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SCSI, LLC v. Kaco USA, Inc.

United States District Court, W.D. North Carolina, Statesville Division

September 16, 2019

SCSI, LLC, as assignee of SCSI Suzhou Quality Service Co., Ltd., Plaintiff,
v.
KACO USA, INC., Defendant.

          STIPULATED PROTECTIVE ORDER

          David C. Keesler United States Magistrate Judge

         Plaintiff SCSI, LLC (“Plaintiff) and Defendant Kaco USA, Inc. (“Defendant”), herein after referred to as the “Parties, ” believe that certain information that is or will be encompassed by discovery demands by the Parties involves the production or disclosure or dissemination of confidential information in this action (the “Litigation”).

         IT IS HEREBY stipulated among the Parties and ORDERED THAT the Parties and anyone else who subsequently may subscribe to this Protective Order by execution of the “Nondisclosure Certificate” attached hereto as Exhibit 1 shall be a “Bound Party” (collectively referred to as “Bound Parties”), and each one of the Bound Parties is ordered by the Court as follows:

         1. SCOPE. This Protective Order shall govern the production, exchange, access, and use of all discovery materials produced or disclosed in the Litigation, including without limitation the following: documents, electronic documents and e-mails, data and information, depositions and deposition exhibits, affidavits, testimony, answers to interrogatories, responses to requests to admit, and all other information (regardless of the medium or manner generated, stored, or maintained) that is produced, given, provided, or exchanged (collectively the “Discovery Materials”) among the Bound Parties in the Litigation. This Protective Order shall apply to each Bound Party and any other entity or person receiving, producing or disclosing Discovery Materials in the Litigation, including any third party responding to subpoenas issued in the Litigation.

         2. CATEGORIES OF INFORMATION. Any Discovery Materials produced by any party, third party, person, or entity subject to or participating in discovery in the Litigation may be designated by the Parties or the producing party by marking the Discovery Materials as “Confidential” (collectively “Designated Discovery Materials”). For electronic files produced in native format, the producing party may mark the Discovery Materials as “Confidential” on the disk or other storage media containing the electronic files; with respect to any electronic files produced in native format, the “Confidential” designation applies to the file in its entirety, including all content and metadata. Any other material containing Confidential Information that cannot be labeled as “Confidential” shall be placed in a sealed envelope or other container that is in turn marked “Confidential” or is otherwise designated as “Confidential” in a manner agreed upon by the Parties.

         3. CONFIDENTIAL INFORMATION. Discovery Materials should be marked as “Confidential” when they contain confidential information that may be reviewed by certain named persons described herein, but must be protected against disclosure to others. Counsel for any Party, third party, person, or entity subject to or participating in discovery in the Litigation (the “Designating Party”) may designate any Discovery Materials as “Confidential” when the Designating Party reasonably and in good faith believes that the Discovery Materials contain, constitute, or reveal trade secrets, non-public proprietary or commercial information, or other sensitive competitive materials for which a protective order would be legally justified under Fed.R.Civ.P. 26(c) (“Confidential Information”). Confidential Information may be shown, disseminated, or disclosed only to the following persons, each of whom shall be deemed a “Qualified Person”:

(a) Counsel for the Parties, and employees and agents of such counsel assigned to and reasonably necessary to assist such counsel in the Litigation;
(b) Parties to this Litigation, including their current or former personnel or representatives;
(c) Consultants, investigators, and experts retained or consulted by a party or counsel to assist in the preparation, trial, and appeal of the action, provided that such consultant, investigator, or expert has executed a Nondisclosure Certificate substantially in the form of Exhibit 1 attached hereto;
(d) Witnesses in connection with the Litigation;
(e) The persons who authored the Confidential Information or who received such Confidential Information in the ordinary course of business or as shown on the face of such Confidential Information;
(f) The Court and its personnel;
(g) Stenographic reporters retained by the Parties to transcribe depositions or other testimony in connection with the Litigation or any outside independent reproduction firm, any technical or technology services firm, or other persons or entities providing litigation support retained by counsel for purposes of the ...

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