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Adelos, Inc. v. Halliburton Co.

United States District Court, D. Montana, Missoula Division

April 5, 2017

ADELOS, INC., Plaintiff,
v.
HALLIBURTON COMPANY and HALLIBURTON ENERGY SERVICES, INC., Defendants.

          STIPULATED PROTECTIVE ORDER

          Dana L. Christensen, United States District Court Chief Judge

         WHEREAS the Parties have stipulated that good cause exists for the entry of a Protective Order to govern confidential materials in accordance with Federal Rule of Civil Procedure 26(c) to protect against improper disclosure of confidential information produced or disclosed in this litigation; and

         WHEREAS this proposed order is subject to and without waiver of any objection to jurisdiction or venue and shall not be used as evidence otherwise;

         IT IS HEREBY STIPULATED AND AGREED, SUBJECT TO THE APPROVAL AND ORDER OF THE COURT, as follows:

         1. Definitions.

         As used in this Protective Order, these terms have the following meanings:

         (a) "Designated Material" means information designated in accordance with Paragraphs 2 or 3;

         (b) "Material" includes all documents, transcripts, records, and things (in oral, written, or electronic forms) within the scope of Federal Rule of Civil Procedure 34, including, without limitation, all testimony adduced at depositions, all documents or things responsive to requests for the production of documents and things, all answers to interrogatories, all responses to requests for admissions, and all other responses to discovery requests provided in accordance with the Federal Rules of Civil Procedure, as well as hearing and trial transcripts, matters in evidence, and any other information furnished, directly or indirectly, by or on behalf of any Party to this litigation or any third party;

         (c) "Agreement to be Bound By Protective Order" means an executed document in the form attached as Exhibit A.

         (d) "Party" or "Parties" means one or more parties to this lawsuit or affiliated parties, as delineated here:

• Adelos, Inc.
• Halliburton Company
• Halliburton Energy Services, Inc.

         (e) "Receiving party" means the Party that requests or receives the disclosure of Designated Material.

         (f) "Producing party" means the Party that owns or otherwise controls the Designated Material requested by the Receiving party.

         (g) "Competitive Decision-making" means participation in activities, association, and relationship with a Party that are such as to involve counsel's advice and participation in any or all of the Party's decisions (pricing, product design, etc.) made in light of similar or corresponding information about a competitor.

         2. "Confidential" Information or Items.

         A Party or non-party may designate any material "CONFIDENTIAL" for protection under this Protective Order where that material includes (a) information relating to the development of products, including computer code and internal product specifications; (b) past, current, or future business or marketing plans; (c) financial information or forecasts, customer lists, pricing data, cost data, customer orders, or customer quotations; (d) pending or abandoned patent, trademark and copyright applications, foreign or domestic, unless published or otherwise publicly available; (e) computer code, including source code, object code, executable code, software files, or other related files; and (f) any other documents, information, or material that relate to proprietary information that the Producing party reasonably believes is of such nature and character that the unauthorized disclosure of such information could irreparably injure the Producing party. The label "CONFIDENTIAL" must be placed on each page of such Designated Material.

         3. "Highly Confidential - Attorneys' Eyes Only" Information or Items.

         4. A Party or non-party may designate any material "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" for protection under this Protective Order where that material includes highly-sensitive "Confidential" information the disclosure of which to competing business or technical staff could result in competitive harm to the Producing party, including without limitation affecting or relating to the producing Party's sales, future sales, pricing, intellectual property rights, product roadmap, customers and customer acquisition. The label "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" must be placed on each page of such Designated Material. Use of Information. All Designated Material shall be used solely for the purpose of this litigation only, including any appeal thereof, unless otherwise agreed to, in writing, by the Producing party, or directed by a court of competent jurisdiction.

         5. Access to Designated ...


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