throbber
Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 1 of 12
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`BETSY C. MANIFOLD (182450)
`RACHELE R. BYRD (190634)
`BRITTANY N. DEJONG (258766)
`WOLF HALDENSTEIN ADLER
`FREEMAN & HERZ LLP
`750 B Street, Suite 1820
`San Diego, CA 92101
`Telephone: 619/239-4599
`Facsimile: 619/234-4599
`manifold@whafh.com
`byrd@whafh.com
`dejong@whafh.com
`Interim Class Counsel for the
`Consumer Plaintiffs
`STEVE W. BERMAN (pro hac vice)
`ROBERT F. LOPEZ (pro hac vice)
`HAGENS BERMAN SOBOL
`SHAPIRO LLP
`1301 Second Ave., Suite 2000
`Seattle, WA 98101
`Telephone: (206) 623-7292
`Facsimile: (206) 623-0594
`steve@hbsslaw.com
`robl@hbsslaw.com
`Interim Class Counsel for the
`Developer Plaintiffs
`[Additional counsel appear on signature page]
`
`PAUL R. RIEHLE (SBN 115199)
`paul.riehle@faegredrinker.com
`FAEGRE DRINKER BIDDLE & REATH
`LLP
`Four Embarcadero Center, 27th Floor
`San Francisco, CA 94111
`Telephone: (415) 591-7500
`Facsimile: (415) 591-7510
`CHRISTINE A. VARNEY (pro hac vice)
`cvarney@cravath.com
`KATHERINE B. FORREST (pro hac vice)
`kforrest@cravarth.com
`GARY A. BORNSTEIN (pro hac vice)
`gbornstein@cravarth.com
`YONATAN EVEN (pro hac vice)
`yeven@cravath.com
`LAUREN A. MOSKOWITZ (pro hac vice)
`lmoskowitz@cravath.com
`M. BRENT BYARS (pro hac vice)
`mbyars@cravath.com
`CRAVATH, SWAINE & MOORE LLP
`825 Eighth Avenue
`New York, New York 10019
`Telephone: (212) 474-1000
`Facsimile: (212) 474-3700
`Attorneys for Epic Games, Inc.
`
`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`OAKLAND DIVISION
`
`Case No. 4:11-cv-06714-YGR
`
`ORDER GRANTING STIPULATED
`[PROPOSED] SUPPLEMENTAL
`PROTECTIVE ORDER GOVERNING
`DISCOVERY FROM GLU MOBILE INC.
`
`Hon. Yvonne Gonzalez Rogers
`Hon. Thomas S. Hixson
`
`)))))))))
`
`IN RE APPLE iPHONE ANTITRUST
`LITIGATION
`
`[caption continued on next page]
`
`- 1 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 2 of 12
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`Case No. 4:19-cv-03074-YGR
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`Case No. 4:20-cv-05640-YGR
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`)))))))))
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`DONALD R. CAMERON, et al.,
`
`
`Plaintiffs,
`
`
`v.
`
`APPLE INC.,
`
` Defendant.
`EPIC GAMES, INC., et al.,
`
` Plaintiff, Counter-defendant,
`
`
`v.
`
`APPLE INC.,
`
` Defendant, Counterclaimant.
`
`- 2 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 3 of 12
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`WHEREAS the parties to In re Apple iPhone Antitrust Litigation and Cameron v. Apple Inc.
`agreed to a Stipulated Protective Order on January 6, 2020 (Case No. 4:11-cv-06714-YGR, Dkt. No.
`195; Case No. 4:19-cv-03074-YGR, Dkt. No. 81);
`WHEREAS the Court entered the Stipulated Protective Order on January 9, 2020 (Case No.
`4:11-cv-06714-YGR, Dkt. No. 199; Case No. 4:19-cv-03074-YGR, Dkt. No. 85) (the “Protective
`Order”);
`WHEREAS, parties to Epic Games, Inc. v. Apple Inc. agreed that the terms of the Stipulated
`Protective Order in Cameron v. Apple Inc. and In re Apple iPhone Antitrust Litigation should also
`apply in Epic Games, Inc. v. Apple Inc. (Case No. 4:20-cv-05640, Dkt. No. 110) (collectively, the
`“Litigations”), and the Court entered a stipulated protective order in Epic Games, Inc. v. Apple Inc.
`on October 2, 2020 with identical terms (Case No. 4:20-cv-05640, Dkt. No. 112);
`WHEREAS Paragraph 10(a) of the Protective Order states that “[t]he terms of this Order are
`applicable to information produced by a Non-Party in this action” and that “[n]othing in these
`provisions should be construed as prohibiting a Non-Party from seeking additional protections”;
`WHEREAS Parties to the Litigations have served subpoenas on Glu Mobile Inc. (“Glu
`Mobile”)1;
`WHEREAS Glu Mobile is willing to produce competitively sensitive information in
`response to subpoenas served on it in these Litigations, subject to certain additional protections
`beyond those set forth in the Protective Order and that the Parties to the Litigations agree to;
`WHEREFORE, IT IS HEREBY ORDERED that documents produced by Glu Mobile in
`connection with the Litigations shall be further subject to the following provisions (the
`“Supplemental Protective Order”):
`GENERAL PROVISIONS
`A.
`1.
`The definitions, terms and provisions contained in the Protective Order shall be
`incorporated herein by reference as though fully set forth herein; provided, however, that in the
`____________________________
`1 The term “Glu Mobile” shall include any entity that responds to subpoenas served on Glu Mobile
`Inc. (including any successor or acquiror of Glu Mobile Inc.) in the Litigations. References to
`“competitors” within this Supplemental Protective Order shall be interpreted to mean competitors
`of Glu Mobile Inc. and its parents and subsidiaries.
`- 1 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 4 of 12
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`event of a conflict between any definition, term or provision of this Supplemental Protective Order
`
`and any definition, term or provision of the Protective Order, this Supplemental Protective Order
`will control with respect to such conflict.
`2.
`The definitions, terms and provisions contained in this Supplemental Protective
`Order shall apply only to those Discovery Materials produced by Glu Mobile, and nothing herein
`shall provide any rights or protections to the Parties to the Litigations beyond those set forth in the
`Protective Order.
`ADDITIONAL DEFINITIONS
`B.
`1.
`Business Consultant: a consultant advising on or involved in competitive decision-
`making.
`Party Expert: with respect to “GLU MOBILE HIGHLY CONFIDENTIAL –
`2.
`OUTSIDE COUNSEL EYES ONLY”, a person with specialized knowledge or experience in a
`matter pertinent to the Litigations who: (1) has been retained by a Party or its counsel to serve as
`an expert witness or as a consultant in this action; (2) is not a current employee or current Business
`Consultant of a Party, Glu Mobile, or of any Glu Mobile competitor, or otherwise currently involved
`in competitive decision-making for a Party, Glu Mobile, or for any Glu Mobile competitor; (3) has
`not, within the 12 months preceding the entry of this Protective Order, been an employee or Business
`Consultant of a Party, Glu Mobile, or Glu Mobile’s competitor, or otherwise been involved in
`competitive decision-making for a Party, Glu Mobile, or Glu Mobile’s competitor; and (4) at the
`time of retention, is not anticipated to become an employee or Business Consultant of a Party, Glu
`Mobile, or of any Glu Mobile competitor, or to be otherwise involved in competitive decision-
`making for a Party or for any Glu Mobile competitor. If, while this action is pending, a Party learns
`that any of its retained experts or consultants as defined herein is anticipating to become, or has
`become, an employee or Business Consultant of Glu Mobile or any Glu Mobile competitor, or
`otherwise involved in competitive decision-making for Glu Mobile or any Glu Mobile competitor,
`the Party learning such information shall promptly disclose the information to Glu Mobile.
`3.
`“GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES
`ONLY” Information or Items: extremely sensitive “Confidential Information or Items” produced
`- 2 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 5 of 12
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`by Glu Mobile and that contain algorithms and source code; non-public, commercially sensitive
`
`customer lists or communications; non-public financial, marketing, or strategic business planning
`information; current or future non-public information regarding prices, costs, margins, or other
`financial metrics; information relating to research, development, testing of, or plans for existing or
`proposed future products; non-public information concerning Glu Mobile’s data protection practices
`and security protocols; evaluation of the strengths and vulnerabilities of Glu Mobile’s product
`offerings, including non-public pricing and cost information; confidential contractual terms,
`proposed contractual terms, or negotiating positions (including internal deliberations about
`negotiating positions) taken with respect to Glu Mobile or competitors to Glu Mobile; information
`relating to pending or abandoned patent applications that have not been made available to the public;
`confidential submissions to governmental entities describing Glu Mobile’s legal positions or
`theories; personnel files; sensitive personally identifiable information; and communications that
`disclose any such information, disclosure of which to a Party or another Non-Party would create a
`substantial risk of serious harm that could not be avoided by less restrictive means.
`ADDITIONAL PROTECTIONS FOR ACCESS TO AND USE OF GLU MOBILE
`C.
`PROTECTED MATERIALS
`Manner of Designating “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE
`1.
`COUNSEL EYES ONLY” Information or Items. Designation in conformity with this Supplemental
`Protective Order requires:
`for information in documentary form (e.g., paper or electronic documents,
`a.
`but excluding transcripts of depositions or other pretrial or trial proceedings), that Glu Mobile affix
`the legend “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY”
`to each page of any document for which Glu Mobile seeks protection under this Supplemental
`Protective Order. If only a portion or portions of the material on a page qualifies for protection, Glu
`Mobile also must clearly identify the protected portion(s) (e.g., by making appropriate markings in
`the margins).
`If Glu Mobile makes original documents or materials available for inspection, it need
`
`not designate them for protection until after the inspecting Party has indicated which material it
`- 3 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 6 of 12
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`would like copied and produced. During the inspection and before the designation, all of the
`
`material made available
`for
`inspection shall be deemed “GLU MOBILE HIGHLY
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY.” After the inspecting Party has
`identified the documents it wants copied and produced, Glu Mobile must determine which
`documents, or portions thereof, qualify for protection under this Supplemental Protective Order.
`Then, before producing the specified documents, Glu Mobile must affix the appropriate legend
`(“GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY”) to each
`page that contains such material. If only a portion or portions of the material on a page qualifies for
`protection, Glu Mobile also must clearly identify the protected portion(s) (e.g., by making
`appropriate markings in the margins).
`for testimony given in deposition or in other pretrial proceedings not
`b.
`involving the Court, that Glu Mobile identify on the record, before the close of the deposition,
`hearing, or other proceeding, all protected testimony. When it is impractical to identify separately
`each portion of testimony that is entitled to protection and it appears that substantial portions of the
`testimony may qualify for protection, Glu Mobile may invoke on the record (before the deposition,
`hearing, or other proceeding is concluded) a right to have up to 21 days to identify the specific
`portions of the testimony as to which protection is sought. Only those portions of the testimony that
`are appropriately designated for protection within the 21 days shall be covered by the provisions of
`this Supplemental Protective Order. Alternatively, Glu Mobile may specify, at the deposition or up
`to 21 days afterwards if that period is properly invoked, that the entire transcript shall be treated as
`“GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY.” With
`respect to trial, Glu Mobile can petition the Court for appropriate protective measures which shall
`be requested in advance of evidence being taken.
`
`Glu Mobile and the Parties shall give the other parties notice if they reasonably
`expect a deposition, hearing, or other proceeding to include “GLU MOBILE HIGHLY
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY” Information or Items so that the other
`parties can ensure that only authorized individuals who have signed the “Acknowledgment and
`Agreement to Be Bound” (Exhibit A) are present at those proceedings. The use of a document as
`- 4 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
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`an exhibit at a deposition shall not in any way affect its designation as “GLU MOBILE HIGHLY
`
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY.”
`
`Transcripts containing “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE
`COUNSEL EYES ONLY” Information or Items shall have an obvious legend on the title page that
`the transcript contains such material, and the title page shall be followed by a list of all pages
`(including line numbers as appropriate) that have been designated as “GLU MOBILE HIGHLY
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY”. Glu Mobile shall inform the Court
`reporter of these requirements. Any transcript that is prepared before the expiration of a 21-day
`period for designation shall be treated during that period as if it had been designated “GLU MOBILE
`HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY” in its entirety unless otherwise
`agreed. After the expiration of that period, the transcript shall be treated only as actually designated.
`for information produced in some form other than documentary and for any
`c.
`other tangible items, that Glu Mobile affix in a prominent place on the exterior of the container or
`containers in which the information or item is stored the legend “GLU MOBILE HIGHLY
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY.” If only a portion or portions of the
`information or item warrant protection, Glu Mobile, to the extent practicable, shall identify the
`protected portion(s).
`Disclosure of “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL
`2.
`EYES ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in writing
`by Glu Mobile, a Party may disclose any information or item designated “GLU MOBILE HIGHLY
`CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY” only to:
`the Party’s Outside Counsel of Record in this action, as well as employees of
`a.
`said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for
`these Litigations and who have signed the “Acknowledgement and Agreement to be Bound” that is
`attached to the Protective Order as Exhibit A;
`Designated House Counsel of the Party, but only in the event that (i)
`b.
`information designated “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL
`EYES ONLY” is incorporated into and necessary to a Party’s work product that is to be filed or
`- 5 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
`

`

`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 8 of 12
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`served in these Litigations; (ii) the Party discloses to Glu Mobile the relevant excerpts from the work
`
`product that include the information designated “GLU MOBILE HIGHLY CONFIDENTIAL –
`OUTSIDE COUNSEL EYES ONLY” prior to disclosure to Designated House Counsel of the Party;
`(iii) the Party identifies by name and job title the Designated House Counsel with whom such work
`product will be shared for the purpose of reviewing and approving the work product in advance of
`filing or service; and (iv) Glu Mobile provides consent to the disclosure, which shall not
`unreasonably be withheld;
`Party Experts (as defined in this Supplemental Protective Order) (1) to whom
`c.
`disclosure is reasonably necessary for these Litigations and (2) who have signed the
`“Acknowledgment and Agreement to Be Bound” (Exhibit A);
`the Court and its personnel;
`d.
`e.
`court reporters and their staff, professional jury or trial consultants, and
`Professional Vendors to whom disclosure is reasonably necessary for these Litigations and who
`have signed the “Acknowledgment and Agreement to be Bound” (Exhibit A); and
`the author or recipient of a document containing the information.
`f.
`All other provisions of the Protective Order, including Paragraphs 2, 3, 4, 5.3, 6, 7.1,
`3.
`9, 10, 11, 12, 13, and 14 apply mutatis mutandis to information designated “GLU MOBILE
`HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY” to the same extent as they
`apply to information designated as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”;
`except that the provision in Paragraph 3 of the Protective Order providing that any use of Protected
`Material at trial shall be governed by a separate agreement or order shall not apply to information
`designated “GLU MOBILE HIGHLY CONFIDENTIAL – OUTSIDE COUNSEL EYES ONLY”.
`Unless otherwise ordered by the Court or expressly permitted by Glu Mobile, no Party seeking to
`introduce documents or information designated “GLU MOBILE HIGHLY CONFIDENTIAL –
`OUTSIDE COUNSEL EYES ONLY” into the record at trial may disclose the materials to any
`persons other than those identified in Paragraph C.2. of this Supplemental Protective Order.
`
`
`
`- 6 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`Dated: May 17, 2021
`
`By:
`
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`
`Dated: May 17, 2021
`
`By:
`
`
`
`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 9 of 12
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`IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
`
`
`
`
`
`
`
`/s/ John I. Karin
`
`CRAVATH, SWAINE & MOORE LLP
`Christine Varney (pro hac vice)
`Katherine B. Forrest (pro hac vice)
`Gary A. Bornstein (pro hac vice)
`J. Wesley Earnhardt (pro hac vice)
`Yonatan Even (pro hac vice)
`Lauren A. Moskowitz (pro hac vice)
`Vanessa A. Lavely (pro hac vice)
`M. Brent Byars (pro hac vice)
`John I. Karin (pro hac vice)
`825 Eighth Avenue
`New York, New York 10019
`Telephone: (212) 474-1000
`Facsimile: (212) 474-3700
`cvarney@cravath.com
`kforrest@cravath.com
`gbornstein@cravath.com
`yeven@cravath.com
`lmoskowitz@cravath.com
`mbyars@cravath.com
`
`FAEGRE DRINKER BIDDLE & REATH LLP
`Paul J. Riehle (SBN 115199)
`Attorneys for Plaintiff Epic Games, Inc.
`
`
`/s/ Nicole Castle
`
` MCDERMOTT WILL & EMERY LLP
`Peter John Sacripanti (pro hac vice)
`John J. Calandra (pro hac vice)
`Nicole Castle (pro hac vice)
`340 Madison Avenue
`New York, NY 10173
`Telephone: (212) 547-5400
`psacripanti@mwe.com
`jcalandra@mwe.com
`ncastle@mwe.com
`
`MCDERMOTT WILL & EMERY LLP
`Michelle Lowery (SBN 302882)
`2049 Century Park East, Suite 3200
`Los Angeles, CA 90067
`Telephone (310) 277-4110
`mslowery@mwe.com
`
`MCDERMOTT WILL & EMERY LLP
`Elizabeth Rodd (pro hac vice)
`200 Clarendon Street
`Boston, MA 02116
`- 7 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 10 of 12
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`Dated: May 17, 2021
`
`By:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: May 17, 2021
`
`By:
`
`
`
`
`
`
`
`
`
`Telephone: (617) 535-4000
`erodd@mwe.com
`
`Attorneys for Defendant Apple Inc.
`
`
`
`/s/ Brittany N. DeJong
`WOLF HALDENSTEIN ADLER
` FREEMAN & HERZ LLP
`BETSY C. MANIFOLD (182450)
`RACHELE R. BYRD (190634)
`BRITTANY N. DEJONG (258766)
`750 B Street, Suite 1820
`San Diego, CA 92101
`Telephone: 619/239-4599
`Facsimile: 619/234-4599
`
`WOLF HALDENSTEIN ADLER
` FREEMAN & HERZ LLP
`MARK C. RIFKIN (pro hac vice)
`MATTHEW M. GUINEY (pro hac vice)
`270 Madison Avenue
`New York, New York 10016
`Telephone: 212/545-4600
`Facsimile: 212/545-4677
`
`Consumer Plaintiffs’ Interim Class Counsel
`
`
`
`/s/ Robert F. Lopez
`HAGENS BERMAN SOBOL SHAPIRO LLP
`Steve W. Berman (pro hac vice)
`Robert F. Lopez (pro hac vice)
`1301 Second Ave., Suite 2000
`Seattle, WA 98101
`Telephone: (206) 623-7292
`Facsimile: (206) 623-0594
`steve@hbsslaw.com
`robl@hbsslaw.com
`
`HAGENS BERMAN SOBOL SHAPIRO LLP
`Shana E. Scarlett (SBN 217895)
`715 Hearst Avenue, Suite 202
`Berkeley, CA 94710
`Telephone: (510) 725-3000
`Facsimile: (510) 725-3001
`shanas@hbsslaw.com
`Developer Plaintiffs’ Interim Class Counsel
`
`- 8 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
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`

`

`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 11 of 12
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`PURSUANT TO STIPULATION, IT IS SO ORDERED.
`
`DATED:
`
`June 28, 2021
`
`HON. YVONNE GONZALEZ ROGERS
`United States District Court Judge
`
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`- 9 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
`

`

`Case 4:20-cv-05640-YGR Document 803 Filed 06/28/21 Page 12 of 12
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`DECLARATION REGARDING CONCURRENCE
`I, Brittany N. DeJong, am the ECF User whose ID and password are being used to file this
`
`document. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that each of the signatories
`identified above has concurred in this filing.
`
`Dated: May 17, 2021
`
`
`
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`
`
`/s/ Brittany N. DeJong
`BRITTANY N. DEJONG
`
`
`
`
`- 10 -
`STIPULATED [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
`GOVERNING DISCOVERY FROM GLU MOBILE INC.
`Case Nos. 4:11-cv-06714-YGR, 4:19-cv-03074-YGR, 4:20-cv-05640-YGR
`
`

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