for the 

purpose of typing notes related to source code review using an application such as 

“Notepad,” provided that said notes do not comprise copying of lines of 

code. Such notes can be printed upon request and will not count against the page 

limits described herein. During review of Source Code, the receiving Party 

(including its Experts) shall also be entitled to take handwritten notes relating to 

the Source Code but may not copy any lines of the Source Code into the notes. 

Any such handwritten notes shall be taken in a bound notebook.

(f) To the extent portions of Source Code are quoted in a 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 will be separately stamped and treated as RESTRICTED 

CONFIDENTIAL SOURCE CODE.

(g) Except as set forth in paragraph 10(k) below, no electronic copies of Source Code 

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 orserved electronically or except as otherwise provided herein.

(h) The receiving Party shall be permitted to print a reasonable number of pages of 

Source Code, from which the receiving Party may make a reasonable number of 

photocopies, which shall presumptively be a total of five (5). All printouts shall be 

designated and clearly labeled “RESTRICTED CONFIDENTIAL SOURCE

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

the outside consultant’s or expert’s direct reports and other support personnel, such that the 

disclosure to a consultant or expert who employs others within his or her firm to help in his or her 

analysis shall count as a disclosure to a single consultant or expert.

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CODE.” The receiving Party shall maintain a log of all such files that are printed 

or photocopied. Any party may later move to modify this limitation for good cause.

(i) 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;

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

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

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

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

receiving Party may also temporarily keep the printouts or photocopies at: (i) the 

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

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

Code are taken, for the dates associated with the deposition(s); and (iii) any 

intermediate location reasonably necessary to transport the printouts or photocopies 

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

(k) A producing Party’s Source Code may only be transported by the receiving Party at 

the direction of a person authorized under paragraph 10(e) above to another person 

authorized under paragraph 10(e) above, on paper or removable electronic media 

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

or other similarly reliable courier. Source Code may not be transported or 

transmitted electronically over a network of any kind, including a LAN, an 

intranet, or the Internet. Source Code may only be transported electronically for 

the purpose of Court proceeding(s), deposition(s), or expert report preparation as 

set forth in paragraph 10(j) above and is at all times subject to the transport 

restrictions set forth herein. But, for those purposes only, the Source Code may be 

loaded onto a stand-alone computer.

11. 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 RESTRICTED - ATTORNEYS’ EYES ONLY and/or RESTRICTED 

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

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two years after its conclusion, including any appeals. This provision shall not prevent 

participating or assisting in inter partes review, reissue, and reexamination proceedings of 

any patents, including the patents-in-suit, provided that such participation or assistance 

shall not, directly or indirectly, include suggesting, proposing for substitution, drafting, or 

amending patent claim language.

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

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

product doctrine, or other privilege, doctrine, or immunity. The parties agree that Federal 

Rule of Civil Procedure 26(b)(5)(B) governs the situation in which information produced 

in discovery is subject to a claim of privilege or of protection as trial-preparation material.

13. 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.

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

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

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

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

designating party,(ii)identified in theDESIGNATEDMATERIALas an author, addressee, 

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

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

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

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

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a company affiliated with the producing Party; (v) a 30(b)(6) witness of the producing 

Party; (vi) counsel for a Party, including outside counsel and in-house counsel (subject to 

paragraph 9 of this Order); (vii) an independent contractor, consultant, and/or expert 

retained for the purpose of this litigation; (viii) court reporters and videographers; (ix) the 

Court; or (x) other persons entitled hereunder to access to DESIGNATED MATERIAL. 

DESIGNATED MATERIAL shall not be disclosed to any other persons unless prior 

authorization is obtained from counsel representing the producing Party or from the Court.

15. 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. Accessto 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 hearing 

transcript shall be treated as “RESTRICTED - ATTORNEYS’ EYES ONLY,” unless 

otherwise designated by the Parties.

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

shall remain underseal 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

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exhibit filed publicly with the Court.

17. 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.

18. 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 

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.

19. 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.

20. 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 contended the discovery sought

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

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

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

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

“RESTRICTED CONFIDENTIAL SOURCE CODE” any documents, information or 

other material, in whole or in part, produced or give by such documents, information or 

other material, in whole or in part, produced or give by such Third Parties. The Third 

Parties shall have ten (10) days after production of such documents, information or other 

materials to make such a designation. Until that time period lapses or until such a 

designation has been made, whichever occurs sooner, all documents, information or other 

material so produced or given shall be treated as “CONFIDENTIAL” in accordance with 

this Order.

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

DESIGNATEDMATERIAL,includingallcopies,duplicates,abstracts,indexes,summaries, 

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

into any privileged memoranda of the Parties and 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.

23. 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

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

thereof, all such objections being hereby preserved.

24. 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.

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

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

26. 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.

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

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

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

protection of DESIGNATED MATERIAL.

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

RAVENWHITE LICENSING LLC,

 Plaintiff,

v.

THE HOME DEPOT, INC. et al.,

 Defendants.

§

§

§

§

§

§

§

§

§

CIVIL ACTION NO. 2:23-CV-423-JRG-RSP

(Lead Case)

APPENDIX A

UNDERTAKING OF EXPERTS OR CONSULTANTS REGARDING 

PROTECTIVE ORDER

I, , declare that:

1. My address is .

My current employer is . 

My current occupation is .

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

understand the provisions of the Protective Order.

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

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

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

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

SOURCE CODE” that is disclosed to me.

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

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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

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