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Enovate Medical, LLC v. Definitive Technology Group, LLC

United States District Court, D. Massachusetts

July 6, 2018

ENOVATE MEDICAL, LLC, Plaintiff/Counterclaim Defendant,
v.
DEFINITIVE TECHNOLOGY GROUP, LLC, Defendant/Counterclaimant.

          ENOVATE MEDICAL, LLC By counsel: Matthew C. Cox (TN Bar No. 028212) Waller Lansden Dortch & Davis, LLP

          DEFINITIVE TECHNOLOGY GROUP, LLC By counsel: Bradley M. Stohry (Ind. Atty. No. 25820-49) Reichel Stohry LLP

          AGREED PROTECTIVE ORDER

          Richard G. Stearns, Judge

         I. INTRODUCTION

         The parties, by their undersigned counsel, pursuant to Fed.R.Civ.P. 26(c)(1), hereby stipulate to the following provisions of this Agreed Protective Order.

         II. SCOPE OF PROTECTED INFORMATION

         In the course of discovery in this action, the parties may be required to produce information that constitutes, in whole or in part, protected information such as trade secrets, non-public research and development, commercial or financial information, or other information that may cause harm to the producing party or a non-party. The parties anticipate production of the following categories of protected information: trade secrets, financial information, product research, non-public information about products and potential products, confidential agreements, customer information and communications, manufacturer information and communications, and internal communications.

         III. DESIGNATION OF PROTECTED INFORMATION

         A. Scope:

         This Order governs the production and handling of any protected information in this action. Any party or non-party who produces protected information in this action may designate it as “Confidential” or “Attorneys' Eyes Only” consistent with the terms of this Order. “Designating Party” means the party or non-party who so designates the protected information; “Receiving Party” means the party or non-party to whom such information was produced or disclosed. Whenever possible, the Designating Party must designate only those portions of a document, deposition, transcript, or other material that contain the protected information and refrain from designating entire documents. Regardless of any designations made hereunder, the Designating Party is not otherwise restricted from use or disclosure of its protected information outside of this action. In addition, any party may move to modify or seek other relief from any of the terms of this Order if it has first tried in writing and in good faith to resolve its needs or disputes with the other party(ies) pursuant to the terms of this Order.

         B. Application to Non-Parties:

         Before a non-party is given copies of designated information as permitted hereunder, it must first sign the acknowledgment to be bound to these terms that is attached hereto as Exhibit A; if it fails to do so, the parties to this action must resolve any such dispute before making disclosure of designated information as permitted hereunder to the non-party. If a non-party wishes to make designations hereunder, it must first sign the acknowledgment to be bound to these terms that is attached hereto as Exhibit A.

         C. Timing and Provisional Protection: Designations may be made at any time. To avoid potential waiver of protection hereunder, the Designating Party should designate information at the time of production or disclosure, including on the record during the taking of any testimony. Deposition testimony will be deemed provisionally protected as Attorneys' Eyes Only for a period of 30 days after the transcript is released to the parties by the court reporter, although the parties may agree at any time to different timelines of provisional protection of information as Confidential or Attorneys' Eyes Only as part of one or more specific depositions. To retain any designations beyond the provisional period, a Designating Party must designate specific pages and lines of deposition testimony before the provisional period has expired. Such designations must be made in writing so that all counsel and court reporters may append the designation to all copies of the transcripts.

         D. Manner of Designation:

         Information may be designated hereunder in any reasonable manner or method that notifies the Receiving Party of the designation level and identifies with specificity the information to which the designation applies. If made verbally, the Designating Party must promptly confirm in writing the designation. Whenever possible, the Designating Party should stamp, affix, or embed a legend of “CONFIDENTIAL” or “ATTORNEYS' EYES ONLY” on each designated page of the document or electronic image.

         IV. CHALLENGES TO ...


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