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Las Vegas Skydiving Adventures LLC v. Groupon, Inc.

United States District Court, D. Nevada

May 13, 2019

LAS VEGAS SKYDIVING ADVENTURES LLC, a Nevada limited-liability company, Plaintiff,
v.
GROUPON, INC., a Delaware corporation, Defendant.

          GIBSON LOWRY LLP, Steven A. Gibson, KRISTINA MILETOVIC, Counsel for Plaintiff

          GREENBERG TRAURIG, LLP, Mark E. Ferrario, TYLER ANDREWS, Counsel for Plaintiff

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Plaintiff Las Vegas Skydiving Adventures LLC (“Plaintiff” or “LV Skydiving”) and Defendant Groupon, Inc. (“Groupon;” Plaintiff and Groupon, the “Parties;” Plaintiff or Groupon, a “Party”), by and through their respective counsel of record hereby stipulate and agree that the materials to be exchanged throughout the course of this litigation between the Parties may contain information that is potentially protectable pursuant to Federal Rule of Civil Procedure (“FRCP”) 26(c)(1)(G). The purpose of this Stipulated Confidentiality Agreement and Protective Order (the “Order”) is to set forth a protocol governing the Parties' conduct with respect to the treatment of such materials. THEREFORE:

         I. DEFINITIONS

         The following terms shall have the following meanings:

a. “Case” shall mean the above-captioned litigation.
b. “Confidential Information” shall mean any Content that is potentially protectable pursuant to FRCP 26(c)(1)(G) and is designated as confidential in the manner set forth in this Order.
c. “Content” shall mean all material, information, knowledge, matter, text, software, data, graphics, computer-generated displays and interfaces, images, and works of any nature, including, without limitation, all compilations of the foregoing and all results and/or derivations of the expression of the foregoing.
d. “Document” shall mean all Content embodied in any tangible Media, whether in draft, in final, original or reproduction, signed or unsigned, and regardless of whether or not approved, sent, received, redrafted, or executed. “Document” shall exclude exact duplicates when originals are available, but shall include all native Media copies and all copies made different from originals by virtue of any writings, notations, symbols, characters, impressions, or any other marks thereon.
e. “Media” shall mean any medium of expression or medium in or through which Content may be embodied or Published (whether tangible or intangible, fixed or unfixed), including, without limitation, written communications, electronic mail, letters, correspondence, memoranda, notes, records, returns, voice mail, balance sheets, business records, photographs, tape or sound recordings, magnetic disks, read-only memory, random access memory, contracts, agreements, notations of telephone conversations or in-person conversations, diaries, desk calendars, reports, computer records, data compilations of any type or kind, television, facsimile, telephony, radio, satellite, cable, wire, network, optical means, electronic means, Internet, intranet, software, compact disks, digital versatile disks, laser disks, digital video displays, multimedia, or materials similar to any of the foregoing, however denominated and to whomever addressed, and any other method (now known or hereafter developed) for the Publication, retention, conveyance, possession, or holding of Content.
f. “Person” shall mean any individual, corporation, partnership, limited partnership, limited-liability partnership, limited-liability company, trust, association, organization or any form of entity whatsoever.
g. “Publication” shall mean the result of anything that has been Published.
h. “Publish” shall mean to make known or otherwise disclose, display, present, communicate, convey, or transfer, whether to one Person or more than one Person, and whether or not for the first time.

         All of the defined terms, if defined in the singular or present tense, shall also retain such general meaning if used in the plural or past tense, and, if used in the plural or past tense, shall retain ...


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