`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
`
`Plaintiff,
`
`
`
`v.
`
`C.A. No. 1:19-cv-11586
`
`JURY TRIAL DEMANDED
`
`PHILIPS NORTH AMERICA LLC,
`
`
`
`
`
`FITBIT, INC.
`
`
`
`
`
`Defendant.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`JOINT NOTICE FOR ENTRY OF AGREED
`PROTECTIVE ORDER AND DISCOVERY STIPULATION
`
`The parties have met and conferred and have agreed to a protective order and stipulation
`
`
`
`
`
`
`
`
`
`on discovery as attached hereto, and jointly request that the Court enter the Agreed Protective
`
`Order and Discovery Stipulation as attached.
`
`Jointly and respectfully submitted on this 31st day of March, 2020.
`
`FITBIT, INC.
`By its attorneys,
`
`By: /s/ David Beckwith
`Jennifer B. Furey (BBO 634,174)
`Andrew T. O’ Connor (BBO 664,811)
`400 Atlantic Avenue
`Boston, MA 02110
`Phone: (617) 482-1776
`Fax: (617) 574-4112
`jfurey@goulstonstorrs.com
`aoconnor@goulstonstorrs.com
`
`
`
`
`4816-8468-6777.1
`
`PHILIPS NORTH AMERICA LLC,
`By its attorneys,
`
`By: _/s/Ruben J. Rodrigues________
`Lucas I. Silva (BBO 673,935)
`Ruben Rodrigues (BBO 676,573)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
`lsilva@foley.com
`rrodrigues@foley.com
`
`
`
`
`1
`
`
`
`Case 1:19-cv-11586-IT Document 58 Filed 03/31/20 Page 2 of 3
`
`
`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
`
`
`
`
`
`
`
`
`Yar R. Chaikovsky (pro hac vice)
`David Beckwith (pro hac vice)
`David T. Okano (pro hac vice)
`Radhesh Devendran (pro hac vice)
`Berkeley G. Fife (pro hac vice)
`PAUL HASTINGS LLP
`1117 S. California Ave.
`Palo Alto, CA 94304
`Phone: (650) 320-1800
`Fax: (650) 320-1900
`yarchaikovsky@paulhastings.com
`davidbeckwith@paulhastings.com
`davidokano@paulhastings.com
`radheshdevandran@paulhastings.com
`berkeleyfife@paulhastings.com
`
`Chad J. Peterman (pro hac vice)
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Phone: (212) 318-6797
`Fax: (212) 230-7797
`chadpeterman@paulhastings.com
`
`
`
`
`
`
`
`
`
`
`
`4816-8468-6777.1
`
`2
`
`
`
`Case 1:19-cv-11586-IT Document 58 Filed 03/31/20 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`The undersigned hereby certifies that on March 31, 2020 a copy of the foregoing
`
`document was filed with the Court through the ECF system and that a copy will be electronically
`
`served on registered participants as identified on the Notice of Electronic Filing.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Ruben J. Rodrigues
` Ruben J. Rodrigues
`
`
`
`
`
`4816-8468-6777.1
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
