Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 1 of 14 Page ID #:967
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`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
`
` Case No. 2:19-cv-06301-AB-KS
`[PROPOSED]
`ORDER ON
`ELECTRONIC DISCOVERY
`
`
`
`
`
`
`Philips North America LLC,
`
`
`
`
`Plaintiff,
`
`
`v.
`
`Garmin International, Inc.
`and Garmin Ltd.,
`
`
`
`
`Defendants.
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`

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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 2 of 14 Page ID #:968
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`Plaintiffs Philips North America, LLC (“Philips”) and Defendant Garmin
`International, Inc. and Garmin Ltd. (“Garmin”), by and through their respective counsel,
`hereby stipulate and agree as follows.
`1.
`Service and Delivery of Documents
`Absent other agreement of the parties, documents and written discovery responses
`in this action will be served by electronic means on an attorney of record, and in all
`instances be accompanied by an email confirmation to the e-mail addresses listed below.
`
`Party
`
`Designated Email Addresses
`
`Philips
`
`Garmin
`
`BOSTFPhilipsGarmin@foley.com
`rdl@lamkinipdefense.com
`
`The parties agree that only individuals permitted access to documents containing
`confidential business information pursuant to the Protective Order will be included in the
`above email distribution addresses.
`When the size of the file containing any such document is larger than 20 MB, and
`cannot be practicably transmitted in a smaller zipped file, same day service of the
`documents in electronic form shall be made via secure file transfer over FTP, extranet, or
`hand delivery of electronic media. Parties may also serve hard copies of documents if
`necessary for timely service, provided that electronic copies of those documents also shall
`be provided to the other parties.
`Discovery requests or responses sent by email on or before 7 p.m. PDT/PST shall be
`deemed to have been served on the day sent. Discovery requests or responses sent by email
`after 7 p.m. PDT/PST shall be deemed to have been served on the following day.
`Discovery requests and discovery responses shall be served in searchable .PDF format by
`electronic service and, in addition to the .PDF format, the parties shall exchange copies of
`discovery requests in Microsoft Word format.
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`4841-2213-2669.1
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`1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`

`

`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 3 of 14 Page ID #:969
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`2.
`Privilege Logs
`The parties agree that absent a showing of good cause, communications with, and
`attorney work product of, trial counsel in this case need not be identified on a privilege
`log. Nor is it necessary for the parties to log any communications with any counsel
`seeking or receiving legal advice concerning the subject matter of the pending lawsuit if
`such communications happened after the commencement of the lawsuit. Absent a
`showing of good cause, no party is required to identify on its respective privilege log any
`communications with counsel or experts in connection with any foreign patent matters
`involving the Parties hereto or their affiliates or parent companies.
`3.
`Inadvertent Production of Privileged Information
`If a document or information inadvertently produced in discovery is subject to a
`claim of privilege, immunity or of protection as work product (“privileged information”),
`the inadvertent production of that privileged information shall not be deemed to constitute
`a waiver of any applicable privileges or protections consistent with Rule 26(b)(5)(B),
`F.R.C.P. Likewise, consistent with Federal Rule of Evidence 502(d), the inadvertent
`production of a privileged or work product protected ESI is not a waiver in the pending
`case or in any other federal or state proceeding. For example, the production of privileged
`information in this case as part of a production by a party is not itself a waiver of any
`privilege or protection in this matter or any other federal or state proceeding.
`When a receiving party identifies potentially privileged information that may have
`been inadvertently produced, it shall promptly notify the producing party. When the party
`that produced the privileged information becomes aware that privileged information was
`produced, it shall promptly provide notice to any party that received the privileged
`information that: (a) identifies the privileged information; (b) specifies the claimed
`privilege or protection; and (c) explains the basis for the claimed privilege or protection.
`After receiving such a notice, or after identifying on its own potentially privileged
`information that may have been inadvertently produced, the receiving party shall (a)
`promptly from service of the notice, return or destroy the specified privileged information
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 4 of 14 Page ID #:970
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`along with any copies it has of the document or information; (b) not use or disclose the
`document or information until the claim is resolved; and (c) within seven days of service
`of the notice, take reasonable steps to retrieve the document or information if the person
`disclosed it to others before being notified and inform the producing party of that fact.
`Such return or destruction shall not preclude the receiving party from subsequently
`seeking to compel production of the privileged information. The person that produced the
`document must preserve the document or information until the claim of privilege or
`protection is resolved.
`4.
`Discovery of Expert Materials
`The parties agree to be bound by Federal Rule of Civil Procedure 26(b)(4) as to
`discovery of expert materials.
`Notwithstanding the above, the parties shall identify and produce copies of any
`documents relied upon by the expert as a basis for the opinions set forth in his or her report,
`declaration, affidavit, and/or testimony, including witness statements and live testimony.
`Furthermore, nothing in this agreement is intended to restrict discovery relating to: (a) the
`compensation paid to an expert; and (b) any assumptions that counsel provided and that
`the expert relied on in forming the opinions to be expressed.
`The parties agree that retained experts and consultants may not share any
`confidential business information received under the Protective Order with any other
`individual, including non-clerical assistants or support staff for the expert or consultant,
`unless that individual has subscribed to the Protective Order.
`5.
`Inadvertent Failure to Designate Confidential Business
`Information
`A party which inadvertently fails to designate information as confidential may
`promptly notify the other parties that such information should have been designated
`confidential and should be treated as confidential after reasonable steps by receiving parties
`have been taken as specified below. Where appropriate, the designating party shall provide
`replacement copies of such materials bearing the appropriate confidentiality designation.
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 5 of 14 Page ID #:971
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`Upon being notified that the information was inadvertently not designated as confidential,
`the receiving parties shall take reasonable steps to retrieve the information from any
`recipients of such information who previously had been provided the confidential
`information and who are not authorized to access such confidential information under the
`Protective Order. If the receiving party has reason to believe that the information has been
`disseminated to persons from whom it has not been able to retrieve the information through
`reasonable steps, it shall inform the producing party of that fact.
`No party shall argue that another party is in breach of the Protective Order for any
`use of confidential information during the time that the information was not designated as
`confidential or before receiving parties complete the reasonable steps specified above.
`6.
`Third-Party Confidentiality
`To the extent the following is not inconsistent with confidentiality obligations in, for
`example, an applicable non-disclosure or other agreement, the parties agree as follows:
`The parties shall take reasonable steps to ensure that the existence of confidentiality
`or non-disclosure agreements with non-parties (“Non-Party Confidentiality Agreements”)
`do not significantly delay the production of any such documents that a party has agreed to
`produce. The parties further agree that those reasonable steps shall include notice from the
`producing party to any non-parties with whom they have any applicable confidentiality or
`non-disclosure agreement that allows the non-party a period of 10 days, or other time
`period set forth in an applicable non-disclosure or other agreement, to provide a written
`objection to the producing party. The written notice to the non-party shall state that the
`information or documents will be produced if the non- party does not respond in writing
`within the allocated time period. If the non-party does not object to the production within
`10 days or such other prescribed period, the documents subject to the non-disclosure or
`other applicable agreement shall be produced. The 10-day period may be extended by an
`additional 5 days if notice is to be sent to a company outside the United States.
`If a non-party raises a timely objection to production, the producing party objects to
`the production based on obligations in a non-disclosure or other applicable agreement that
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`4841-2213-2669.1
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`4
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`

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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 6 of 14 Page ID #:972
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`conflict with the preceding paragraph, or the requesting party so requests, the parties shall
`meet and confer in good faith regarding the production of the information subject to any
`non-disclosure or other applicable agreement. If the matter reaches an impasse, the party
`seeking production of the information, the non-party objecting to production, or both may
`seek assistance from the Court by motion or other permissible manner.
`7.
`Email Production
`The parties agree that, as a general matter, the parties do not need to search or
`produce email or other forms of electronic correspondence in response to Requests for
`Production, subject to the exception identified in subparagraph (a) below which shall apply
`to only Philips and Garmin.
`a.
`If a party, having reviewed another party’s production, believes that
`searching and production of another party’s email is reasonably necessary to proceed
`with its case, then the parties agree to the following procedure, subject to the
`limitations set forth in subparagraphs (b)-(d): A requesting party may make a request
`to the other party to conduct a reasonable, narrowly-tailored search by providing to
`the receiving party a list of ten search terms. The search terms (1) shall be narrowly-
`focused to particular issues, (2) shall correlate to a named employee or representative
`of the receiving party, and (3) shall be limited to a reasonable time period not to
`exceed two years absent good cause shown. Indiscriminate terms, such as a
`company’s name or its product name, are inappropriate unless combined with
`narrowing search criteria that sufficiently reduce the risk of overproduction. A
`conjunctive combination of multiple words or phrases (e.g., “computer” and
`“system”) narrows the search and shall count as a single search term. A disjunctive
`combination of multiple words or phrases (e.g., “computer” or “system”) broadens
`the search, and thus each word or phrase shall count as a separate search term unless
`they are variants of the same word. The parties may jointly agree to modify this
`limit.
`
`b.
`
`Each requesting party shall limit its email production requests as
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 7 of 14 Page ID #:973
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`follows consistent with proportionality under Rule 26(b)(1). Each party shall limit
`email production requests to a total of ten search terms and five employees or
`representatives.
`c.
`If a proposed search returns an unreasonably large number of emails or
`other electronic correspondence, the parties agree to meet and confer to attempt to
`narrow or limit the requested search. If a dispute arises as to the scope of any email
`production request pursuant to this paragraph, the parties further agree to meet and
`confer promptly to attempt to resolve the matter without intervention by the Court.
`d.
`The mere fact that a party has previously produced email or electronic
`correspondence as part of a document production shall not itself constitute a waiver
`for any purpose of any provision of this paragraph.
`8.
`Sources Not to Be Searched
`Absent a showing of good cause by the requesting party, the parties agree that the
`following sources need not be searched and therefore need not be preserved: automated
`disaster recovery backup systems and/or disaster recovery backup tapes; RAM or
`temporary files; temporary internet files, history, cache, cookies, and other on-line access
`data; data in metadata fields that are updated automatically such as last-opened dates; data
`remaining from systems no longer in use that is unintelligible on the systems in use;
`residual, fragmented, damaged, permanently deleted, slack, and unallocated data;
`voicemail systems; text messages; mobile devices; personal home computers; instant
`messaging logs; and social media or other web-based communications.
`9.
`Documents Received in Response to a Subpoena
`Any party who receives documents from a third party pursuant to a subpoena shall
`re-produce those documents to the other parties within three business days or less. The
`parties agree that they shall make reasonable efforts to re-produce such third-party
`materials in fewer than three business days when necessary such as, for example, in the
`event such documents may be used in a deposition. Where re-production of the documents
`within three business days is not feasible, the party who received the documents shall
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 8 of 14 Page ID #:974
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`provide prompt notice to the other parties and the issue will be resolved on a case-by-case
`basis.
`
`10. Non-Confidential Versions of Certain Documents
`Counsel for a party may request permission to provide a redacted version of a
`confidential submission from another party to individuals outside the protective order. The
`other parties shall endeavor to respond in a reasonably timely fashion to such requests. In
`accordance with the Protective Order, no document designated Confidential Business
`Information may be shared with anyone outside the Protective Order absent express written
`authorization from the party that designated the document as Confidential Business
`Information. To the extent possible, each confidential submission shall identify in the
`confidentiality header the party and/or third party supplier(s) that provided Confidential
`Business Information contained in that submission.
`11. Form of Production and Electronically Stored Information
`Unless otherwise agreed between the parties, all documents, including any
`electronically stored information (“ESI”), shall be produced in native-file format or as TIFF
`images as follows, subject to the technical capabilities of the producing party or its vendor:
`a.
`If ESI (or non-ESI) is produced as TIFF images, it shall be produced as
`single- page TIFF Group IV images, black and white, at 300 x 300 dpi
`resolution with a standard delimited concordance format (DAT file) and
`either IPRO (LFP file) or Opticon (OPT file) format, including document
`breaks and page counts. The producing party may, at any time, reproduce
`any document in color in JPG format or at a higher resolution. Documents
`reproduced in color or at a higher resolution shall bear the same production
`number(s) as the originally produced document where practicable. A single
`multi-page text file shall be provided for each document, and the filename
`should match its respective TIFF image filename. A commercially-
`acceptable technology for optical character recognition (“OCR”) shall be
`used for all scanned, hard copy documents written in English or other Latin-
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`4841-2213-2669.1
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 9 of 14 Page ID #:975
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`b.
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`c.
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`d.
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`e.
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`character language. When possible, the text of native files should be
`extracted directly from the native file. Text files will not contain the
`redacted portions of the documents and OCR text files will be substituted
`instead of extracted text files for redacted documents.
`Images shall be produced using a unique file name that will be the
`production number of that page (e.g., ABC000001.TIFF). The production
`number shall appear on the face of the image. For documents that are
`produced as native files, the producing party shall endeavor to include in the
`set of TIFF images a slipsheet where the native file would otherwise have
`been produced indicating the production number of the native file or other
`document and the confidentiality designation. In addition, native files shall
`be produced using a name that bears the production number, for example:
`ABC000002.xls. The producing party shall also endeavor to indicate any
`confidentiality designation in the produced filename where possible and
`reasonable. The DAT file shall also include a path to the native file.
`Parent-child relationships (association between an attachment and its parent
`document) shall be preserved to the extent such relationships are maintained
`in the normal course of business in the source repository. The attachment(s)
`shall be produced adjacent to the parent document in terms of production
`numbers, with the first attachment being named with the next sequential
`number after the parent, and any additional attachment(s) sequentially
`numbered after that first attachment. Any parent-child relationship will be
`reflected in the DAT file.
`Productions that contain foreign language documents shall be Unicode
`compliant.
`To the extent possible, the unitization of a produced electronically stored
`document and any attachments or affixed notes shall be maintained as it
`existed in the original file or computer. Scanned/paper documents should be
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`4841-2213-2669.1
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 10 of 14 Page ID #:976
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`f.
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`g.
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`h.
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`i.
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`j.
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`logically unitized (i.e., to preserve page breaks between documents and
`otherwise allow separate documents to be identified).
`If unitization cannot be maintained, the original unitization shall be
`documented in the associated load file or otherwise electronically tracked if
`possible.
`Document level text files with a .txt extension will be provided where
`available. The text file name will correspond to the beginning production
`number of the image or native file. A field will be included in the DAT with
`the path to the corresponding text file.
`Each party will use reasonable efforts to filter out common system files and
`application executable files.
`A party is required to produce only a single copy of a responsive document
`and a party may de-duplicate responsive ESI (based on MD5 or SHA-1 hash
`values at the document level) across custodians. To the extent that a party
`has propounded a specific request for email and shown good cause in
`compliance with this stipulation, the hash value will be generated based on
`the parent/child document grouping for emails with attachments. A party
`may also de-duplicate “near- duplicate” email threads as follows: In an
`email thread, only the final-in-time document need be produced, assuming
`that all previous emails in the thread are contained within the final message.
`Where a prior email contains an attachment, that email and attachment shall
`not be removed as a “near-duplicate.” To the extent that de-duplication
`through MD5 or SHA-1 hash values is not possible, the parties shall meet
`and confer to discuss any other proposed method of de- duplication.
`To facilitate production of ESI, a producing party may batch designate ESI
`produced pursuant to this agreement as Confidential Business Information
`under the Protective Order without justifying the confidentiality of the ESI
`on a document-by-document basis at the time of production. Upon request
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 11 of 14 Page ID #:977
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`l.
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`k.
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`by a receiving party, however, the producing party shall cooperate to de-
`designate, as appropriate, material that is not confidential but was previously
`produced designated as Confidential Business Information.
`The parties are not required to preserve metadata fields that are frequently
`updated in the ordinary course of business, such as last-opened dates.
`No party shall be required to create any metadata for production (e.g., hash
`value or other metadata not associated with ESI in the ordinary course of
`business) except that the parties will create a field to indicate whether or not
`a document has been marked confidential pursuant to the protective order
`(see below list of metadata fields). However, a receiving party may not rely
`solely on this field to identify information and documents that it is required
`to treat as confidential. Any document produced with a confidentiality
`banner on the produced image is to be afforded confidential treatment under
`the Protective Order regardless of whether there is an entry in this field.
`m. Absent a showing of good cause, ESI productions need not include metadata
`except that the following fields shall be included in the production if such
`fields exist and are reasonably available to the producing party:
`Field Name
`Field Description
`BEGBATES
`Number stamped on first image page of
`document
`
`ENDBATES
`
`Number stamped on last image page of document
`
`BEGATTACH
`
`Number stamped on first image page of
`attachment(s)
`
`ENDATTACH
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`Number stamped on last image page of
`attachment(s)
`
`CBI
`
`Indicates the confidentiality designation of
`a document that has been designated as
`Confidential Business Information
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 12 of 14 Page ID #:978
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`Field Name
`CUSTODIAN
`
`DE-DUPED
`CUSTODIA
`N
`
`Field Description
`Where applicable and available, identifies the
`individual (custodian) from whom the
`document originated
`
`Where applicable and available, identifies all
`individuals other than the individual identified
`in the CUSTODIAN field whose files were de-
`duplicated but contained a copy of the
`document
`
`FILENAME
`
`File name of an electronic document or
`attachment
`
`NATIVEFILELIN
`K
`
`For documents produced as native file, link to
`that file
`
`TEXTFILELINK Link to text file produced with document or
`attachment
`
`MD5HASH
`
`Identifies value of an electronic record that can
`be used for deduplication and authentication
`generated using the MD5 hash algorithm
`
`To the extent that any email productions take place pursuant to Section 6 of this
`stipulation, the requesting and producing party shall meet and confer regarding the
`possible inclusion of additional fields, if necessary, in addition to the following:
`
`FROM
`
`TO
`
`CC
`
`The name and email address of the sender of the
`email
`
`All recipients that were included on the “To”
`line of the email
`
`All recipients that were included on the “CC”
`line of the email
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 13 of 14 Page ID #:979
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`BCC
`
`All recipients that were included on the “BCC”
`line of the email
`
`SUBJECT
`
`Email Subject Line
`
`DATESENT
`
`Date email was sent (format: MM/DD/YYYY)
`
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`The producing party has the option of producing as native files Microsoft Excel
`spreadsheets, Microsoft Access databases, and other documents that cannot be converted
`to a TIFF image format in a readily-usable and legible format. In addition, a producing
`party shall not be required to produce in TIFF format when the conversion to image TIFF
`format would impose unreasonable cost on the producing party and/or would result in
`unintelligible documents. Under such circumstances, the producing party shall notify the
`requesting party within a reasonable time after learning of the issue and the parties shall
`meet and confer regarding an acceptable production format.
`A producing party shall respond to reasonable requests that spreadsheets and other
`documents produced in TIFF format that are unintelligible or not readily usable be
`produced in another format, such as native format.
`The parties also shall respond to reasonable requests for the production of higher-
`resolution or color images. The producing party shall not object to reasonable requests for
`color images and also shall not object to reasonable requests for higher resolution images
`if the document as originally produced is illegible or difficult to read. The producing party
`shall have the option of producing the native-file version of the documents in response to
`such requests.
`12. Discovery Logistics
`Microsoft Word versions will be promptly provided upon request of any lists or other
`content in pleadings that the receiving party reasonably needs to import into a Word
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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`4841-2213-2669.1
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`Case 2:19-cv-06301-AB-KS Document 67-2 Filed 05/26/20 Page 14 of 14 Page ID #:980
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`document of their own, such as for example in preparation of a responsive pleading.
`Verifications of interrogatory responses shall be served within (a) five business days
`prior to the deposition(s) of party witnesses for all responses provided by that party as of
`that date; (b) ten business days after service of the final amended interrogatory response;
`and (c) in no case later than ten days after the close of fact discovery.
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` DATED: ________________
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`___________________________________
`KAREN E. SCOTT
`UNITED STATES MAGISTRATE JUDGE
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`[PROPOSED] ORDER ON DISCOVERY
`CASE NO. 2:19-cv-06301-AB-KS
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