`Case 1:19-cv-11586—IT Document 123-1 Filed 11/09/20 Page 1 of 2
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`EXHIBIT A
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`EXHIBIT A
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`Case 1:19-cv-11586-IT Document 123-1 Filed 11/09/20 Page 2 of 2
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`The Honorable Indira Talwani
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` Date: November 9, 2020
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`Subject: Philips North America LLC v. Fitbit, Inc., Case No. 1:19-cv-11586-IT
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`Dear Judge Talwani:
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` I
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` am in-house counsel for Philips in the above-referenced Action.
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`By this letter, I acknowledge that I have read: the Protective Order (Order No. 59, Attachment
`2) issued by Judge Indira Talwani (the “Protective Order”). I also acknowledge that I have
`read: the Supplement to the Protective Order (Dkt. No. 69, Exhibit A). Specifically, I hereby
`agree:
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`1)
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`Not to reveal any confidential business information (as the term is defined in the
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`Protective Order) to anyone other than another person designated in Paragraph 3 of the
`Protective Order;
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`3)
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`To the acknowledgement at paragraph 4 of the Protective order, specifically that
`4)
`“Confidential business information submitted in accordance with the provisions of paragraph
`2 [of the protective order] shall not be made available to any person designated in paragraph
`3(iii) unless he or she shall have first read [the protective] order and shall have signed the
`undertaking at Attachment A [of the protective order]. However, Attorneys who have filed an
`appearance in this matter need not sign the undertaking at Attachment A, but shall
`nevertheless be subject to, and bound by, the provision of [the] Protective Order.”; and
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`5)
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`Respectfully submitted,
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`To be bound by the terms of the Protective Order and its Supplement;
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`To utilize such confidential business information solely for purposes of this Action;
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`To be bound by the Prosecution Bar in paragraph 14 of the Protective Order.
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`Arie J.W. Tol
`Principal Licensing Counsel
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`V
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`Koninklijke Philips N.V.
`High Tech Campus 5, 5656 AE Eindhoven, The Netherlands, Tel +31 629602212, Fax +31 40 79 80085, www.ip.philips.com
`Chamber of Commerce 17001910, VAT number NL002065538B01
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