`
`UNITED STATES DISTRICT COURT
`DISTRICT OF KANSAS
`
`Case No. 6:17-cv-01217-EFM-ADM
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`
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`LOGANTREE LP,
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`vs.
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`GARMIN INTERNATIONAL, INC. and
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`GARMIN USA, INC.,
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`
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`Plaintiff,
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`Defendants.
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`STIPULATION OF THE PARTIES
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`THE PARTIES AGREE AND STIPULATE TO THE FOLLOWING:
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`1.
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`The parties shall apply temporary procedures during the present COVID-19
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`pandemic to facilitate remote source code review.
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`
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`2.
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`Garmin International, Inc. and Garmin USA, Inc. (“Garmin”) will make
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`arrangements to allow remote source code review via a Citrix application installed on a secured
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`laptop during the normal business hours of 9:00 a.m. to 5:00 p.m. Central Time, on dates mutually
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`agreeable to the parties not to extend beyond the current deadline for fact discovery of May 18,
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`2021. The parties agree that the mutually agreed upon dates will be no fewer than five business
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`days from the date on which the selected dates are agreed upon.
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`3.
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`To help mitigate security concerns, LoganTree LP (“LoganTree”) agrees that no
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`personnel from LoganTree and/or LoganTree’s counsel or support staff will allow viewing of the
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`source code by anyone not permitted to do so under the Protective Order (Dkt. 51) or will attempt
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`to transfer, copy, or screen capture any of the source code, or otherwise make improper use of the
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`remote review. Garmin will make remote review available via a Citrix application installed on a
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`
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`Case 6:17-cv-01217-EFM-ADM Document 114 Filed 05/04/21 Page 2 of 3
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`secured laptop provided by Garmin after signed, written certifications are provided by
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`LoganTree’s counsel and each individual involved in remote review that they: i) will not allow
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`viewing of the source code by anyone not permitted to do so under the Protective Order (Dkt. 51),
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`ii) will maintain an active Zoom video session (excluding audio) at all times during the remote
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`review to allow Garmin and/or Garmin’s counsel or support staff to verify the identity of the
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`reviewer, maintain a record of who has reviewed the source code and when said review has
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`occurred, and monitor or watch said reviewer at all times during the remote review, and iii) will
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`not attempt to transfer, copy, or screen capture any of the source code, or otherwise make improper
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`use of the remote review.
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`4.
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`Any violation of such certifications made pursuant to paragraph 3 above shall
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`constitute a violation of the Protective Order (Dkt. 51).
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`5.
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`The remote source code review will be otherwise governed by the Protective Order
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`(Dkt. 51), subject to the modifications set forth herein as necessary to facilitate remote review.
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`6.
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`The parties shall have the right to revisit the propriety and need for this stipulation
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`and for remote source code review as the circumstances surrounding the COVID-19 pandemic
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`continue to evolve.
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`IT IS SO STIPULATED.
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` 2
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`Case 6:17-cv-01217-EFM-ADM Document 114 Filed 05/04/21 Page 3 of 3
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`FOR DEFENDANTS GARMIN INTERNATIONAL, INC. and GARMIN USA, INC.:
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`DATED: May 4, 2021
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`Respectfully submitted,
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`
`/s/ Megan J. Redmond
`Megan J. Redmond, KS Bar #21999
`Adam P. Seitz, KS Bar #21059
`Caroline A Bader, KS Bar #24436
`Clifford T. Brazen, KS Bar #27408
`ERISE IP, P.A.
`7015 College Blvd., Suite 700
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`megan.redmond@eriseip.com
`adam.seitz@eriseip.com
`carrie.bader@eriseip.com
`cliff.brazen@eriseip.com
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`Attorneys for Defendants Garmin International,
`Inc. and Garmin USA, Inc.
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`CERTIFICATE OF SERVICE
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`I hereby certify that on May 4, 2021, a true and correct copy of the foregoing document
`was filed with the Clerk of the Court using CM/ECF and that all counsel of record who are
`deemed to have consented to electronic service are being served with a copy of this document via
`the Court’s CM/ECF system accordingly.
`
`By: /s/ Megan J. Redmond
` Megan J. Redmond
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`
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` 3
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