Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 1 of 14 PageID #:899
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
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`No. 12 C 8450
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`Hon. Joan B. Gottschall
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`OCEAN TOMO, LLC,
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` Plaintiff-Counterdefendant,
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`vs.
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`JONATHAN BARNEY and
`PATENTRATINGS, LLC,
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` Defendants-Counterplaintiffs.
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`STIPULATED PROTECTIVE ORDER REGARDING
`CONFIDENTIALITY OF DISCOVERY MATERIALS
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`Whereas, the Parties have stipulated that certain discovery material be treated as
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`confidential, and upon good cause appearing, IT IS HEREBY ORDERED:
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`I.
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`Proceedings and Information Governed.
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`1.
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`This Order and any amendments or modifications hereto (together, the
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`“Protective Order”) shall govern the disclosure and use by a receiving party of any
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`document (including electronic documents), information (including electronically stored
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`information), and/or testimony (a) produced, disclosed, and/or provided by a Party in
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`discovery, or (b) produced, disclosed, and/or provided by a non-party in discovery. The
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`documents, information, and testimony protected by this Protective Order includes, but are
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`not limited to, documents and information produced, disclosed, and/or provided in
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`connection with answers to interrogatories, answers to requests for admission, and responses
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`to requests for production of documents; deposition transcripts and videotapes; deposition
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`exhibits; compiled or un-compiled source code; and other records or writings or things
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`produced, given, or filed in this action that are designated by a Party as “Confidential” or
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`Page 1 of 14
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`PATENTRATINGS EXHIBIT 2004
`OCEAN TOMO v. PATENTRATINGS
`CBM2015-00157
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 2 of 14 PageID #:900
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`“Confidential – Prosecution Bar” in accordance with the terms of this Protective Order, as
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`well as any copies, excerpts, abstracts, analyses, summaries, descriptions, or other forms of
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`recorded information containing, reflecting, or disclosing such information (together,
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`“Discovery Materials”). Ocean Tomo, LLC, Jonathan Barney, and PatentRatings, LLC, as
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`well as their officers, directors, employees, agents, and legal counsel, are referred to as the
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`“Parties” for the purposes of this Protective Order.
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`II.
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`Designation and Maintenance of Discovery Materials as Confidential Or
`Confidential – Prosecution Bar.
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`2.
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`For purposes of this Protective Order, the “Confidential” designation may be used
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`when Discovery Materials contain or constitute sensitive personal information; trade secrets;
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`non-public information relating to commercial research or development, business or marketing
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`strategies, data, and analyses, technical specifications, and vendor relationships; non-publicly
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`available pricing and financial information; commercial, financial, budgeting and/or accounting
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`information; new product information; technical know-how; product development; marketing
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`and pricing strategies; compilations of industry data and consumer needs, habits and preferences;
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`intellectual property and other technical information; non-published financial and sales
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`information; information about existing customers; marketing studies; performance and
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`projections; business strategies; decisions and/or negotiations; personnel compensation;
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`evaluations and other employment information; and confidential and proprietary information
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`about affiliate, parents, subsidiaries and third parties with whom the parties to this action have
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`had business relationships which a producing party in good faith so designates because of its
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`view that the information or any information derived therefrom contains or reflect confidential
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`commercial information; and information required by law or agreement to be kept confidential.
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`In the event of information required by agreement to be kept confidential, the party designating
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 3 of 14 PageID #:901
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`the information as “Confidential” must identify, within a reasonable period of time, the
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`agreement or agreements which it contends requires such information to be kept confidential.
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`The Parties shall treat the item(s) as confidential unless and until the Court determines otherwise.
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`3.
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`Discovery Materials produced or disclosed during the course of this litigation
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`within the scope of paragraph 2 may be designated by the producing Party as containing
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`confidential information by placing on each page and each thing, in a manner that will not
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`interfere with its legibility, the legends: “CONFIDENTIAL” and/or “SUBJECT TO
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`PROTECTIVE ORDER.” Where Confidential Material is produced in a non-paper medium
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`(e.g., video tapes, audio tapes, and electronic documents, data, and/or files), the confidentiality
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`notice above should be placed on the medium, if possible, and its container, if any, so as to
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`clearly give notice of the designation. In the event that electronic documents, data, and/or files
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`are produced that do not readily permit the foregoing legends to be placed on each page, the
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`Parties shall negotiate in good faith to reach a further agreement regarding the manner of
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`designation and the handling of such Discovery Materials, which shall be consistent with the
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`terms of this Protective Order.
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`4.
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`Except for documents produced for inspection, designation of confidential
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`Discovery Materials shall be made before, or at the time of, production or disclosure. In the
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`event that documents are produced for inspection, such documents may be produced for
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`inspection before being marked “CONFIDENTIAL.” Once specific documents have been
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`designated for copying, any documents containing confidential information will then be marked
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`“CONFIDENTIAL” after copying but before delivery to the Party who inspected and
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`designated the documents. There will be no waiver of confidentiality by the inspection of
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`confidential documents before they are copied and marked “CONFIDENTIAL” pursuant to
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`this procedure.
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`5.
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`A Party may designate
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`information disclosed at a deposition as
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`“CONFIDENTIAL” by requesting the reporter to so designate the transcript or any portion
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`thereof at the time of the deposition. If no such designation is made at the time of the deposition,
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`any Party may thereafter designate the deposition or portions thereof as “CONFIDENTIAL” as
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`long as such designation is made in writing and presented to the other Parties and to the court
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`reporter within 30 days of the deposition. Each Party and the court reporter shall attach a copy of
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`any final and timely written designation notice to the transcript and each copy thereof in its
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`possession, custody, or control, and the portions designated in such notice shall thereafter be
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`treated in accordance with this Protective Order. Any testimony that describes a document that
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`has been designated as “CONFIDENTIAL” shall also be deemed to be designated as such.
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`Counsel for any Disclosing Party shall have the right to exclude from oral depositions, other than
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`the deponent, deponent’s counsel(s), the reporter, and videographer (if any), any person who is
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`not authorized by this Protective Order to receive documents or information designated
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`“Confidential.” Such right of exclusion shall be applicable only during periods of examination
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`or testimony directed to or comprising Confidential Material. The Court Reporter or other
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`person recording the proceedings shall segregate any portion of the transcript of the deposition or
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`hearing which has been stated to contain Confidential Material and may furnish copies of these
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`segregated portions, in a sealed envelope, only to the deponent, to the Court, and to counsel for
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`the parties bound by the terms of this Protective Order. The Court Reporter may be asked to
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`prepare Confidential or non-Confidential versions of the transcript, as appropriate.
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`6.
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`For purposes of this Protective Order, the “Confidential – Prosecution Bar”
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`designation may be used when Discovery Materials contain or constitute pending unpublished
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`patent applications, current
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`information
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`technology processes, ongoing
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`research and
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`development projects, and/or uncited prior art. The Parties shall treat the item(s) as confidential
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`unless and until the Court determines otherwise.
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`III.
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`Inadvertent Failure to Designate.
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`7.
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`The inadvertent failure to designate Discovery Materials as “CONFIDENTIAL”
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`or “CONFIDENTIAL – PROSECUTION BAR” will not be deemed to waive a later claim as to
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`their confidential nature, or to stop the producing Party from so designating such Discovery
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`Materials at a later date in writing and with particularity. Notwithstanding anything herein to the
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`contrary, any Discovery Materials received by a Party that have not been designated as
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`confidential shall not be considered confidential for purposes of this Protective Order until such
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`time as the receiving Party receives notice in writing from the producing Party within a
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`reasonable time of the change in the designation.
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`IV. Disclosure and Use of Confidential Discovery Materials.
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`8.
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`All Discovery Materials produced in this litigation may only be used for purposes
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`of the litigation between the Parties (including the pending action between the Parties in the
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`Circuit Court of Cook County, Illinois), and not for any other purpose. Discovery Materials
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`designated as “CONFIDENTIAL” or “CONFIDENTIAL – PROSECUTION BAR” may only be
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`shown to others as set forth in this Protective Order.
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`9.
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`The Parties shall not disclose or permit the disclosure of any Discovery
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`Materials designated as “CONFIDENTIAL” or “CONFIDENTIAL – PROSECUTION BAR”
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`under this Protective Order to any other person or entity, except as expressly contemplated
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`herein, including in the following circumstances:
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`a.
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`Disclosure may be made to court reporters engaged for depositions and
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`those persons, if any, specifically engaged for the limited purpose of
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`making photocopies.
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`b.
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`Disclosure may be made to the Parties’ respective in-house and outside
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`counsel, and to employees of such counsel to whom disclosure is
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`c.
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`d.
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`reasonably necessary for this litigation.
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`Disclosure may be made to Mr. Barney.
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`Disclosure may be made to employees, officers, and agents of Ocean
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`Tomo, LLC and PatentRatings, LLC to whom disclosure is reasonably
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`necessary for this litigation.
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`e.
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`Disclosure may be made to consultants, investigators, or experts
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`employed by the Parties to assist in the preparation and trial of the
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`lawsuit. Before disclosure to any consultant, investigator, or expert, the
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`individual must be informed of and agree in writing to be subject to the
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`provisions of this Order requiring that the Discovery Materials received be
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`held in confidence, and must execute the “Acknowledgement and
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`f.
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`g.
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`Agreement to be Bound,” attached hereto as Exhibit A.
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`The author or recipient of such Discovery Materials.
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`During depositions, witnesses in the action when disclosure is
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`reasonably necessary and who have signed the “Acknowledgement and
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`Agreement to be Bound,” unless otherwise agreed by the designating
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`Party or ordered by the Court.
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`h.
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`Disclosure may be made to the Court.
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`10.
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`Except as provided in paragraph 9 above or otherwise herein, the Parties
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`shall keep all Discovery Materials designated as “CONFIDENTIAL” or “CONFIDENTIAL
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`– PROSECUTION BAR” that are received under this Protective Order secure within their
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`exclusive possession and shall take reasonable efforts to place such Discovery Materials in a
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`secure area and appropriately identified so as to allow access to such information only to such
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`persons and under such terms as is permitted under this Protective Order.
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`11. All copies, duplicates, pleadings, extracts, summaries, or descriptions of
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`Discovery Materials designated as confidential under this Order, or any portion thereof, shall
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`be immediately affixed with the legend “CONFIDENTIAL” or “CONFIDENTIAL –
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`PROSECUTION BAR” if that legend does not already appear.
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`12.
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`Confidential or Confidential – Prosecution Bar Discovery Materials may be
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`disclosed to a person, not already allowed access to such information under this Order, if: (a) the
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`Discovery Materials were written or were previously received by the person; (b) the Discovery
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`Materials were written or received by a director, officer, employee, or agent of the entity for
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`which the person is testifying as a Fed. R. Civ. P. 30(b)(6) designee, or (c) counsel for the Party
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`designating the Discovery Materials agrees in writing or otherwise on the record that the
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`materials may be disclosed to the person. Disclosure of Discovery Materials pursuant to this
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`paragraph shall not constitute a waiver of the confidential status of the materials so disclosed.
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`13.
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`Should any document or information designated as “CONFIDENTIAL” or
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`“CONFIDENTIAL – PROSECUTION BAR” be disclosed, through inadvertence or otherwise,
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`to any person or party not authorized under this Protective Order, then the party responsible for
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`the disclosure shall use its best efforts to retrieve such document and, if unable to do so, inform
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`the Party that produced the Discovery Material of the disclosure.
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 8 of 14 PageID #:906
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`V.
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`Challenging Designations.
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`14. A receiving Party may, in good faith, challenge a producing Party’s designation at
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`any time. The burden of proving confidentiality and/or other designation remains with the
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`Party asserting such designation.
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`15. Any Party that wishes to challenge a designation shall first request in writing that
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`the designating Party change the designation. That writing shall provide sufficient identification
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`so that the designating Party can identify the Discovery Materials whose designation is being
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`challenged. If the Discovery Materials being challenged are documents having identification
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`numbers, the documents shall be identified by those numbers. The writing also shall describe the
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`reason(s) that the challenging Party believes the designation should be changed.
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`16.
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`In the event that a designating Party does not voluntarily change the identified
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`designation within seven (7) days of the written request provided for in Paragraph 15, the
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`challenging Party may request a meet-and-confer with the designating Party. The meet-and-
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`confer shall occur within fourteen (14) days of the request. The meet-and-confer shall include
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`either an in-person or telephone dialogue between counsel for the challenging Party and the
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`designating Party, and counsel shall attempt in good faith to resolve any disputes without the
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`need for court intervention. During the meet-and-confer, the challenging Party must explain the
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`basis for its belief that the designation was not proper and must give the designating Party an
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`opportunity to review the designated Discovery Materials, to reconsider the circumstances, and,
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`if no change in designation is offered, to explain the basis for the chosen designation. A
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`challenging Party may proceed to the next stage of the challenge process only if it has engaged in
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`this meet-and-confer process first, or has made a good faith, but unsuccessful, effort to do so.
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 9 of 14 PageID #:907
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`17.
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`If the Parties are unable to reach agreement regarding the challenge, the
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`challenging Party may thereafter seek a Court Order to alter the status of the designated
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`Discovery Materials. Said motion should identify the materials that are the subject of the
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`challenge and set forth in detail the basis for the challenge. Until the Court rules on the
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`challenge, all Parties shall continue to afford the Discovery Materials in question the level of
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`protection to which it is entitled under the designating Party’s designation.
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`VI. Non-Party Discovery Materials.
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`18.
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`The existence of this Order shall be disclosed to any person producing documents,
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`tangible things, or testimony in this action who may reasonably be expected to desire
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`confidential treatment for such Discovery Materials. Any such person may designate Discovery
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`Materials confidential pursuant to this Order.
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`VII. Disclosure of Privileged Discovery Materials.
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`19.
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`Notwithstanding anything in this Order, the burden of establishing the existence
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`and applicability of the attorney-client privilege, the attorney work-product doctrine, and/or other
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`applicable privileges and protections, and of complying with the requirements of Fed. R. Civ. P.
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`26(b)(5)(A), remains with the Party asserting such privilege or protection.
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`20.
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`If a party inadvertently produces Discovery Materials that it later discovers, or in
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`good faith later asserts, contain information that is protected from disclosure by the attorney-
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`client privilege or some other applicable privilege or doctrine, the production of such Discovery
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`Materials will not be presumed to constitute a waiver of any applicable privileges or other
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`protections. In such circumstances, the Producing Party must notify all parties in writing of the
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`inadvertent production and the basis for the privilege or other protection from disclosure, and
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`request in writing the return or confirmed destruction of the privileged or protected information.
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`21. Within five (5) days of receiving such notification, all receiving parties must
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`return or confirm destruction of all such materials, including copies and/or summaries thereof.
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`22.
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`Should a receiving party contest the applicability of a privilege or other protection
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`asserted with respect to an inadvertently produced document or other Discovery Materials
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`withheld on the basis of the attorney-client privilege, the attorney work-product doctrine, and/or
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`some other applicable privilege or doctrine, the receiving party shall first request in writing that
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`the designating Party produce the withheld documents. That writing shall provide sufficient
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`identification so that the designating Party can identify the Discovery Materials being
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`challenged. If the Discovery Materials being challenged are documents having identification
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`numbers, the documents shall be identified by those numbers. The writing also shall describe the
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`reason(s) that the challenging Party believes the privilege or doctrine is inapplicable, and/or that
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`the reasons(s) that the designating Party has failed to establish the existence and applicability of
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`the privilege or doctrine.
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`23.
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`In the event that a designating Party does not voluntarily produce the withheld
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`documents within seven (7) days of the written request provided for in Paragraph 22, the
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`challenging Party may request a meet-and-confer with the Party asserting the privilege. The
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`meet-and-confer shall occur within fourteen (14) days of the request. The meet-and-confer shall
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`include either an in-person or telephone dialogue between counsel for the challenging Party and
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`the designating Party, and counsel shall attempt in good faith to resolve any disputes without the
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`need for court intervention. During the meet-and-confer, the challenging Party must explain the
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`basis for its belief that the privilege or other doctrine is inapplicable and must give the
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`designating Party an opportunity to review the designated Discovery Materials, to reconsider the
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`circumstances, and, the designating Party persists in its assertion of the privilege or other
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 11 of 14 PageID #:909
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`doctrine, to explain the basis for the privilege or other doctrine. A challenging Party may proceed
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`to the next stage of the challenge process only if it has engaged in this meet-and-confer process
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`first, or has made a good faith, but unsuccessful, effort to do so.
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`24.
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`If the Parties are unable to reach agreement regarding the challenge, the
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`challenging Party may thereafter seek a Court Order requiring production of the challenged
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`Discovery Materials. Said motion should identify the materials that are the subject of the
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`challenge and set forth in detail the basis for the challenge.
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`VIII. No Prejudice.
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`25.
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`Stipulating to this Protective Order, producing or receiving confidential
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`information, designating or not designating Discovery Materials, objecting or not objecting to a
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`producing Party’s designation of Discovery Materials, or otherwise complying with the terms of
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`this Protective Order, shall not (a) operate as a waiver or modification of, or prejudice in any
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`way the rights of any Party to enforce or insist upon the performance of any other agreement or
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`obligation between the Parties concerning the receipt, disclosure, and/or use of any documents or
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`information, (b) operate as an admission by any Party that any particular confidential information
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`contains or reflects trade secrets or any other type of confidential or proprietary information,
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`(c) prejudice the rights of a Party to object to requests for production or disclosure of information
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`or material that the Party does not consider to be within the scope of discovery, or that otherwise
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`are objectionable; (d) prejudice the rights of a Party to object to the admission of information or
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`material into evidence, (e) prejudice the rights of a Party to seek a determination by the Court
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`that particular materials be produced, (f) prejudice the rights of a Party to object to the
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`production of documents or information unless and until a further protective order is entered;
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`(g) otherwise prejudice the rights of a Party to apply to the Court for further protective orders, or
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`(h) prevent the Parties from agreeing in writing to alter or waive the provisions or protections
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`provided for herein with respect to any particular information or material.
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`IX. Other Proceedings.
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`26.
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`If a receiving Party is served with a subpoena, order, or other compulsory process
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`that would compel disclosure of any Discovery Materials designated confidential under the terms
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`of this Protective Order, the receiving Party must so notify the designating Party in writing (by
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`email, if possible) immediately and in no event more than three (3) court days after receiving the
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`subpoena, order, or other compulsory process. Such notification must include a copy of the
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`subpoena, order, or other compulsory process. The receiving Party also must immediately
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`inform, in writing, the party who caused the subpoena, order, or other compulsory process to
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`issue that the material covered by the subpoena, order, or other compulsory process is the subject
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`of this Protective Order, and deliver a copy of this Protective Order to that party.
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`27.
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`The purpose of imposing these duties is to alert the interested Parties to the
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`existence of this Protective Order and to afford the designating Party an opportunity to try to
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`protect its confidentiality interests in the court or other forum from which the subpoena, order, or
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`other compulsory process issued. The designating Party shall bear its own fees and the expenses
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`of seeking protection in that forum of its Discovery Materials – and nothing in these provisions
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`should be construed as authorizing or encouraging a receiving Party in this action to disobey a
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`lawful directive from another court or forum.
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`X.
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`Prosecution Bar
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`28.
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`Absent written consent from the producing Party, any individual who receives
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`access to documents and/or information designated “CONFIDENTIAL – PROSECUTION
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`BAR” under this Protective Order shall not be involved in the prosecution of patents or patent
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`Case: 1:12-cv-08450 Document #: 73 Filed: 05/19/14 Page 13 of 14 PageID #:911
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`applications with respect to any inventions, innovations, products, and/or processes embodied by
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`any documents and/or information marked “CONFIDENTIAL – PROSECUTION BAR” before
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`any foreign or domestic agency, including the United States Patent and Trademark Office (“the
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`Patent Office”). For purposes of this paragraph, “prosecution” includes directly or indirectly
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`drafting, amending, advising, or otherwise affecting the scope or maintenance of patent claims.
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`To avoid any doubt: (a) “prosecution” as used in this paragraph does not include challenging or
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`defending a patent in a litigation proceeding or in an administrative proceeding before a domestic
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`or foreign agency (including, but not limited to, a reissue protest, ex parte reexamination or inter
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`partes reexamination); and (b) nothing herein is intended to or shall be interpreted as precluding
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`Mr. Barney or PatentRatings from receiving or reviewing any documents and/or information
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`marked “CONFIDENTIAL – PROSECUTION BAR” or using such documents and/or
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`information in connection with taking any action to defend the validity and enforceability of any
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`patent currently held by Mr. Barney, PatentRatings, and/or any other entity (with the exception
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`of Ocean Tomo) in which Mr. Barney has an interest, directly or indirectly. This Prosecution Bar
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`shall begin when access to “CONFIDENTIAL – PROSECUTION BAR” information is first
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`received by the affected individual and shall end two (2) years after final termination of this
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`action.
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`XI. Miscellaneous
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`29.
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`After final disposition of both this action and any related action between the
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`Parties in the Circuit Court of Cook County, Illinois, including any appeals, and within ninety
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`(90) days of a written request from the producing Party, the receiving Party shall return promptly
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`to the Party from whom they were obtained, all documents, other than attorney work-product,
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`which have been designated “Confidential” or “Confidential – Prosecution Bar” or destroy same
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`upon request; and return or destroy all copies made thereof, including all documents, or copies
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`provided by a Party to any other person. At the conclusion of the 90-day period, upon written
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`request, the Parties shall represent in writing that to his or her knowledge and belief the party has
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`either returned or destroyed all Confidential or Confidential – Prosecution Bar material in
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`accordance with this Protective Order.
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`30.
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`The Court retains jurisdiction even after termination of this action to enforce this
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`Protective Order and to make such amendments, modifications, deletions and additions to this
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`Protective Order as the Court may from time to time deem appropriate. The disclosing parties
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`reserve all rights to apply to the Court at any time, before or after termination of this action, for
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`an order: (i) modifying this Protective Order, (ii) seeking further protection against discovery or
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`use of Confidential or Confidential – Prosecution Bar Material or other documents or
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`information, or (iii) seeking further production, discovery, disclosure, or use of claimed
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`Confidential or Confidential – Prosecution Bar Material or other documents or information.
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` N T E R:
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`Dated: May 19, 2014
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`MARY M. ROWLAND
`United States Magistrate Judge
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