`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`SOUTHERN DIVISION
`
`
`IN RE NEO WIRELESS, LLC
`PATENT LITIG.
`
`Case No. 2:22-md-03034-TGB
`HON. TERRENCE G. BERG
`JURY TRIAL DEMANDED
`
`STIPULATED SUPPLEMENTAL PROTECTIVE ORDER
`REGARDING NON-PARTY MERCEDES
`
`WHEREAS, the Court entered a Protective Order in this action on October
`
`
`
`18, 2022;
`
`WHEREAS, non-parties Mercedes-Benz USA, LLC and Mercedes-Benz
`
`AG (together, “Mercedes”) have certain CONFIDENTIAL INFORMATION that
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`has been or may be produced by Plaintiff Neo Wireless, LLC to Defendants
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`(together, the “Parties”) in this action (“Mercedes Confidential Information”);
`
`WHEREAS the Parties and Mercedes have agreed to certain terms in
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`addition to those included in the Protective Order to protect Mercedes Confidential
`
`Information;
`
`IT IS HEREBY ORDERED that documents that incorporate Mercedes
`
`Confidential Information produced in this action that are designated as “HIGHLY
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`CONFIDENTIAL – ATTORNEYS’ EYES ONLY” shall be subject to the
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`following restrictions:
`
`1
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`
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`Case 2:22-md-03034-TGB ECF No. 285, PageID.30981 Filed 08/29/24 Page 2 of 3
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`1. Mercedes Material. “Mercedes Material” is material that has been
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`designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” that
`
`reflects Mercedes Confidential Information, including those documents bearing
`
`Bates Nos. NEO-AUTO_0104908 – NEO-AUTO_0104946; NEO-
`
`AUTO_0105853 – NEO-AUTO_0110370; NEO-AUTO_0110384 – NEO-
`
`AUTO_0110410; NEO-AUTO_0110421 – NEO-AUTO_0110440; NEO-
`
`AUTO_0110507 – NEO-AUTO_0110589; NEO-AUTO_0110670 – NEO-
`
`AUTO_0110671; NEO-AUTO_0110771 – NEO-AUTO_0110776; NEO-
`
`AUTO_0112364-NEO-AUTO_0112457; NEO-AUTO_0112474-0112505; NEO-
`
`AUTO_0112534 – NEO-AUTO_0113148; NEO-AUTO_0013150-NEO-
`
`AUTO_0113210; NEO-AUTO_0113212 – NEO-AUTO_0113228 as well as
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`information copied or extracted therefrom.
`
`2.
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`Relationship to Other Protective Orders. This Supplemental Protective
`
`Order is a supplement to any other protective order in this action. Any use of
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`Mercedes Material remains subject to all existing restrictions.
`
`3.
`
`Use of Mercedes Material at Hearing or Trial. The parties will give
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`Mercedes prior notice of, and an opportunity to object to, any intended use of the
`
`Mercedes Material at any hearing or trial in this case. Said notice shall (a) be
`
`served by facsimile or email on outside counsel for Mercedes at least five (5)
`
`business days prior to the hearing or first day of trial, (b) identify the Mercedes
`
`2
`
`
`
`Case 2:22-md-03034-TGB ECF No. 285, PageID.30982 Filed 08/29/24 Page 3 of 3
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`Material with specificity while redacting any other Party’s confidential business
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`information and (c) identify the measures the party intends to rely upon to protect
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`the Mercedes Material when used at any hearing or trial consistent with this
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`Supplemental Protective Order. This section shall not limit in any way the use of
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`Mercedes Material during the cross-examination of any witness otherwise
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`permitted access to such Mercedes Material, as long as the parties take all
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`necessary steps to protect and maintain the confidentiality of any such Mercedes
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`Material. If Mercedes moves to seal the court or transcript due to the planned use
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`of any Mercedes Material at any hearing or trial, the Parties will not oppose such
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`motion.
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`IT IS SO ORDERED.
`
`
`DATED: August 29, 2024
`
`
`
`s/Terrence G. Berg
`TERRENCE G. BERG
`UNITED STATES DISTRICT JUDGE
`
`
`
`3
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`
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