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State Farm Fire & Casualty Co. v. Cube Electronics Co., Ltd.

United States District Court, D. Nevada

March 20, 2018

STATE FARM FIRE AND CASUALTY COMPANY, as subrogee of Troy Daigneau, Plaintiff,
v.
CUBE ELECTRONICS CO., LTD. a/k/a Cube Shenzhen Electronics Tech Co., Ltd.; AMAZON.COM INC.; BIKE REVOLUTION BIKE SHOP d/b/a Elite Cycle & Sports; MEGA SINAI, LLC; and DOES 1 through X, inclusive, Defendants.

          Steve Morris, NV Bar No. 1543 Jean-Paul Hendricks, NV Bar No. 10079 Attorneys for Defendant Amazon.com, Inc.

          (PROPOSED) REVISED STIPULATED PROTECTIVE ORDER

         Plaintiff and defendants Amazon.com, Inc. ("Amazon") and Bike Revolution Bike Shop d/b/a Elite Cycle & Sports ("Bike Revolution") (defendants Cube Electronics Co., LTD and Mega Sinai, LLC have not appeared) contemplate that discovery will involve information and documents that contain personal medical and financial information, trade secrets, proprietary or competitively sensitive financial and business information, and other private or confidential information. Plaintiff, Amazon.com, and Bike Revolution hereby stipulate to the following stipulated protective order and request entry of this order to establish procedures to enable the parties to obtain discovery of such information and documents; to protect against public disclosure; and to promptly resolve disputes over confidentiality.

         The Court hereby orders:

         1. Scope and Application of Protective Order.

         This Protective Order governs all documents, information, or other material that is designated "Confidential Information" as defined herein, and that is produced in connection with this litigation by any person or entity (the "producing party") to any other person or entity (the "receiving party"), regardless whether the person or entity producing or receiving the Confidential Information is a party.

         2. Definitions.

         Confidential Information. "Confidential Information" means any information that is private, confidential, or proprietary, including the following representative but non-exclusive examples:

• taxes and other financial records
• accounting or financial statements (not including publicly available financial statements)
• trade secrets
• commercial, financial, pricing, budgeting, revenue, profit, or accounting information
• information about existing and potential customers
• marketing studies and projections
• business strategies, decisions, or negotiations
• compensation, evaluations, and employment information
• proprietary information about affiliates, parents, subsidiaries, and third-parties with
• whom the parties have or have had business relationships
• any other information whose disclosure could cause an invasion of privacy or
• competitive business harm.

         A protective order is warranted because Confidential Information derives value from not being publicly known, and public disclosure could lead to serious and unwarranted injury.

         2.2. Documents.

         The term "documents" includes all information or communications in any written or electronic form, regardless of format, and includes visual depictions such as photographs.

         3. Designation of Confidential Information.

         3.1. Good Faith Claims.

         All claims of confidentiality and objections to those claims must be made under a good faith belief that the information satisfies (or, in the case of objections, does not satisfy) the definition of Confidential Information.

         3.2. Produced Documents.

         A party producing documents that it believes constitute or contain Confidential Information shall label the documents with the following legend or something substantially similar to clearly advise of the confidential nature of the contents:

I CONFIDENTIAL: Subject to Protective Order in I No. 2:17-cv-02109-JCM-GWF in the United States District Court for the District of Nevada

         The label shall not obliterate or obscure the contents. If a document containing Confidential Information is produced in native format, the file name shall contain the term "Confidential Information" or otherwise clearly indicate that it contains information subject to this Order. If any person or party makes copies of documents designated as containing Confidential Information, each copy must be marked as containing Confidential Information in the same form as the original document.

         A party producing documents that are stored on data storage devices shall designate the data storage device as containing Confidential Information, by labeling the data storage device and files as described above. If the receiving party or other persons or entities to whom disclosure is authorized under this order make a copy of any data storage device designated by the producing party as containing Confidential Information, the receiving party or other authorized person shall mark each copy as containing Confidential Information in the same form as the notice on the original data storage device. If the receiving party or ...


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