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V5 Technologies LLC v. Switch Ltd.

United States District Court, D. Nevada

December 20, 2017

SWITCH, LTD., a Nevada limited company; SWITCH BUSINESS SOLUTIONS, LLC, a Nevada limited liability company; SWITCH COMMUNICATIONS GROUP L.L.C., a Nevada limited liability company; SWITCH, INC., a Nevada corporation, Defendants.

          I. Scott Bogatz, Kerry E. Kleiman REID RUBINSTEIN & BOGATZ Bank of America Plaza Bryan A. Merryman (Pro Hac Vice) Catherine Simonsen (Pro Hac Vice) WHITE & CASE LLP Claire DeLelle (Pro Hac Vice) WHITE & CASE LLP Attorneys for Plaintiff V5 Technologies, LLC, d/b/a Cobalt Data Centers


         Before the Court is the Parties' Stipulated Protective Order, which the Court being fully advised as to the same, it is hereby ORDERED. The protections afforded in this Protective Order also apply to any third party producing documents or electronically stored information in this action.


         Discovery in this litigation could involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Such confidential and proprietary materials and information consist of, among other things, confidential business or financial information, information regarding confidential business practices, or other confidential research, development, or commercial information (including information implicating privacy rights of third parties), or information otherwise generally unavailable to the public. Accordingly, to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of the litigation, and to serve the ends of justice, a protective order for such information is justified in this matter.

         2. DEFINITIONS

         2.1 Action: The above-captioned action.

         2.2.1 “CONFIDENTIAL” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that may reveal a trade secret, or other confidential research, development, financial, or other information: (1) that is not commonly known by or available to the public and derives value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain value from its disclosure or use; (2) that contains protected personally identifiable information; or (3) any other material that is confidential pursuant to applicable law.

         2.2.2 “HIGHLY CONFIDENTIAL INFORMATION”: passwords, technical design specifications, equipment serial numbers, equipment model numbers, IP addresses, and social security numbers. The parties agree that the producing party may redact Highly Confidential Information by redacting such information and replacing it with a box that reads: “Highly Confidential Information, ” subject to the receiving party's right to challenge the redaction. To the extent a party challenges another party's redaction and the Court orders disclosure, the parties will work in good faith to agree on the handling of such Highly Confidential Information.

         2.3 Counsel: Outside Counsel of Record and In-House Counsel (as well as their support staff).

         2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.” 2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.

         2.6 Expert and/or Consultants: a person with specialized knowledge or experience in a matter pertinent to the litigation, along with his or her support staff, who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in the Action.

         2.7 In-House Counsel: attorneys who are employees of a party to the Action. In-House Counsel does not include Outside Counsel of Record or any other outside counsel.

         2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this Action.

         2.9 Outside Counsel: attorneys who are not employees of a party to this Action but are retained to represent or advise a party to this Action and includes support staff.

         2.10 Party: any party to this Action, including all of its officers, directors, and employees.

         2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action.

         2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

         2.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.” 2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

         3. SCOPE

         The protections conferred by this Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that reveal Protected Material. Any use of Protected Material at trial shall be governed by the orders of the trial judge.


         4.1 Designating Material for Protection.

         Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. The Designating Party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify so that other portions of the material, documents, items, or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order. If it comes to a Designating Party's attention that information or items that it designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the inapplicable designation.

         4.2 Manner and ...

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