UNITED STATES INTERNATIONAL TRADE COMMISSION
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`Washington, D.C.
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`INV. NO. 337-TA-1242
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`
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`In the Matter of
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`CERTAIN IP CAMERA SYSTEMS INCLUDING
`VIDEO DOORBELLS AND COMPONENTS
`THEREOF
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`ORDER NO. 9:
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`GRANTING-IN-PART JOINT MOTION TO AMEND THE
`PROTECTIVE ORDER TO ADD PROVISIONS COVERING
`SOURCE CODE
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`
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`(June 17, 2021)
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`On June 9, 2021, complainants SkyBell Technologies, Inc., SB IP Holdings, LLC, and
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`Eyetalk365, LLC, and respondents Vivint Smart Home Inc., SimpliSafe, Inc., and Arlo
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`Technologies, Inc. (collectively, the “Parties”) filed a joint motion (“Mot.”) seeking to amend the
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`Protective Order (Order No. 1) to include enhanced confidentiality provisions for source code
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`produced in this investigation. Motion Docket No. 1242-003. The Parties also seek an amendment
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`to the Protective Order that would bar persons who review source code from participating in certain
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`patent prosecution activities concerning related subject matter. See Mot. Ex. A ¶ 21.
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`Motion No. 1242-003 is granted-in-part. Good cause has been shown for the additional
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`source code provisions set forth in the Parties’ proposed addendum to the protective order. Those
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`provisions, appended to this order as Attachment A, are hereby incorporated into the Protective
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`Order.
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`The Parties’ request for a prosecution bar is denied without prejudice. To demonstrate the
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`need for a patent prosecution bar in this investigation, the Parties must show that (1) the
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`information triggering the bar is confidential, relevant to patent prosecution, and is of the kind that
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`may pose a heightened risk of inadvertent disclosure; (2) a particular patent prosecution attorney
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`having access to the information is involved in competitive decision making; and (3) the risk of
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`inadvertent disclosure by that person outweighs the burden a prosecution bar would impose on that
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`individual. See, e.g., Certain Consumer Electronics, Including Mobile Phones and Tablets, Inv.
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`No. 337-TA-839, Order No. 28, at 4 (Jan. 7, 2013) (discussing In re Deutsche Bank Tr. Co.
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`Americas, 605 F.3d 1373 (Fed. Cir. 2010)); see also Certain Multi-Domain Test and Measurement
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`Instruments, Inv. No. 337-TA-1104, Order No. 9, at 3 (Jun. 11, 2018) (applying Deutsche Bank to
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`determine whether a prosecution bar is warranted).
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`The Parties have not demonstrated that a particular patent prosecution attorney has access
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`to confidential information in this investigation such that there is a risk of inadvertent disclosure.
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`Compare Certain Pre-Filled Syringes for Intravitreal Injection and Components Thereof, Inv. No.
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`337-TA-1207, Order No. 17, at 3–4 (Nov. 17, 2020) (four attorneys subscribed to the
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`administrative protective order also represented the same client in pending inter partes review
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`petitions before the U.S. Patent and Trademark Office) with Certain Multi-Domain Test and
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`Measurement Instruments, Inv. No. 337-TA-1104, Order No. 9, at 3 (prosecution bar unwarranted
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`without a showing related to a particular attorney).
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`SO ORDERED.
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`2
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`ATTACHMENT A
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`ATTACHMENT A
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`18.
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`DEFINITIONS
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`(a)
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`“Outside Counsel” means (i) outside counsel who appear on the pleadings as
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`counsel for a Party and (ii) partners, associates, and staff of such counsel to whom it is reasonably
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`necessary to disclose the information for this litigation, including supporting personnel employed
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`by the attorneys, such as paralegals, legal translators, legal secretaries, and legal clerks. However,
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`“Outside Counsel” expressly precludes any attorneys who also serve as In-house Counsel and/or
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`INVESTIGATION NO. 33 7-TA-1242
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`ADDENDUM T0 PRO'I'ECI'IVE ORDER
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`who are members, officers, or directors of a Party or anyone who is an employee of a Party even
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`if that person appears on the pleadings as counsel for a Party.
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`(b)
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`“In-house Counsel” means attorneys who are employees of a Party, and includes
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`supporting personnel employed by those counsel, such as paralegals.
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`(c)
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`“Party” means any party to this Investigation, including all of its officers, directors,
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`employees, consultants, retained experts, and Outside Counsel and their support staff.
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`(d)
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`“Producing Party” means any Party or non-party that discloses or produces any
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`Discovery Material in this case.
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`(e)
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`“Receiving Party” means any Party who receives Discovery Material from a
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`Producing Party.
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`(f)
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`“Source Code” means data that defines software, firmware, and/or circuits (“source
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`code”), including computer code, object code (i.e., computer instructions and data definitions
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`expressed in a form suitable for input to an assembler, compiler, or other translator), microcode,
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`pseudocode, source code listings, software code for performing numerical or data analysis,
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`mathematical modeling, or simulations (e.g., scripts, algorithms, and/or functions), register
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`transfer language (“RTL”), source code for firmware, drivers, controllers, and hardware
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`description language (“HDL”), as well as any and all programmer notes, annotations, revision
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`histories, and other comments related thereto and directly associated with and accompanying the
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`code. For avoidance of doubt, this includes, but is not limited to, source files, project files, make
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`files, intermediate output files, executable files, header files, resource files, binaries, scripts,
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`algorithms, library files, module definition files, map files, object files, linker files, and debug
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`files.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`2
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`19.
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`DISCOVERY MATERIAL DESIGNATED AS “HIGHLY CONFIDENTIAL –
`SOURCE CODE”
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`(a)
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`A Producing Party may designate Source Code as “HIGHLY CONFIDENTIAL –
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`SOURCE CODE” if it comprises or includes confidential, proprietary, and/or trade secret Source
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`Code.
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`(b)
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`Nothing in this Protective Order shall obligate any Party to produce any Source
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`Code, nor act as an admission that any particular Source Code is discoverable.
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`(c)
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`Unless otherwise ordered by the Administrative Law Judge or the Commission,
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`confidential business information designated as “HIGHLY CONFIDENTIAL – SOURCE CODE”
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`shall be subject to the provisions set forth in Paragraph 20 below, and may be disclosed, subject to
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`Paragraph 20 below, solely to:
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`(i)
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`(ii)
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`The Receiving Party’s Outside Counsel;
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`Any outside expert or consultant retained by the Receiving Party to assist
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`in this Investigation, provided that disclosure is only to the extent necessary to perform such work;
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`and provided that: (a) such expert or consultant has agreed to be bound by the provisions of the
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`Protective Order by signing a copy of Attachment A to the Protective Order; (b) such expert or
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`consultant is not a current officer, director, or employee of a Party or of a competitor of a Party,
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`nor anticipated at the time of retention to become an officer, director, or employee of a Party or of
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`a competitor of a Party; and (c) no unresolved objections to such disclosure exist after proper notice
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`has been given to all Parties as set forth in Paragraph 11 of the Protective Order;
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`(iii)
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`Court reporters, stenographers, and videographers retained to record
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`testimony taken in this action;
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`3
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`(iv)
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`The Commission, the Administrative Law Judge, the Commission
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`Investigative Staff, Commission personnel and contract personnel who are acting in the capacity of
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`Commission employees as indicated in paragraph 3(iv-v) of the Protective Order.
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`(v)
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`Any other person with the prior written consent of the Producing Party.
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`20.
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`DISCLOSURE AND REVIEW OF SOURCE CODE
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`(a)
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`Any Source Code that is produced shall be made available for inspection in
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`electronic format at the office of the Producing Party’s Outside Counsel, and where available and
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`convenient for Respondents, in Dallas, TX, or any other location mutually agreed by the Parties.
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`In the event a Respondent agrees to provide Source Code in Dallas, TX, Complainants agree to
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`provide Source Code at a convenient location for that Respondent’s experts, consultants, or other
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`representatives designated to review and inspect the source code. Source Code will be made
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`available for inspection between the hours of 9:00 a.m. and 5:00 p.m. on business days (i.e.,
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`weekdays that are not Federal holidays), or at other mutually agreeable times.
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`(b)
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`Prior to the first inspection of any requested Source Code, the Parties agree to meet
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`and confer regarding the review and production of Source Code if requested by either Party.
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`Further, the Receiving Party shall provide ten (10) days’ notice for its initial review of any Source
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`Code that it wishes to inspect, identifying in writing the person(s) who will be reviewing the Source
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`Code. The Receiving Party shall provide two (2) business days’ notice prior to any additional
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`inspections, identifying in writing the person(s) who will be reviewing the Source Code.
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`(c)
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`Source Code that is designated “HIGHLY CONFIDENTIAL – SOURCE CODE”
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`shall be produced for inspection and review subject to the following provisions, unless otherwise
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`agreed by the Producing Party:
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`4
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`(i)
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`All Source Code shall be made available by the Producing Party to the
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`Receiving Party’s Outside Counsel and/or experts in a secure room1 on at least one secured
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`computer without Internet access or network access to other computers and on which all access
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`ports have been disabled, so that additional peripheral devices cannot be connected to it and as
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`necessary and appropriate to prevent and protect against any unauthorized copying, transmission,
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`removal, or other transfer of any Source Code outside or away from the computer on which the
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`Source Code is provided for inspection but which includes a mouse and keyboard, and if
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`practicable an extra monitor) (the “Source Code Computer” in the “Source Code Review Room”).
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`Upon ten (10) days’ notice and if practical given Covid-19 restrictions that may be in place, the
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`Producing Party shall make a second review computer available. The Source Code Computer shall
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`be password protected and shall have the Source Code stored on a hard drive contained inside or
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`securely attached to the computer. The supplier shall produce Source Code in computer searchable
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`format on the Source Code Computer and in the file format in which the Source Code is kept in
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`the ordinary course of the Producing Party’s business. If requested, the Producing Party shall
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`provide the Receiving Party with information explaining how to start, log on to, and operate the
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`stand-alone computer(s) in order to access the produced Source Code. Proper identification of all
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`authorized persons shall be provided prior to any access to the Source Code Review Room or the
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`Source Code Computer. Proper identification requires showing, at a minimum, a photo
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`identification card sanctioned by the government of any State of the United States, by the
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`government of the United States, or by the nation state of the authorized person’s current
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`1 The Producing and Receiving Parties shall take all reasonable precautions to prevent the spread of
`COVID-19 and/or other viruses by practicing social distancing, wearing face masks, and making cleaning
`and sanitizing supplies available in the area where review and inspection of source code is to take place.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`5
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`citizenship. Access to the Source Code Review Room or the Source Code Computer may be
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`denied, at the discretion of the Producing Party, to any individual who fails to provide proper
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`identification.
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`(ii)
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`Upon request by the Receiving Party and approval by the Producing Party,
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`which approval shall not be unreasonably withheld, the Producing Party will make reasonable efforts
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`to install reasonable analysis tools appropriate for the type of Source Code supplied by the Producing
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`Party, with a license for such tools supplied by the Receiving Party at least five (5) business days in
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`advance of the date upon which the reviewer wishes to have the software tools available for use on the
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`Source Code Computer. Such software shall not be capable of compiling, assembling or building
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`the source code and must otherwise be consistent with the security purposes of this Protective
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`Order and, for example, shall not re-activate the computer’s ports, reactivate any of its wireless
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`devices or capabilities, re-activate electronic or physical copying, or otherwise defeat the security
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`provisions. The Producing Party need not produce source code in executable format absent further
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`agreement of the parties or order of the Administrative Law Judge. Approved analysis tools include
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`the following:
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`https://notepad-plus-plus.org/download/v6.9.2.html
`https://licensing.scitools.com/download
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`https://www.slickedit.com/trial/slickedit
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`Notepad++
`Understand by
`SciTools
`SlickEdit Pro
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`Free
`License key will be
`provided
`Free trial version
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`(iii)
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`No electronic devices, including without limitation laptops, sound
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`recorders, personal digital assistants (PDAs), cellular telephones, peripheral equipment, cameras,
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`voice recorders, Dictaphones, telephone jacks, CDs, DVDs, or drives of any kind (e.g., USB
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`memory sticks and portable hard drives), shall be permitted into the Source Code Review Room.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`6
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`No non-electronic devices capable of similar functionality shall be permitted in the Source Code
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`Review Room.
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`(iv)
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`The reviewer shall not take notes electronically on the Source Code
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`Computer itself or any other computer or electronic device while conducting a review. The
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`reviewer shall be entitled to take handwritten notes relating to the Source Code. Written notes
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`relating to the Source Code may be taken only in spiral- or permanently-bound notebooks. The
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`Source Code may not be copied into the notes. Notwithstanding this provision, file names, location
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`(i.e., directory path), and line numbers as well as function, parameter, and variable names and
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`relationship between segments of code may be copied into the notes. Unless otherwise agreed in
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`advance by the Parties in writing, following each day on which inspection is done under this Order,
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`the Receiving Party’s Outside Counsel and/or experts shall remove all notes, documents, and all
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`other materials from the Source Code Review Room and shall maintain any such notes in a manner
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`that prevents duplication of or unauthorized access to the Source Code. Any such notes must be
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`marked on each page with the designation “HIGHLY CONFIDENTIAL – SOURCE CODE.”
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`(v)
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`The Producing Party may visually monitor the activities of the Receiving
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`Party’s representatives during any Source Code review to ensure compliance with these
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`restrictions. During the Receiving Party’s review of the Source Code, the Producing Party shall
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`not otherwise interfere with the Receiving Party’s review of the Source Code and shall not be
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`permitted access to the Receiving Party’s notes, work product, or discussions inside the review
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`room or following each day’s inspection of the Source Code.
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`(vi)
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`During the Source Code review, the Producing Party agrees to make
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`reasonable efforts provide a “break-out” room for the Receiving Party’s Source Code reviewer(s)
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`to make phone calls, use the Internet, and work. To the extent such a break out room is not
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`7
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`reasonably available, the Producing Party agrees to notify the Receiving Party in advance of any
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`day on which the Receiving Party’s Source Code reviewers are expected to inspect the Source
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`Code and to provide alternative arrangements where practical.
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`(vii) No copies of all or any portion of the Source Code may leave the Source
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`Code Review Room except as otherwise provided herein. Further, no other written or electronic
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`record of the Source Code is permitted except as otherwise provided herein. The Receiving Party
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`may request a reasonable number of pages of Source Code to be printed by the Producing Party,
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`but no more than 37 consecutive pages, or an aggregate total of more than 1125 pages and only
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`when reasonably necessary to prepare Commission filings or pleadings or other papers (including
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`a testifying expert’s expert report), to prepare for and conduct depositions, and only to the extent
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`necessary for use in this Investigation.2 To the extent Receiving Party requires an aggregate total
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`of more than 1125 pages of source code, the Receiving Party shall make such request in writing,
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`including the good faith basis of such a request. The Producing Party will have 5 business days to
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`object and provide basis to object to the request. If Producing Party objects to the request, and the
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`parties are not able to resolve the issue within ten (10) business days of the request, Receiving
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`Party can move to compel Producing Party to produce the requested source code over the 1125
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`page limit. The Receiving Party shall not request printing of Source Code in order to review blocks
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`of Source Code elsewhere in the first instance, i.e., as an alternative to reviewing that Source Code
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`electronically on the Source Code Computer, as the Parties acknowledge and agree that the purpose
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`of the protections herein would be frustrated by printing portions of code for review and analysis
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`2 As an alternative, a Producing Party may at its sole discretion, but is not required to, opt to produce its source code
`on CD, DVD, or other storage media as “HIGHLY CONFIDENTIAL – SOURCE CODE.” The Receiving Party may
`copy such produced source code of the Producing Party from the medium to a secured computer without Internet
`access or network access to other computers which must be kept in a secure location at the offices of the Receiving
`Party’s Outside Counsel.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`8
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`elsewhere, and printing is permitted only when necessary to prepare filings or pleadings or other
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`papers (including a testifying expert’s expert report.).
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`(viii) The Producing Party shall Bates number, copy, and label “HIGHLY
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`CONFIDENTIAL – SOURCE CODE” any pages requested by the Receiving Party. Within five
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`(5) business days, the Producing Party shall either (i) provide up to three (3) copy sets of such
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`pages to the Receiving Party, or (ii) inform the Requesting Party that it objects that the printed
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`portions are excessive and/or not done for a permitted purpose. If, after meeting and conferring
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`within three (3) days of any objections, the Producing Party and the Receiving Party cannot resolve
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`the objection, the Receiving Party shall within five (5) business days of the meet and confer move
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`for an Order compelling production and shall agree to expedited briefing of the motion.3
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`(ix)
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`Access to the Source Code Computer shall be limited to Outside Counsel
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`representing the Reviewing Party and three (3) outside consultants or experts retained by the
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`Reviewing Party and qualified pursuant to paragraphs 3 and 4 of the Protective Order.
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`(x)
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`The Producing Party may maintain a log identifying: (a) the name of each
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`person who accessed the Source Code Review Room; (b) the date and time of access; (c) the length
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`of time of access; and (d) whether any pages were printed. The Producing Party may also retain
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`copies of any printed pages of the Source Code.
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`(xi)
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`The copy sets of the Source Code must be kept in a locked storage container
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`where they will not be accessible to persons other than those allowed access under this order.
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`3 Both Parties agree that the briefing period and page-limits for such motions for a protective order shall be
`as follows: (1) Producing Party shall file the motion by 5:00 PM EST no later than five (5) business days
`after the meet and confer with an agreed motion for expedited briefing as set forth herein; (2) Receiving
`Party’s Response shall fall due within ten (10) days. Both the Producing and Receiving Party further agree
`that briefing for such motions shall be limited to no more than five (5) pages for the motion and five (5)
`pages for the response to the motion. The Parties further agree that neither reply nor sur-reply briefs shall
`be filed in connection with such motions.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`9
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`Except as explicitly permitted below, the Receiving Party is prohibited from making additional
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`copies or scanning the printouts.
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`(xii)
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`The Receiving Party must maintain a log identifying each person who
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`reviews the printouts. The Receiving Party must provide the Producing Party with a copy of the
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`log on seven (7) business days’ notice.
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`(xiii) A Receiving Party may make copies of source code for outside counsel and
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`its experts’ use at a deposition or hearing. The Receiving Party will notify the Producing Party
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`three days in advance of a deposition to provide the Producing Party the option of making a Source
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`Code Computer available at a deposition or hearing or printed copies for witnesses, the Producing
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`Party’s counsel, and the Court as appropriate (and identify the required pages by production
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`number). At the conclusion of the deposition or hearing, the additional copies will be returned to
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`the Producing Party or destroyed. Copies shall not be attached to deposition transcripts.
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`(xiv) Except as provided herein, absent express written permission from the
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`Producing Party, the Receiving Party may not create electronic images, or any other images, or
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`make electronic copies of the Source Code from any paper copy of Source Code for use in any
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`manner (including by way of example only, the Receiving Party may not scan the Source Code to
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`a PDF or photograph the code) except in preparation for or in connection with: (i) filing (under
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`seal) and service of papers, motions, and pleadings; (ii) expert reports and contentions; and (iii) a
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`hearing in this Investigation. Any such electronic copies shall be included in the log generated
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`pursuant to subsection (xiii). Images or copies of Source Code shall not be included in
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`correspondence between the Parties (references to production numbers shall be used instead) and
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`shall be omitted from pleadings and other papers whenever possible.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`10
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`(xv) A Receiving Party that wants to serve, file, or otherwise submit Source
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`Code in connection with a filing or document served may, no earlier than 72 hours prior to the
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`relevant filing, make only as many copies, and only of the specific pages as needed, for submission.
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`It must file the materials under seal and must notify the Producing Party upon filing. To the extent
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`it is necessary to reference Source Code in an expert report, filing, or other discovery document,
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`the excerpts must be limited to the minimum amount necessary to support the specific argument
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`made. Documents containing excerpts must be designated “HIGHLY CONFIDENTIAL –
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`SOURCE CODE.”
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`(xvi) Access to and review of the Source Code shall be strictly for the purpose of
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`investigating the claims and defenses at issue in the above-styled case. No person shall review or
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`analyze any Source Code for purposes unrelated to this case, nor may any person use any knowledge
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`gained as a result of reviewing Source Code in this case in any other pending or future dispute,
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`proceeding, or litigation.
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`INVESTIGATION NO. 337-TA-1242
`ADDENDUM TO PROTECTIVE ORDER
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`11
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`CERTAIN IP CAMERA SYSTEMS INCLUDING VIDEO
`DOORBELLS AND COMPONENTS THEREOF
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`
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`PUBLIC CERTIFICATE OF SERVICE
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`I, Lisa R. Barton, hereby certify that the attached ORDER has been served upon the
`following parties as indicated, on June 17, 2021.
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`Inv. No. 337-TA-1242
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`On Behalf of Complainants SkyBell Technologies, Inc., SB IP
`Holdings, LLC, and Eyetalk365, LLC:
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`Rett Snotherly, Esq.
`LEVI & SNOTHERLY, PLLC
`1101 Connecticut Avenue, NW, Suite 450
`Washington, DC 20036
`Email: rsnotherly@levisnotherly.com
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`On Behalf of Respondent Arlo Technologies, Inc.:
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`Sean C. Cunningham, Esq.
`MORGAN, LEWIS & BOCKIUS LLP
`401 B Street, Suite 1700
`San Diego, California 92101
`Email: sean.cunningham@us.dlapiper.com
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`On Behalf of Respondent SimpliSafe, Inc.:
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`Adam R. Alper, Esq.
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Email: adam.alper@kirkland.com
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`On Behalf of Respondent Vivint Smart Home, Inc.:
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`Charles Barquist, Esq.
`MASCHOFF BRENNAN
`300 South Grand Ave., Suite 1400
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`Lisa R. Barton, Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`☐ Via Hand Delivery
`☐ Via Express Delivery
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`Inv. No. 337-TA-1242
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`☐ Via First Class Mail
`☒ Other: Email Notification
`of Availability for Download
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`CERTAIN IP CAMERA SYSTEMS INCLUDING VIDEO
`DOORBELLS AND COMPONENTS THEREOF
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`Certificate of Service – Page 2
`Los Angeles, California 90071
`Email: cbarquist@mabr.com
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