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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

for the

 

)

)

)

)

)

)

Plaintiff

v. Civil Action No.

Defendant

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS

OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION 

To:

(Name of person to whom this subpoena is directed)

Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following 

documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the

material:

Place: Date and Time:

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or 

other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party

may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

Place: Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached  Rule 45(c), relating to the place of compliance;

Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to

respond to this subpoena and the potential consequences of not doing so.

Date:

CLERK OF COURT

OR

Signature of Clerk or Deputy Clerk Attorneys signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)

, who issues or requests this subpoena, are:

Notice to the person who issues or requests this subpoena

If this subpoena commands the production of documents, electronically stored information, or tangible things or the

inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before

it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

 Eastern District of Texas

SIGNODE INDUSTRIAL GROUP LLC,

2:24-cv-00080-JRG

SAMUEL, SON & CO., LTD and SAMUEL, SON &

CO. (USA) INC

DIMONTE GROUP, INC.

c/o Foley & Lardner LLP

See Attachment A

K&L Gates LLP

70 W Madison St, Suite 3300

Chicago, IL 60602 10/09/2024 5:00 pm

/s/ Nathan Fuller

Signode Industrial Group LLC

Nathan Fuller, K&L Gates LLP, 70 W Madison St, Suite 3300, Chicago, IL 60602; nathan.fuller@klgates.com

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any)

on (date) .

I served the subpoena by delivering a copy to the named person as follows:

on (date) ; or

I returned the subpoena unexecuted because:

.

Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also 

tendered to the witness the fees for one days attendance, and the mileage allowed by law, in the amount of

$ .

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:

Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc.:

2:24-cv-00080-JRG

0.00

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AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)

(c) Place of Compliance.

 (1) For a Trial, Hearing, or Deposition. A subpoena may command a

person to attend a trial, hearing, or deposition only as follows:

 (A) within 100 miles of where the person resides, is employed, or

regularly transacts business in person; or

 (B) within the state where the person resides, is employed, or regularly

transacts business in person, if the person

 (i) is a party or a partys officer; or

 (ii) is commanded to attend a trial and would not incur substantial

expense.

 (2) For Other Discovery. A subpoena may command:

 (A) production of documents, electronically stored information, or

tangible things at a place within 100 miles of where the person resides, is

employed, or regularly transacts business in person; and

 (B) inspection of premises at the premises to be inspected.

(d) Protecting a Person Subject to a Subpoena; Enforcement.

 (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney

responsible for issuing and serving a subpoena must take reasonable steps

to avoid imposing undue burden or expense on a person subject to the

subpoena. The court for the district where compliance is required must

enforce this duty and impose an appropriate sanctionwhich may include

lost earnings and reasonable attorneys feeson a party or attorney who

fails to comply.

 (2) Command to Produce Materials or Permit Inspection.

(A) Appearance Not Required. A person commanded to produce

documents, electronically stored information, or tangible things, or to

permit the inspection of premises, need not appear in person at the place of

production or inspection unless also commanded to appear for a deposition,

hearing, or trial.

(B) Objections. A person commanded to produce documents or tangible

things or to permit inspection may serve on the party or attorney designated

in the subpoena a written objection to inspecting, copying, testing, or

sampling any or all of the materials or to inspecting the premisesor to

producing electronically stored information in the form or forms requested.

The objection must be served before the earlier of the time specified for

compliance or 14 days after the subpoena is served. If an objection is made,

the following rules apply:

(i) At any time, on notice to the commanded person, the serving party

may move the court for the district where compliance is required for an

order compelling production or inspection.

 (ii) These acts may be required only as directed in the order, and the

order must protect a person who is neither a party nor a partys officer from

significant expense resulting from compliance.

 (3) Quashing or Modifying a Subpoena.

(A) When Required. On timely motion, the court for the district where

compliance is required must quash or modify a subpoena that:

 (i) fails to allow a reasonable time to comply;

(ii) requires a person to comply beyond the geographical limits

specified in Rule 45(c);

(iii) requires disclosure of privileged or other protected matter, if no

exception or waiver applies; or

(iv) subjects a person to undue burden.

(B) When Permitted. To protect a person subject to or affected by a

subpoena, the court for the district where compliance is required may, on

motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research,

development, or commercial information; or

(ii) disclosing an unretained experts opinion or information that does

not describe specific occurrences in dispute and results from the experts

study that was not requested by a party.

(C) Specifying Conditions as an Alternative. In the circumstances

described in Rule 45(d)(3)(B), the court may, instead of quashing or

modifying a subpoena, order appearance or production under specified

conditions if the serving party:

(i) shows a substantial need for the testimony or material that cannot be

otherwise met without undue hardship; and

(ii) ensures that the subpoenaed person will be reasonably compensated.

(e) Duties in Responding to a Subpoena.

 (1) Producing Documents or Electronically Stored Information. These

procedures apply to producing documents or electronically stored

information:

(A) Documents. A person responding to a subpoena to produce documents

must produce them as they are kept in the ordinary course of business or

must organize and label them to correspond to the categories in the demand.

(B) Form for Producing Electronically Stored Information Not Specified.

If a subpoena does not specify a form for producing electronically stored

information, the person responding must produce it in a form or forms in

which it is ordinarily maintained or in a reasonably usable form or forms.

(C) Electronically Stored Information Produced in Only One Form. The

person responding need not produce the same electronically stored

information in more than one form.

(D) Inaccessible Electronically Stored Information. The person

responding need not provide discovery of electronically stored information

from sources that the person identifies as not reasonably accessible because

of undue burden or cost. On motion to compel discovery or for a protective

order, the person responding must show that the information is not

reasonably accessible because of undue burden or cost. If that showing is

made, the court may nonetheless order discovery from such sources if the

requesting party shows good cause, considering the limitations of Rule

26(b)(2)(C). The court may specify conditions for the discovery.

(2) Claiming Privilege or Protection.

(A) Information Withheld. A person withholding subpoenaed information

under a claim that it is privileged or subject to protection as trial-preparation

material must:

(i) expressly make the claim; and

(ii) describe the nature of the withheld documents, communications, or

tangible things in a manner that, without revealing information itself

privileged or protected, will enable the parties to assess the claim.

(B) Information Produced. If information produced in response to a

subpoena is subject to a claim of privilege or of protection as

trial-preparation material, the person making the claim may notify any party

that received the information of the claim and the basis for it. After being

notified, a party must promptly return, sequester, or destroy the specified

information and any copies it has; must not use or disclose the information

until the claim is resolved; must take reasonable steps to retrieve the

information if the party disclosed it before being notified; and may promptly

present the information under seal to the court for the district where

compliance is required for a determination of the claim. The person who

produced the information must preserve the information until the claim is

resolved.

(g) Contempt.

The court for the district where compliance is requiredand also, after a

motion is transferred, the issuing courtmay hold in contempt a person

who, having been served, fails without adequate excuse to obey the

subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

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ATTACHMENT A 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 5 of 31 PageID #: 972
1 

ATTACHMENT A 

This subpoena and document request pertains to the matter of Signode Industrial Group 

LLC v. Samuel, Son & Co., Ltd. et al, Case No. 2:24-cv-00080-JRG (E.D. Tex.). 

The parties in this matter have entered into a Protective Order to prevent the disclosure of 

private or sensitive information. Documents produced by You pursuant to this Subpoena may be 

marked as subject to the applicable Protective Order, provided that they qualify for protection 

thereunder. A true and correct copy of the Protective Order in this matter is attached hereto as 

Attachment B for your review and consideration. 

The Document Requests seek DOCUMENTS and COMMUNICATIONS within YOUR 

possession, custody, and/or control. This includes, but is not limited to, any and all DOCUMENTS 

and COMMUNICATIONS contained on any of YOUR devices (INCLUDING laptop computers, 

desktop computers, iPads, cell phones, external drives, cloud accounts, etc.), as well as on any of 

Your electronic and/or cloud accounts (INCLUDING email, text messages, Slack, etc.). 

DEFINITIONS 

1. DiMonte Group or You means DiMonte Group, Inc. and its officers, directors, 

employees, representatives, consultants, agents, servants, attorneys, accountants, or any other 

person or entity acting on its behalf, or any person or entity that served in any such role any time, 

as well as corporate parents, subsidiaries, affiliates, divisions, predecessor companies or 

proprietorships. 

2. Signode means Plaintiff Signode Industrial Group LLC and its present and 

former directors, officers, employees, parent organization(s), subsidiary organization(s), 

predecessors in interest, successors in interest, divisions, servants, agents, attorneys, consultants, 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 6 of 31 PageID #: 973
2 

partners, associates, investigators, representatives, accountants, financial advisors, distributors, 

and any other person acting on its behalf, pursuant to its authority or subject to its control. 

3. Defendant or Samuel means Defendants Samuel, Son & Co., Ltd. and Samuel, 

Son & Co. (USA) Inc. d/b/a Samuel Packaging Systems Group and Samuel Strapping Systems 

and its present and former directors, officers, employees, parent organization(s), subsidiary 

organization(s), predecessors in interest, successors in interest, divisions, servants, agents, 

attorneys, consultants, partners, associates, investigators, representatives, accountants, financial 

advisors, distributors, and any other person acting on its behalf, pursuant to its authority or subject 

to its control. 

4. Case means the above-referenced litigation: Signode Industrial Group LLC v. 

Samuel, Son & Co., Ltd. et al, Case No. 2-24-cv-00080-JRG (E.D. Tex.). 

5. Asserted Patents means U.S. Patent Nos. 11,667,417; 11,667,418; and 

11,932,430. 

6. Person or persons include, without limitation, both natural persons and 

entities (including corporations, proprietorships, partnerships, associations, joint ventures, 

governmental agencies, and other entities, and any combination thereof, and all predecessors in 

interest, successors, affiliates, subsidiaries, and related entities). 

7. Document or documents include all things within the meaning and scope of 

that term as used in the Federal Rules of Civil Procedure and the Federal Rules of Evidence, 

including Federal Rule of Civil Procedure 34(a). 

8. Communication or communications mean every manner or method of the 

disclosure, transfer, transmission, or exchange of information, in whatever form, by whatever 

means, including, but not limited to, oral, written, face-to-face, telephone, facsimile, network 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 7 of 31 PageID #: 974
3 

transfer, electronic mail, smartphone messages, voice-mail, text messages, postal mail, personal 

delivery, or otherwise, at any time or place under any circumstances. The definition is not limited 

to transfers between persons but also includes other transfers, such as records and memoranda to 

file; any written letter, memorandum, or other document which was sent by one or more 

individuals to another or others; any telephone call between one or more individuals and another 

or others, whether such call was by chance or prearranged, formal or informal; and any 

conversation or meeting between one or more individuals and another, whether such contact was 

by chance or prearranged, formal or informal. This definition also includes all transcripts, 

summaries, electronic recordings, audio tapes and audio files constituting, reflecting or 

transcribing such communications. 

9. Thing or things shall be interpreted broadly and include, but not be limited to, 

products, parts, machines, equipment, prototypes, specimens, models, devices, apparatuses, and 

commercially manufactured items. 

10. Product or products mean a machine, manufacture, apparatus, device, 

instrument, mechanism, appliance, system, or assemblage of components/parts (either individually 

or collectively), which are designed to function together electrically, mechanically, chemically, or 

otherwise, to achieve a particular function or purpose, including those offered for sale, sold, or 

under development. 

11. And and or shall be construed conjunctively or disjunctively as necessary to 

make the requests inclusive rather than exclusive. 

12. Accused Products as used herein means the STL-500 Battery Operated Plastic 

Strapping Tool and products that operate in a similar manner, including, but not limited to the 

following STL-500 products: 143089 - STL-500 HAND TOOL BATTERY, 12MM STRAP - 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 8 of 31 PageID #: 975
4 

6PSTL50012 143090 - STL-500 HAND TOOL BATTERY, 16MM STRAP - 6PSTL50016 

143092 - STL-500 HAND TOOL BATTERY, 19MM STRAP - 6PSTL50019 177692 - STL-500 

HAND TOOL BATTERY, 16MM STRAP - 6PSTL50016(R). 

INSTRUCTIONS 

1. If You contend that any document which would otherwise be producible in 

response to any request may be withheld under the attorney-client privilege, the attorney-work 

doctrine, or any other basis, state the following with respect to each such document to explain the 

basis for the claim of privilege and to permit adjudication of the propriety of that claim: 

a. The privilege asserted and its basis; 

b. The nature of the document withheld (e.g. letter, memorandum, etc.); 

c. The title of the document; 

d. The date of the document; 

e. The identity of the author(s) of the document; 

f. The identity of each recipient of the document or any copy thereof; 

g. The length of the document; 

h. The location of the original and each copy of the document; 

i. The general subject matter of the document, including a statement of 

sufficient facts and circumstances to explain the basis of the claim privilege 

and which will permit adjudication of the prosperity of the claim of privilege; 

and 

j. The identity of each person, other than your attorneys of record, having 

knowledge of the factual basis asserted for the privilege. 

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2. If You object that a term or phrase in these requests is vague, ambiguous or 

indefinite, You are instructed to provide your understanding of the term or phrase, or what You 

believe to be a reasonable interpretation of the term or phrase, and respond in accordance with that 

understanding or interpretation. 

3. If You object that a request is overbroad or to any extent beyond the scope of 

discovery, You are instructed to explain the manner in and extent to which it is overbroad or 

beyond the scope of discovery, provide a proposed narrowed request that You agree is not 

overbroad or beyond the scope of discovery, and respond to Your narrowed request. 

4. If You object that a request is unduly burdensome, You are instructed to explain 

the manner in and extent to which it is unduly burdensome, provide a proposed narrowed request 

that You agree is not unduly burdensome, and respond to Your narrowed request. 

5. If You object to only a portion of a request, You are instructed to identify the 

objectionable portion and to respond and produce documents with respect to the remaining 

portions. 

6. If a request calls for a document or communication which has been destroyed, 

placed beyond Your possession, custody or control, or otherwise disposed of, set forth with respect 

to each such document or communication a brief, but complete, identification and description of 

the document or communication, including: (i) the identity of all individuals to whom the 

substance of the document or communication was transmitted, who saw such document or was 

part of such communication, or who otherwise know any of its contents, and under what 

circumstances; (ii) the present location of the document or communication, if not destroyed; and 

(iii) the name, title, home and business address, and home and business telephone number of the 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 10 of 31 PageID #: 977
6 

person(s) currently having possession, custody or control of the document or communication, if 

not destroyed. 

7. Any documents and communication produced for inspection should be produced as 

they are kept in the usual course of business or organized and labeled to correspond to the 

categories in the requests. Documents and communications from any single file should be 

produced in the same order as they were found in such file. 

8. In Your response to these requests, please restate the text of each request preceding 

Your response thereto. 

DOCUMENTS TO BE PRODUCED

1. All Documents, Things, and Communications between You and Samuel 

concerning battery operated plastic strapping tools, including, but not limited to, any Documents, 

Things, and Communications related to the Accused Products. 

2. All agreements between You and Samuel, including, but not limited to, all 

agreements reflecting any obligations of indemnity relating to the Accused Products, any 

agreement referencing and or referenced by such indemnity agreement relating to such obligations, 

and all agreements explaining Your obligation to support or assist in the defense against claims of 

patent infringement. 

3. All Documents, Things, and Communications reflecting any analysis, comparison, 

or testing that You conducted with respect to the Accused Products, including, but not limited to, 

(1) any analysis or comparison of the Asserted Products against the Accused Patents and (2) any 

analysis, comparison, or testing of the Asserted Products against any Signode products. 

4. All Documents, Things, and Communications evidencing any notice, advising, or 

awareness of any patents assigned to, owned by, and/or granted to Signode, including, but not 

Case 2:24-cv-00080-JRG Document 52-3 Filed 09/18/24 Page 11 of 31 PageID #: 978
7 

limited to, any Communications between You and Samuel related to any patents assigned to, 

owned by, and/or granted to Signode. 

5. All Documents, Things, and Communications concerning the market for battery 

operated plastic strapping tools, including, but not limited to, any Documents, Things, and 

Communications sufficient to identify Samuels competitors for battery operated plastic strapping 

tools. 

6. All Documents and Things concerning Your practice, policy, or procedure for the 

retention of documents and/or classes or categories of documents, including, but not limited to, email communications, spreadsheets, presentation materials, and word-processing materials. 

7. All documents and things concerning Your practice, policy, or procedure for 

evaluating and reviewing patents during the process of product design, including, but not limited 

to, any freedom-to-operate analysis. 

 

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ATTACHMENT B 

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1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

SIGNODE INDUSTRIAL GROUP LLC 

v. 

SAMUEL, SON & CO., LTD., et al. 

§ 

§ 

§ 

§ 

§ 

Case No. 2:24-CV-00 80-JRG 

PROTECTIVE ORDER

WHEREAS, Plaintiff Signode Industrial Group LLC (Signode or Plaintiff) and 

Defendants Samuel, Son & Co., Ltd. and Samuel, Son & Co. (USA) Inc. (collectively, Samuel or 

Defendants), hereafter referred to as the Parties, believe that certain information that is or will 

be encompassed by discovery demands by the Parties involves the production or disclosure of 

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

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 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

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

information or material as follows: CONFIDENTIAL or RESTRICTED -

ATTORNEYS EYES ONLY. The label CONFIDENTIAL or RESTRICTED -

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2 

ATTORNEYS EYES ONLY shall be placed clearly on each page of the Protected Material 

(except deposition and hearing transcripts and documents produced in native format) for 

which such protection is sought. For deposition and hearing transcripts, the label 

CONFIDENTIAL or RESTRICTED - ATTORNEYS EYES ONLY 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. For documents produced in native format (e.g., Excel spreadsheets), 

the filename may be amended to include one of the aforementioned labels instead of 

labeling each page of the natively-produced document. 

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 is redesignated to have a different 

classification under this Order. 

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

or RESTRICTED - ATTORNEYS EYES ONLY (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 Procedure; (b) all pretrial, hearing or deposition testimony, or 

documents marked as exhibits or for identification in depositions and hearings; (c) pretrial 

1

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

to the class of materials designated as CONFIDENTIAL or RESTRICTED - ATTORNEYS 

EYES ONLY, both individually and collectively. 

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3 

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 or RESTRICTED -

ATTORNEYS EYES ONLY ) may be made at any time. Inadvertent or unintentional 

production of documents, information or material that has not been designated as 

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

confidential treatment. Any party that inadvertently or unintentionally produces Protected 

Material without designating it as DESIGNATED MATERIAL may request destruction of 

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

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

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

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

and any documents, information 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; 

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

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

counsel in the litigation of this Action; 

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

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4 

extent reasonably necessary for the litigation of this Action, except that either party 

may in good faith request the other partys 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 subject to the 

provisions of paragraph 19 below; 

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

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

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

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

(g) 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; and 

(h) 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 

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 of such DESIGNATED MATERIAL or any 

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

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5 

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

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

8. For the avoidance of doubt, nothing in the foregoing paragraph 7 shall preclude any person 

or entity who obtains access to Protected Material or the contents thereof pursuant to this 

Order from submitting such Protected Material to a closed2 generative AI tool, provided 

that, before the receiving Party submits the designating Partys Protected Material to a 

closed generative AI tool, the receiving Party shall make reasonably sure that it can delete 

all produced information from the tool at the close of the Action. The receiving Party will 

be responsible for destroying such produced information from such tools at the close of the 

Action. Any material or information generated by a closed generative AI tool shall be 

considered Protected Material and shall receive the most restrictive designation as that of 

any Protected Material input into the closed generative AI tool. The receiving Party will be 

responsible for destroying any generated material or information from such tools at the 

close of the Action. 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. 

9. For Protected Material designated RESTRICTED -- ATTORNEYS EYES ONLY, access 

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

2

 A closed generative AI tool as used herein refers to a generative AI tool that uses input 

information solely for the purpose of generating the output information and the input and output 

information is only accessible to persons authorized to view the material under this Protective 

Order. For the avoidance of doubt, any generative AI tool that also uses input information for the 

purpose of training the generative AI tool is not a closed generative AI tool and not permitted 

under this Order. 

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paragraphs 5(a-b) and (e-h). In the event that a Party has a reasonable need to share 

Protected Material designated RESTRICTED  ATTORNEYS EYES ONLY with 

individuals listed in paragraph 5(c), the requesting Party shall identify with specificity the 

Protected Materials sought to be shared and the reasonable need therefore, and the parties 

shall meet and confer regarding such request. No disclosure of Protected Material 

designated RESTRICTED  ATTORNEYS EYES ONLY to individuals listed in 

paragraph 5(c), shall occur unless the Parties reach agreement or by Court order. 

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

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

designated RESTRICTED -- ATTORNEYS EYES ONLY (HIGHLY SENSITIVE 

MATERIAL), who obtains, receives, has access to, or otherwise learns, in whole or in 

part, the other Partys 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 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. 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, 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. For sake of 

clarity, any attorney representing a Party, whether in-house or outside counsel, and any 

person associated with a Party and permitted to receive another Partys HIGHLY 

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SENSITIVE MATERIAL, may participate, supervise, and assist in any and all postissuance proceedings before the U.S. Patent and Trademark Office as well as similar 

proceedings in jurisdictions outside the U.S., including without limitation Inter Partes

Review (IPR) proceedings, even if they have received the other Partys HIGHLY 

SENSITIVE MATERIAL, provided that they do not participate or assist in any claim 

drafting or amendment of claims in such proceedings (e.g., motion-to-amend practice in an 

IPR proceeding or claim amendments in a reexamination proceeding). 

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

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

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

other 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 promptly 

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

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

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

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. 

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12. Each party receiving such designated material shall comply with all applicable export 

control statutes and regulations. Nothing in this Order shall require the production of 

personally identifiable information (PII) that is protected or precluded from disclosure 

under the Federal Act on Data Protection (DPA), the General Data Protection Regulation 

(GDPR), or any other foreign or international law. Any such PII, as defined under 

applicable foreign or international law, shall be redacted from any documents and 

materials produced by a party without the need for the producing party to identify such PII 

in its privilege log. Any party that inadvertently or unintentionally produces documents, 

information or other material containing unredacted PII may obtain the return of such 

documents, information, or other material by promptly notifying the recipient(s). The 

recipient(s) shall gather and return all copies of such documents, information, or other 

material containing the unredacted PII to the producing Party, except for any pages 

containing properly redacted PII, which pages shall instead be destroyed and certified 

as such to the producing Party. The Parties agree, however, that this proceeding 

establishes a legal obligation to collect and produce documents and information that is 

subject to discovery in this litigation, including documents and information that may be 

located in foreign jurisdictions. No Party shall unreasonably withhold the names and any 

known past and/or current company name information of relevant witnesses located 

outside the U.S., and shall otherwise minimize withholding information to that strictly 

necessary to abide by legal restrictions associated with PII. 

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 

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material to protect against disclosure to any unauthorized persons or entities. 

14. Nothing contained herein shall be construed to prejudice any Partys 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 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 persons entitled hereunder to 

access to DESIGNATED MATERIAL. For avoidance of doubt, DESIGNATED 

MATERIAL may be shown to the designating partys witness(es) put forth to testify on 

behalf of that party under FRCP 30(b)(6). 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. Counsel for any producing Party shall 

have the right to exclude from oral depositions, other than the deponent, deponents 

counsel, the reporter and videographer (if any), and translators, any person who is not 

authorized by this Protective Order to receive or access Protected Material based on the 

designation of such Protected Material. Such right of exclusion shall be applicable only 

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during periods of examination or testimony regarding such Protected Material. 

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 or RESTRICTED - ATTORNEY EYES ONLY 

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 hearing transcript shall be treated as confidential. 

16. 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. 

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) calendar days of receipt of the written request, the 

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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 Rules 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 Courts determination of the application, the 

designation of the designating Party shall be maintained. 

19. DESIGNATION OF EXPERTS AND CONSULTANTS

(a) 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. 

(b) Before any DESIGNATED MATERIAL is disclosed to an outside consultant or 

expert, the following information must be provided in writing to the producing 

Party and received no less than seven (7) business days before the intended date of 

disclosure to that outside consultant or expert: the items specified in Federal Rules 

of Civil Procedure 26(a)(2)(B)(iv)-(vi), including an identification of which party 

was represented for any items listed under FRCP 26(a)(2)(B)(v), and any past 

consulting or employment relationship between the outside consultant or expert 

and either Party or any Party-affiliated entities. 

(c) If the producing Party objects to the disclosure of DESIGNATED MATERIAL to 

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a receiving Partys outside consultant or expert, the producing Party shall within 

seven (7) business days of receipt serve written objections identifying the specific 

basis for the objection, and identifying the information to which disclosure is 

objected. Failure to object within seven (7) business days shall authorize the 

disclosure of DESIGNATED MATERIAL to the consultant or expert. As to any 

objections, the Parties shall attempt in good faith to promptly resolve any 

objections informally within five (5) business days of the objection. If the 

objections cannot be resolved, the Party seeking to prevent disclosure of the 

DESIGNATED MATERIAL to the outside consultant or expert shall move within 

five (5) business days of the meet and confer for an order of the Court preventing 

the disclosure. If no such motion is made within five (5) business days, disclosure 

to the consultant or expert shall be permitted. In the event that objections are made 

and not resolved informally, and a motion is filed, disclosure of DESIGNATED 

MATERIAL to the consultant or expert shall not be made except by order of the 

Court. 

(d) No Party shall attempt to depose any consultant or expert of another Party until 

such time as the consultant or expert is designated by the Party engaging the 

consultant or expert as a testifying expert. Notwithstanding the preceding 

sentence, any Party may depose a consultant or expert as a fact witness provided 

that the Party seeking such deposition has a good faith, demonstrable basis 

independent of the Acknowledgement of Appendix A or the provided 

DESIGNATED MATERIAL that such person has personal knowledge of facts 

relevant to this Action or of facts likely to lead to the discovery of admissible 

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evidence, independent of any knowledge that such person develops through work 

as a consultant or expert in this Action; however, such deposition, if it precedes the 

designation of such person by the engaging Party as a testifying expert, shall not 

include any questions regarding the scope or subject matter of the engagement. In 

addition, if the engaging Party chooses not to designate the consultant or expert as 

a testifying expert, the non-engaging Party shall not seek discovery or trial 

testimony as to the scope or subject matter of the engagement. 

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 

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 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 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 

RESTRICTED -- ATTORNEYS EYES ONLY in accordance with this Order. 

22. If a Party is served with a subpoena issued by a court, arbitral, administrative, or legislative 

body, or with a court order issued in other litigation that compels disclosure of any 

information or items designated pursuant to this Order, that Party must: 

a. notify the designating Party via email within 5 business days of receiving the 

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subpoena. Such notification shall include a copy of the subpoena or court order; 

b. promptly notify in writing the person 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 Protective 

Order and copy counsel for the designating Party; and 

c. not interfere with respect to all reasonable procedures sought to be pursued by the 

designating Party whose DESIGNATED MATERIAL 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 information designated pursuant to this Order before a determination by the 

Court from which the subpoena or order issued, unless the Party has obtained the designating 

Partys permission, or required by court order to do so. 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. 

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

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

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

into any privileged memoranda of the Parties and materials which have been admitted into 

evidence in this Action), shall at the producing Partys 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 Partys request. The 

foregoing requirements do not apply to DESIGNATED MATERIAL that has been 

archived on backup media or otherwise stored as difficult-to-access backup data according 

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to a Receiving Partys normal or allowed processes. 

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

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

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

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

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

thereof, all such objections being hereby preserved. 

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

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

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

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

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

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

action alleged to constitute a violation of this Order. 

26. Production of DESIGNATED MATERIAL by 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. 

27. 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. 

28. 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 

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protection of DESIGNATED MATERIAL. 

29. This Order shall be binding upon the Parties, 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. This paragraph applies only 

to the extent any such person or entity has received DESIGNATED MATERIAL. 

30. To the extent any Party finds that the provisions of this Order are interfering with the 

efficient preparation of the case for trial or that stricter provisions may be necessary for 

the protection of a Partys confidential information, they may seek modifications from the 

Court without being prejudiced by having agreed to any of the provisions. 

So Ordered this

Jun 29, 2024

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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

SIGNODE INDUSTRIAL GROUP LLC 

 v. 

SAMUEL, SON & CO., LTD., et al. 

§ 

§ 

§ 

§ 

§ 

 Case No. 2:24-CV-0080-JRG 

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 or 

RESTRICTED -- ATTORNEYS EYES ONLY that is disclosed to me. 

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

designated as CONFIDENTIAL or RESTRICTED -- ATTORNEYS EYES ONLY 

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 

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Protective Order in this action. 

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

Signature ________________________________________ 

Date ____________________________________________ 

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