`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`VB Assets, LLC,
`
`Plaintiff,
`
`v.
`
`Amazon.com Inc., et al.,
`
`Defendants.
`
`C.A. No. 1:19-cv-01410-MN
`
`ADDENDUM TO STIPULATED PROTECTIVE ORDER
`
`In light of the COVID-19 pandemic, and the resulting Federal, State, and local travel
`
`restrictions and shelter-in-place orders (collectively, “COVID-19 Restrictions”), Plaintiff VB
`
`Assets, LLC and defendants Amazon.com, Inc.; Amazon.com LLC; Amazon Web Services,
`
`Inc.; A2Z Development Center, Inc. d/b/a Lab126; Rawles LLC; AMZN Mobile LLC; AMZN
`
`Mobile 2 LLC; Amazon.com Services, Inc. f/k/a Amazon Fulfillment Services, Inc.; and
`
`Amazon Digital Services LLC (collectively, “the parties”) agree to the following additional term
`
`governing production of Protected Information designated as “HIGHLY CONFIDENTIAL –
`
`SOURCE CODE.”
`
`The term in this Addendum shall remain in effect only so long as COVID-19 Restrictions
`
`are in effect at the locations of respective relevant parties, such as the location of the parties’
`
`respective counsel and source code review consultants and experts. Once the COVID-19
`
`Restrictions in those locations are lifted, however, the Producing Party can, at its sole discretion,
`
`continue (or resume) providing Source Code pursuant to the term of this Addendum at any time
`
`or provide Source Code pursuant to section 2.4.10 of the Stipulated Protective Order.
`
`
`
`Case 1:19-cv-01410-MN Document 40 Filed 05/27/20 Page 2 of 3 PageID #: 1008
`
`The parties acknowledge that while the term below may not reflect the Producing Party’s
`
`normal security protocols, it represents an accommodation in the interest of moving the case
`
`forward during the unprecedented COVID-19 pandemic and in light of applicable COVID-19
`
`Restrictions and related office closures and travel restrictions. A Party’s agreement to make
`
`Source Code available pursuant to this Addendum shall not be construed as an admission that the
`
`provision of this Addendum is appropriate in any other case or that this provision provides an
`
`acceptable level of security for the Producing Party’s Source Code at any other time not affected
`
`by the COVID-19 pandemic. The Addendum may not be cited as an appropriate practice to
`
`follow once the COVID-19 pandemic has passed even if the Producing Party decides to follow
`
`the term of this Addendum after the COVID-19 Restrictions are lifted because other pandemic-
`
`related issues such as delayed office re-openings may still be experienced.
`
`1.
`
`The Receiving Party’s outside counsel of record, experts or consultants may
`
`temporarily keep paper copies of the Source Code or any notes, analyses, or descriptions of
`
`Source Code (“Source Code Material”) under their direct control in a secured home office in a
`
`manner that prevents unauthorized access to the Source Code Material.
`
`2
`
`
`
`Case 1:19-cv-01410-MN Document 40 Filed 05/27/20 Page 3 of 3 PageID #: 1009
`
`JOINTLY SUBMITTED BY:
`
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`
`ASHBY & GEDDES
`
`/s/ Ian R. Liston
`Ian R. Liston (Delaware Bar I.D. # 5507)
`222 Delaware Avenue
`Suite 800
`Wilmington, DE 19801
`iliston@wsgr.com
`Telephone: (302) 304-7600
`Facsimile: (866) 974-7329
`Attorneys for VB Assets, LLC
`
`/s/ Andrew C. Mayo
`Steven J. Balick (#2114)
`Andrew C. Mayo (#5207)
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`Wilmington, DE 19899
`(302) 654-1888
`sbalick@ashbygeddes.com
`amayo@ashbygeddes.com
`
`Attorneys for Defendants
`Amazon.com Inc.; Amazon.com LLC; Amazon
`Web Services, Inc.; A2Z Development Center,
`Inc. d/b/a Lab126; Rawles LLC; AMZN
`Mobile LLC; AMZN Mobile 2 LLC;
`Amazon.com Services, Inc. f/k/a Amazon
`Fulfillment Services, Inc.; and Amazon Digital
`Services LLC
`
`SO ORDERED this _____day of ___________, 2020
`(cid:21)(cid:26)(cid:87)(cid:75)(cid:3)
`(cid:3)
`(cid:48)(cid:68)(cid:92)
`_______________________________
`___________________ _____________________________________________________________ _________ _______ _____________
`The Honorable Maryellen Noreika
`The eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee Honooooooooooooooooooooooooooooooooooooooooooooooooooooooooooooorrarrrrrrrr ble Maryellen Noreika
`United States District Judge
`U it d St t Di t i t J d
`
`0 _
`
`3
`
`
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