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HP Tuners, LLC v. Cannata

United States District Court, D. Nevada

June 6, 2019

HP TUNERS, LLC, a Nevada limited liability company, Plaintiff,
v.
KENNETH CANNATA, Defendant.

          LEE HIGH, LTD. CECILIA LEE, ESQ. ELIZABETH HIGH, ESQ.

          KOLESAR & LEATHAM BART LARSEN, ESQ. ATTORNEY FOR DEFENDANT, KENNETH CANNATA

          MARKS & KLEIN ANDREW P. BLEIMAN, ESQ. ATTORNEYS FOR PLAINTIFF HP TUNERS, LLC

          STIPULATION FOR PROTECTIVE ORDER

         IT IS HEREBY STIPULATED BY AND BETWEEN Plaintiff HP Tuners, LLC, through its attorneys, Andrew P. Bleiman, Esq., Marks & Klein, and Cecilia Lee, Esq. and Elizabeth High, Esq., Lee High, Ltd., and Defendant Kenneth Cannata, through his attorney, Bart Larsen, Esq., Kolesar & Leatham, for the entry of the following protective order.

         PROTECTIVE ORDER

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. The parties have therefore agreed to the following Protective Order. The parties acknowledge that this agreement is consistent with Fed.R.Civ.P. 26(c) and LR II 26-1. It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. “CONFIDENTIAL” AND “HIGHLY CONFIDENTIAL” MATERIAL

         2.1 “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged: business records and employee files; documents relating to expertise and knowledge, including automotive tuning data and data related to other types of vehicles; documents relating to undisclosed advertising and marketing; management communications; pricing information; agreements with employees and non-parties; technical information about a party's products or anticipated products; communications and other non-public documents relating to the business and dealings of the parties.

         2.2 “Highly Confidential” material shall include any document, material, or information otherwise meeting the definition of “Confidential, ” the disclosure of which to another party or non-party the disclosing party reasonably believes would likely result in competitive, commercial, financial, or other harm to the disclosing party or its clients or potential clients. “Highly confidential” material may include, without limitation, proprietary technical information in the nature of hardware design documents, source code; proprietary software; license key generators, and computer passwords.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material.

         However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving ...


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