`
`IN THE UNITED STATES DISTRICT COURT
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`FOR THE DISTRICT OF DELAWARE
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`ELM 3DS INNOVATIONS, LLC, a
`Delaware limited liability company,
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`Plaintiff,
`
`v.
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`SAMSUNG ELECTRONICS CO., LTD., a
`Korean business entity,
`SAMSUNG SEMICONDUCTOR, INC., a
`California corporation,
`SAMSUNG ELECTRONICS AMERICA,
`INC., a New York corporation, and
`SAMSUNG AUSTIN SEMICONDUCTOR,
`LLC, a Delaware limited liability company,
`
`C.A. No. 14-1430-LPS
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`
`
`)
`)
`)
`)
`)
`)
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`Defendants.
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`______________________________________
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`STIPULATION AND [PROPOSED] ORDER
`TO ENTER SUPPLEMENTAL PROTECTIVE ORDER
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`WHEREAS, the Court has entered a Stipulated Protective Order (the “Protective Order”)
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`governing the disclosure of confidential materials in the above-referenced matter;
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`WHEREAS, the Court has entered a Supplemental Protective Order governing the
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`disclosure of the confidential materials of non-party Apple Inc. (D.I. 332) pursuant to the Court’s
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`Oral Order (D.I. 327);
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`NOW THEREFORE, the parties hereby stipulate and agree, subject to the approval of the
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`Court, to enter a Supplemental Protective Order for non-party Lam Research Corporation (“Lam
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`Research”) as follows:
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`
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`
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`Case 1:14-cv-01430-LPS Document 346 Filed 10/23/20 Page 2 of 3 PageID #: 21755
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`
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`1.
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`Disclosure of Lam Research Confidential Information. To the extent that a party
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`seeks to disclose any Lam Research Confidential Information to any individual pursuant to
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`Sections I.A.5.b (regarding experts or consultants) or I.A.5.f (regarding “any other person”) of
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`the operative Protective Orders, the parties shall afford Lam Research the same notice,
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`disclosure, and consent rights as provided to a producing party under the Protective Orders.
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`2.
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`Exhibit List. The parties shall notify Lam Research should any Lam Research
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`Confidential Information appear on any party’s trial exhibit list; and
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`3.
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`Use of Lam Research Confidential Information at Hearing or at Trial. The parties
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`shall use reasonable efforts to seal the courtroom and redact any related transcript should the
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`Lam Research Confidential Information be discussed at hearing or at trial; or provide Lam
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`Research with reasonable notice before such information is used so that Lam Research may
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`intervene.
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`2
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`Case 1:14-cv-01430-LPS Document 346 Filed 10/23/20 Page 3 of 3 PageID #: 21756
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`
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`
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`DATED: October 23, 2020
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`
`
`
`
`
`
` /s/ Brian E. Farnan
`Brian E. Farnan (#4089)
`Michael J. Farnan (#5165)
`Farnan LLP
`919 North Market Street
`12th Floor
`Wilmington, DE 19801
`(302) 777-0300
`bfarnan@farnanlaw.com
`mfarnan@farnalaw.com
`
`
`Attorneys for Plaintiff Elm 3DS Innovations,
`LLC
`
`
`
`
`
`
`
` /s/ Adam W. Poff
`Adam W. Poff (No. 3990)
`Pilar G. Kraman (No. 5199)
`Young Conaway Stargatt & Taylor, LLP
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`apoff@ycst.com
`pkraman@ycst.com
`
`Attorneys for Defendants Samsung
`Electronics Co., Ltd., Samsung
`Semiconductor, Inc., Samsung Electronics
`America, Inc., and Samsung Austin
`Semiconductor, LLC
`
`
`
`IT IS SO ORDERED this __________ day of ____________, 2020.
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`
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`27238244.1
`
`___________________________
`Honorable Leonard P. Stark
`Chief, United States District Judge
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`3
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`
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