Case 3:22-cv-02868-S Document 36 Filed 06/26/23 Page1of20 PagelD 519
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`IN THE UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF TEXAS
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`DALLAS DIVISION
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`R2 Solutions LLC,
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`Plaintiff,
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`y
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`Crvil Action No. 3:22-cv-02761-S
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`Hilton Domestic Operating CompanyInc.,
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`Jury Trial Demanded
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`Defendant.
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`R2 Solutions LLC,
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`Vv.
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`7-Eleven, Inc.,
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`R2 Solutions LLC,
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`v.
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`Plaintiff,
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`Civil Action No. 3:22-cv-02868-S
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`Jury Trial Demanded
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`Defendant.
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`Plaintiff,
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`Civil Action No. 3:22-cv-02869-S
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`Jury Trial Demanded
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`Southwest Airlines Co.,
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`Defendant.
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`PROTECTIVE ORDER
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`Proceedings and Information Governed.
`1. This Order (“Protective Order”) is made under Fed. R. Civ. P. 26(c). It governs any document, |
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`information, or other thing furnished by any party fo any other party, and it includes any nonparty who
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`receives a subpoena in connection with this action. The information protected includes, but is not limited
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`to: answers to interrogatories; answers to requests for admission; responses to requests for production of
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`documents; deposition transcripts and videotapes; deposition exhibits; and other documents or things
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`produced, given, or filed in this action that are designated by a party as “Confidential Information,”
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`“Confidential Attorney Eyes Only Information,” or “Confidential Attorney Eyes Only Source Code”in
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`accordance with the terms of this Protective Order (collectively, “Designated Material”), as well as to any
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`copies, excerpts, abstracts, analyses, summaries, descriptions, or other forms of recorded information
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`containing, reflecting, or disclosing such information.
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`Designation and Maintenance of Information.
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`2. For purposes ofthis Protective Order, (a) the “Confidential Information” designation meansthat
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`the document is comprised of trade secrets or commercial information that is not publicly known andis
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`of technical or commercial advantage to its possessor, in accordance with Fed. R. Civ. P. 26(c)(1)(G), or
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`other information required by law or agreement to be kept confidential, (b) the “Confidential Attorney
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`Eyes Only” designation means that the document is comprised of information that the producing party
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`deems especially sensitive, which may include, but
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`is not
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`limited to, confidential research and
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`development,
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`financial,
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`technical, marketing, or any other sensitive trade-secret
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`information, or
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`information capable of being utilized for the preparation or prosecution of a patent application dealing
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`with such subject matter, and (c) the “Confidential Attorney Eyes Only Source Code” designation means
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`that the documentincludes computer source code and/or live data (that is, data as it exists residing in a
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`database or databases) (“Source Code Material”). Confidential Information, Confidential Attorney Eyes
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`Only Information, and Confidential Attorney Eyes Only Source Code does not include, and this Protective
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`Order does not apply to, information that is already in the knowledge or possession of the party to whom
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`disclosure is made unless that party is already bound by agreement not to disclose such information, or
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`information that has been disclosed to the public or third persons in a manner making such information
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`no longer confidential.
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`3. Documents and things produced during the course ofthis litigation within the scope of paragraph
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`2(a) above, may be designated by the producing party as containing Confidential Information by placing
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`on each page and each thing a legend substantially as follows:
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`CONFIDENTIAL INFORMATION
`SUBJECT TO PROTECTIVE ORDER
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`Documents and things produced during the course ofthis litigation within the scope of paragraph 2(b)
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`above may be designated by the producing party as containing Confidential Attorney Eyes Only
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`Information by placing on each page and each thing a legend substantially as follows:
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`CONFIDENTIAL ATTORNEY EYES ONLY INFORMATION
`SUBJECT TO PROTECTIVE ORDER
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`Documents and things produced during the course of this litigation within the scope of paragraph 2(c)
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`above may be designated by the producing party as containing Confidential Attorney Eyes Only Source
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`Code by placing on each page and each thing a legend substantially as follows:
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`CONFIDENTIAL ATTORNEY EYES ONLY SOURCE CODE
`SUBJECT TO PROTECTIVE ORDER
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`4. A party may designate information disclosed at a deposition as Confidential Information,
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`Confidential Attorney Eyes Only Information, or Confidential Attorney Eyes Only Source Code by
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`requesting the reporter to so designate the transcript or any portion of the transcript at the time of the
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`deposition.If no such designation is made at the time of the deposition, any party will have fourteen (14)
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`calendar days after receipt of the deposition transcript to designate, in writing to the other parties and to
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`the court reporter, whether any portion of the transcript is to be designated as Confidential Information,
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`Confidential Attorneys Eyes Only Information, or Confidential Attorney Eyes Only Source Code. If no
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`such designation is madeat the deposition or within this fourteen (14) calendar day period (during which
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`period, the transcript must be treated as Confidential Attorneys Eyes Only Information, unless the
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`disclosing party consents to less confidential treatment of the information), the entire deposition will be
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`Confidential Attorney Eyes Only Source Code (subject to paragraph 5 below). Each party and the court
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`reporter must attach a copy of any final and timely written designation notice to the transcript and each
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`copy of the transcript in its possession, custody or control, and the portions designated in such notice must
`thereafter be treated in accordance with this Protective Order. It is the responsibility of counsel! for each
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`party to maintain materials containing Confidential Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code in a secure manner and appropriately
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`identified so as to allow access to such information only to such persons and under such terms as is
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`permitted under this Protective Order.
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`Inadvertent Failure to Designate,
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`5. The inadvertent failure to designate or withhold any information as confidential or privileged
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`will not be deemed to waive a later claim as to its confidential or privileged nature, or to stop the producing
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`party from designating such information as confidential at a later date in writing and with particularity.
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`The information must be treated by the receiving party as confidential from the time the receiving party
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`is notified in writing of the change in the designation.
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`Challenge to Designations.
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`6. A receiving party may challenge a producing party’s designation at any time. Any receiving
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`party disagreeing with a designation may request in writing that the producing party change the
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`designation. The producing party will then haveten (10) business days after receipt of a challenge notice
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`to advise the receiving party whetherornotit will change the designation. If the parties are unable to reach
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`agreement after the expiration of this ten (10) business day time frame, and after the conference required
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`under Local Rule 7.1(a), the receiving party may at any time thereafter seek an order to alter the
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`confidential status of the designated information. Until any dispute under this paragraph is ruled upon by
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`the presiding judge, the designation will remain in full force and effect, and the information will continue
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`to be accorded the confidential treatment required by this Protective Order.
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`Disclosure and Use of Confidential Information.
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`7.
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`Information designated as Confidential
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`Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code may only be used for purposes of
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`preparation, trial, and appeal ofthis action. Confidential Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code may not be used under any circumstances
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`for prosecuting any patent application, for patentlicensing, or for any other purpose.
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`8. Subject to paragraph 12 below, Confidential Information may be disclosed by the receiving
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`party only to the following individuals, provided that such individuals are informed of the termsof this
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`Protective Order:
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`(a) one (1) employeeof the receiving party whois required in goodfaith to provide assistance
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`in the conductofthis litigation, including any settlement discussions, and whois identified as such in
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`writing to counsel for the designating party in advance of the disclosure. Defendants’ designated
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`employee under this paragraph shall not have access to any other Defendant’s Designated Material;
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`(b) two (2) in-house counsel for the receiving party who are identified as such in writing to
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`counsel for the designating party in advance of the disclosure. Defendants’ in-house counsel under
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`this paragraph shall not have access to any other Defendant’s Designated Material;
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`(c) outside counsel for the receiving party;
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`(d) supporting personnel employed by (b) and (c), such as paralegals, legal secretaries, data-
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`entry clerks, legal clerks, and private photocopying andlitigation support services;
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`(e) experts or consultants retained for the purposesofthis litigation; and
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`(f) any persons requested by counsel to furnish services such as document coding, image
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`scanning, mocktrial, jury profiling, translation services, court-reporting services, demonsttative-
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`exhibit preparation, or the creation of any computer database from documents.
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`9, Subject to paragraph 12 below, Confidential Attorney Eyes Only Information may be disclosed
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`by the receiving party only to the following individuals, provided that such individuals are informed of
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`the terms of this Protective Order:
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`(a) outside counsel for the receiving party;
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`(b) paralegals, legal secretaries, data-entry clerks, legal clerks, private photocopying and
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`litigation support services employed by outside counsel;
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`(c) experts or consultants retained for the purposesofthis litigation;
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`(d) any persons requested by counsel to furnish services such as document coding, image
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`scanning, mocktrial, jury profiling, translation services, court-reporting services, demonstrative-
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`exhibit preparation, or the creation of any computer database from documents; and
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`(e) those individuals designated in paragraph 14.
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`10. Subject to paragraph 12 below, Confidential Attorney Eyes Only Source Code may be
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`disclosed by the receiving party only to the following individuals, provided that such individuals are
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`informed of the terms of this Protective Order:
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`(a) outside counsel for the receiving party;
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`(b) paralegals,
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`legal secretaries, data-entry clerks, and legal clerks empioyed by outside
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`counsel;
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`(c) up to two (2) outside consultants or experts! (Le., not existing employeesoraffiliates of a
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`party or an affiliate of a party) retained for the purposes ofthis litigation, provided that such experts
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`or consultants are not involved in competitive decision-making on behalf of a party or a competitor of
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`a party; and
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`| For the purposes of this paragraph, an outside consultant or expert is defined to include the outside
`consultant’s or expert’s direct reports and other support personnel, such that the disclosure to a consultant
`or expert who employs others within his or her firm to help in his or her analysis shail countas a disclosure
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`(d) those individuals designated in paragraph 14.
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`For Confidential Attorney Eyes Only Source Code, the following additional restrictions apply:
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`(i) Source Code Material shall be loaded on a single, standalone, non-networked personal
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`computerthat is password protected, maintained in a secure, locked area, and connected to two large
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`screen monitors, a mouse, and a keyboard (“Source Code Computer”). Absent specific agreement by
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`the producing party, use or possession of any input/output device or other electronic device (e.g., USB
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`memory stick, cameras or any camera-enabled device, CDS, portable hard drive, laptops, cellular
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`telephones, smartphones, voice recorders, smart watches, or any device capable of photographing or
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`recording information,etc.) is prohibited while in the secured, locked area containing the Source Code
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`Computer, and no recordable media or recordable devices shall be permitted into the secure source
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`code reviewing room. The stand-alone computer(s) shall only be located at the offices of the producing
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`party’s outside counselor its vendors. All requests for production shall be made in Adobe PDF format
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`and placed in dated production folders. Any native source code files placed in dated production folders
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`shall not be produced.
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`(ii) The producing party may visually monitor the activities of the receiving party’s
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`representatives during any Source Code Material review, but only to ensure that no unauthorized
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`electronic records of the Source Code Materials are being created or transmitted in any way, and only
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`so long as the producing party cannot hear the receiving party or view any handwritten notes, as
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`discussed in paragraph 10(vii) below. The producing party shall have the right to confirm identities of
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`the persons accessing Source Code Material.
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`(iii) The receiving party shall make reasonable efforts to restrict its requests for such access to
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`the Source Code Computer(s) to normal business hours, which for purposes ofthis paragraphshall be
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`9:00 a.m. through 5:00 p.m. However, upon reasonable notice from the receiving party, the producing
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`party shall make reasonable efforts to accommodate the receiving party’s request for access to the
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`Source Code Computer(s) outside of normal business hours. The parties agree to cooperate in good
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`faith such that maintaining the producing party’s Source Code Material at the offices of its outside
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`counsel shall not unreasonably hinder the receiving party’s ability to efficiently and effectively
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`conduct the prosecution or defense of this litigation. The receiving party shall provide at least 3
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`business days’ notice in advance of requesting subsequent reviews.
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`(iv) The producing party shall provide the receiving party with information explaining how to
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`start, log on to, and operate the Source Code Computer(s) in order to access the produced Source Code
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`Material on the Source Code Computer(s).
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`(v) The producing party will produce Source Code Material in computer searchable format on
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`the stand-alone computer(s) as described above. The producing party shall have installed software
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`applications that are reasonably requested by the receiving party for review of the produced Source
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`Code Material. At least seven (7) business days in advance of the date upon which the receiving party
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`wishes to use the source code computerforthe first time, the receiving party shail identify the licensed
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`software tools it wishes to have installed and available for use on the source code computers, and
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`provide a properly licensed copy of the software it requests to be installed. Any costs associated with
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`acquiring licenses to request software tools shall be borne by the receiving party. In the event that
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`there are issues concerning the installation or use of such tools, the parties, and their technicalstaff,
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`shall meet and confer promptly to resolve such issues.
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`(vi) Except as otherwise allowed herein, the receiving party shall not create a copy of or
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`reproduce Source Code Material in any way exceptthat the receiving party may reproduce selected
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`excerpts of Source Code Material if such selected excerpts are reasonably necessary for the purpose
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`of any filing with the Court, the service of any pleading or other paper on anyparty, testifying expert
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`reports, consulting expert written analyses, deposition exhibits as discussed in paragraph 10(xiii)
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`below, or any draft of these documents (“Source Code Documents”), Source Code Documents shall
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`be designated “Confidential Attorney Eyes Only Source Code”either (a) in their entirety, or (b) on
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`any page containing quoted Source Code Material.
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`(vii) The receiving party shall be entitled to take handwritten notes related to the Source Code
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`Material but may not copy the Source Code Material into such notes. Any such notesshall be stamped,
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`designated, and treated as Confidential Attorney Eyes Only Source Code. For the avoidance of doubt,
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`such notes shall be considered and treated as the receiving party’s work product, and the producing
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`party shall not have any right to make copies of or otherwise review such notes. The receiving party
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`shall not be permitted to take electronic notes related to Source Code Material while in the source code
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`reviewing room.
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`(viii) A receiving party may include excerpts of Source Code Material only when necessary in
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`a pleading, exhibit, expert report, discovery document, deposition transcript, or other Court document,
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`provided that the Source Code Documents are appropriately marked under this Order, restricted to
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`those who are entitled to have access to them as specified herein, and, if filed with the Court, filed
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`under seal in accordance with the Court’s rules, procedures and orders.
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`(ix) To the extent portions of Source Code Material are quoted in a Source Code Document,
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`either (1) the entire Source Code Document will be stamped and treated as Confidential Attorney Eyes
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`Only Source Code or (2) those pages containing quoted Source Code Material will be separately
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`stamped and treated as Confidential Attorney Eyes Only Source Code.
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`(x) Exceptas set forth in paragraph 1 0(vi) above, no electronic copies of Source Code Material
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`shall be made without prior written consent of the producing party, except as necessary to create
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`documents which, pursuant to the Court’s rules, procedures and order, must be filed or served
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`electronically.
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`(xi) The receiving party may request a reasonable number’ of pages of Source Code Material
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`to be Bates-numbered and printed for purposes of case preparation activity. The receiving party may
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`not request paper copies for the purposes of reviewing the Source Code Material in the first instance.
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`Within five (5) business days of any request, the producing party will provide one (1) copy of the
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`requested material on watermarked or colored paper bearing Bates numbers and the designation
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`Confidential Attorney Eyes Only Source Code unless objected to, as discussed in paragraph 10(xii)
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`below.
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`(xii) Ifthe producing party objects that the printed portions are not reasonably necessary to any
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`case preparation activity, the producing party shall make such objection knownto the receiving party
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`within five (5) business days. If, after meeting and conferring, the producing party and the receiving
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`party cannot resolve the objection, the receiving party may seek a Court resolution of whether the
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`printed Source Code Material in question is reasonably necessary to any case preparation activity.
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`Contested Source Code Material printouts need not be producedto the receiving party until the matter
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`is resolved by the Court.
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`(xiii) The receiving party shall be permitted to make no more than four (4) photocopies of
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`printed Source Code Material. All photocopies shall be designated and clearly labeled “Confidential
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`Attorney Eyes Only Source Code,” and the receiving party shall maintain a log ofall such photocopies.
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`Outside counsel for the receiving party shall keep log(s) recording the identity of each individual to
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`whom each hard copy of each Source Code Material is provided and when it was provided to that
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`person in the first instance, and within sixty (60) days after the issuance of a final, non-appealable
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`decision resolvingall issues in this action, the receiving party must serve the log upon the producing
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`party. In addition, any outside consultants of the receiving party to whom the paper copies of the
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`2Sincea“reasonablenumber”may vary depending onthe facts of each action, the producing party and receiving
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`party shall meet and confer during the course of discovery to agree on a numberof pages of Source Code Material
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`Source Code Material were provided must certify in writing (i) that all copies of the Source Code
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`Material were destroyed or returned to the counsel who provided them the information and (ii) that
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`they will make no use of the Source Code Material, or of any knowledge gained from the source code
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`in any future endeavor.
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`(xiv) If the receiving party’s outside counsel, consultants, or experts obtain printouts or
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`photocopies of Source Code Material, the receiving party shall ensure that such outside counsel,
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`consultants, or experts keep the printouts or photocopies in a secured lockedarea in the offices of such
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`outside counsel, consultants, or expert. The receiving party may also temporarily keep the printouts or
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`photocopiesat: (a) the Court for any proceedings(s) relating to the Source Code Material, for the dates
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`associated with the proceeding(s); (b) the sites where any deposition(s) relating to the Source Code
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`Material are taken, for the dates associated with the deposition(s); and (c) any intermediate location
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`reasonably necessary to transport the printouts or photocopies (e.g., a hotel prior to a Court proceeding
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`or deposition).
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`(xv) A producing party’s Source Code Material may only be transported by the receiving party
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`at the direction of a person authorized under paragraphs 10(a) ~ (c) above to another person authorized
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`under paragraphs 1 0(a) -- (c) above via hand carry, Federal Express, or other similarly reliable courier.
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`Source Code Material may not be transported or transmitted electronically over a network of any kind,
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`including a LAN, an intranet, or the Internet, except as necessary to file or serve a document
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`electronically. Source Code Material may only be transported electronically for the purpose of Court
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`proceeding(s) or deposition(s) as set forth in paragraph 10{vi) above andis at all times subject to the
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`transport restrictions set forth herein. But, for those purposes only, the Source Code Materials may be
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`loaded onto a stand-alone computer.
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`11. Any outside counsel representing Plaintiff who accesses any of Defendant’s Confidential
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`Attorney Eyes Only Information and Confidential Attorney Eyes Only Source Code underthis Ordershall
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`not prepare, prosecute, supervise, or assist in the preparation or prosecution of any patent application
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`pertaining to the field of the invention of the patents-in-suit on behalf of Plaintiff or its acquirer, successor,
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`predecessor, during the pendency of this Action against any Defendant and for one year after its
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`conclusion, including any appeals. This provision does not prohibit counsel of record for any Party or
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`experts in this litigation from participating in or representing a Party in reexamination proceedings, Post-
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`Grant Review proceedings, Inter Partes Review proceedings, or Covered Business Method Review
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`proceedings involving the patents-in-suit, provided that Plaintiffs outside counsel who access
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`Confidential Attorney Eyes Only Information and Confidential Attorney Eyes Only Source Code, or
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`litigation experts who have accessed Confidential Attorney Eyes Only Information and Confidential
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`Attorney Eyes Only Source Code, do not advise on, consult on, prepare, draft, or edit any amendmentto
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`specifications or claims in those proceedings. To ensure compliance with the purpose ofthis provision,
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`Plaintiff shall create an “Ethical Wall” between those persons who access Confidential Attorney Eyes
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`Only Information and Confidential Attorney Eyes Only Source Code any individuals who, on behalf of
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`Plaintiff or its acquirer, successor, predecessor, prepare, prosecute, supervise, or assist in the preparation
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`or prosecution of any patent application pertaining to the field of invention of the patent-in-suit.
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`12. Further, prior to disclosing Confidential Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code to a receiving party’s proposed expert,
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`consultant, or employees, the receiving party must provideto the producing party a signed Confidentiality
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`Agreement in the form attached as Exhibit A, the resume or curriculum vitae of the proposed expert or
`consultant, the expert or consultant’s businessaffiliation, and any current and past consulting relationships |
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`in the industry. The producing party will thereafter have ten (10) business days from receipt of the
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`Confidentiality Agreement to object to any proposed individual. The objection must be made for good
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`cause and in writing, stating with particularity the reasons for the objection. Failure to object within ten
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`(10) business days constitutes approval. If the parties are unable to resolve any objection, the receiving
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`party may file a motion to resolve the matter. There will be no disclosure to any proposed individual
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`during the ten (10) business day objection period, unless that period is waived by the producing party, or
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`if any objection is made, until the parties have resolved the objection, or the presiding judge has ruled
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`upon any resultant motion.
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`13. Counsel is responsible for the adherence by third-party vendors to the terms and conditions of
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`this Protective Order. Counsel may fulfill this obligation by obtaining a signed Confidentiality Agreement
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`in the form attached as Exhibit B.
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`14. Confidential Information, Confidential Attorney Eyes Only Information, or Confidential
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`Attorney Eyes Only Source Code may be disclosed to a person whois not already allowed access to such
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`information under this Protective Orderif:
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`(a) the information was previously received or authored by the person or was authored or
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`received by a director, officer, employee, or agent of the company for which the personis testifying
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`as a designee under Fed. R. Civ. P. 30(b)(6);
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`(b) the person is the designating party, or is a director, officer, employee, consultant, or agent
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`of the designating party; or
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`(c) counsel for the party designating the material agrees that the material may be disclosed to
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`the person.
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`In the event of disclosure under this paragraph, only the reporter, the person, his or her counsel, the
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`presiding judge, and persons to whom disclosure may otherwise be made under and who are bound by
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`this Protective Order, may be present during the disclosure or discussion of the Confidential Information,
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`Confidential Attorney Eyes Only Information, or Confidential Attorney Eyes Only Source Code.
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`Disclosure of material pursuantto this paragraph does not constitute a waiver of the confidential status of
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`the material so disclosed.
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`Nonparty Information.
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`15. The existence of this Protective Order must 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 confidential
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`treatment for such documents,tangible things, or testimony. Any such person may designate documents,
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`tangible things, or testimony Confidential Information, Confidential Attorney Eyes Only, or Confidential
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`Attorney Eyes Only Source Code pursuant to this Protective Order, and such person shall be considered a
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`“producing party” underthis Protective Order.
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`Filing Documents With the Court.
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`16. If any party wishes to submit Confidential Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code to the Court, the submission must be filed
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`using the Sealed and/or Ex Parte Motion event. The word “Sealed” must appear in thetitle or caption of
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`any document intendedforfiling under seal (and any proposed order you believe should be filed under
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`seal if entered by the judge).
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`17. Producing or
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`receiving Confidential
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`Information, Confidential Attorney Eyes Only
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`Information, or Confidential Attorney Eyes Only Source Code, or otherwise complying with the terms of
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`this Protective Order, will not (a) operate as an admission by any party that any particular Confidential
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`Information, Confidential Attomey Eyes Only Information, or Confidential Attorney Eyes Only Source
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`Code contains or reflects trade secrets or any other type of confidential or proprietary information;
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`(b) prejudicethe rights of a party to object to the production of information or material that the party does
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`not consider to be within the scope of discovery; (c) prejudicethe rights of a party to seek a determination
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`by the presiding judge that particular materials be produced; (d) prejudicethe rights of a party to apply to
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`the presiding judge for further protective orders; or (e) prevent the parties from agreeing in writing to alter
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`or waive the provisionsor protections provided for in this Protective Order with respect to any particular
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`information or material.
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`Conclusion of Litigation.
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`

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`Case 3:22-cv-02868-S Document 36 Filed 06/26/23 Page15o0f20 PagelD 533
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`18. Within sixty (60) calendar daysafter final judgmentin this action, including the exhaustion of
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`all appeals, or within sixty (60) calendar days after dismissal pursuant to a settlement agreement, each
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`party or other person subject to the terms of this Protective Order is under an obligation to destroy or
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`return to the producing party all materials and documents containing Confidential
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`Information,
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`Confidential Attorney Eyes Only Information, or Confidential Attorney Eyes Only Source Code, and to
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`certify to the producing party that this destruction or return has been done. However,outside counsel for
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`any party is entitled to retain all court papers, trial transcripts, exhibits, and attorney work provided that
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`any such materials are maintained and protected in accordance with the terms of this Protective Order.
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`
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`Other Proceedings.
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`19. By entering this Protective Order and limiting the disclosure of information in this case, the
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`presiding judge does not intend to preclude another court from finding that information may be relevant
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`and subject to disclosure in another case. Any person or party subject to this Protective Order who may
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`be subject to a motion to disclose another party’s information designated Confidential Information,
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`Confidential Attorney Eyes Only Information, or Confidential Attorney Eyes Only Source Code pursuant
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`to this Protective Order must promptly notify that party of the motion so that the party may have an
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`opportunity to appear and be heard on whether that information shouldbe disclosed.
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`Remedies.
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`20. It is Ordered that this Protective Order will be enforced by the sanctions set forth in Fed. R.
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`Civ. P. 37(b) and any other sanctions as may be available to the presiding judge, including the power to
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`hold parties or other violators of this Protective Order in contempt. Ail other remedies available to any
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`person injured by a violation of this Protective Order are fully reserved.
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`Case 3:22-cv-02868-S Document 36 Filed 06/26/23 Page16of20 PagelD 534
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`21. Any party may petition the presiding judge for good cause shownif the party desires relief
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`from a term or condition of this Protective Order.
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`SO ORDERED.
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`SIGNED June 26, 2023.
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`N GREN SCHOLER
`UNITED STATES DISTRICT JUDGE
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`

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`Case 3:22-cv-02868-S Document 36 Filed 06/26/23 Page17of20 PagelD 535
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`EXHIBIT A
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`IN THE UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF TEXAS
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`DALLAS DIVISION
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`R2 Solutions LLC,
`
`Plaintiff,
`
`y
`
`Civil Action No. 3:22-cv-02761-S
`
`Hilton Domestic Operating CompanyInc.,
`
`Jury Trial Demanded
`
`Defendant.
`
`R?2 Solutions LLC,
`
`Vv.
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`7-Eleven, Inc.,
`
`R2 Solutions LLC,
`
`v.
`
`Plaintiff,
`
`Civil Action No. 3:22-cv-02868-S
`
`Jury Trial Demanded
`
`Defendant.
`
`Plaintiff,
`
`Civil Action No. 3:22-cv-02869-S
`
`Jury Trial Demanded
`
`Southwest Airlines Co.,
`
`Defendant.
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`CONFIDENTIALITY AGREEMENT FOR EXPERT,
`CONSULTANT OR EMPLOYEES OF ANY PARTY
`
`I hereby affirm that