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Bodine v. Salesforce.Com, Inc.

United States District Court, D. Montana, Butte Division

December 12, 2019

KIM BODINE, Plaintiff,
v.
SALESFORCE.COM, INC., and JOHN DOES 1-5, Defendants.

          PROTECTIVE ORDER

          Honorable Kathleen DeSoto, United States Magistrate Judge

         Defendant has filed a Proposed Protective Order upon conferring with Plaintiff's counsel and reaching an agreement as to the provisions contained in the Proposed Protective Order. Accordingly, IT IS ORDERED that the parties' Proposed Protective Order is hereby approved and entered as an order of the Court.

         IT IS FURTHER ORDERED that any party seeking to file a document under seal pursuant to paragraph 6 of this Stipulated Protective Order shall seek leave of Court in accordance with the pertinent provisions of L.R. 5.2. In addition, any party wishing to file any document under seal must make the appropriate showing of good cause or compelling reasons as delineated in Ground Zero Center for Non-Violent Action v. United States Department of the Navy, 860 F.3d 1244, 1261 (9th Cir. 2017) (requiring a showing of compelling reasons to seal documents attached to dispositive motions and other filings relating to the merits of a case) and Center for Auto Safety v. Chrysler Group, LLC, 809 F.3d 1092, 1097 (9th Cir. 2016) (requiring only a showing of good cause to seal documents related to a non-dispositive motion or a motion unrelated to the merits of a case).

         1. In this action, the parties will be producing documents and disclosing information that contains or may be deemed by a party as containing confidential or proprietary information, including personnel and client information; confidential business, financial, commercial and other information; and, confidential sales and marketing information regarding the parties or individuals employed by the Defendant. This Stipulated Protective Order shall govern the production, disclosure, review, maintenance, and use of all information or documents deemed “Confidential” or “Highly Confidential” by a party.

         DEFINITIONS

         2. “Confidential” information means information (regardless of how it is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c) which are designated as “Confidential” under the terms of this Agreement.

         3. “Highly Confidential” information means and refers to information (regardless of how it is generated, stored or maintained) designated as “Highly Confidential” under the terms of this Agreement. It includes, but is not limited to:

         a. Non-public revenue, costs, income, pricing, margin, profit, loss, income statement, balance sheet, cash flow, sources and uses of cash, and other non-public financial data, including financial projections and forecasts containing such data;

         b. All client-specific contracts, agreements, communications and related information that are confidential, private or subject to non-disclosure agreement or otherwise;

         c. Any material constituting a trade secret, including, without limitation, product specifications, product designs, product development plans, research and development plans and data, market surveys and analyses, customer lists, other customer data, customer profiles, customer feedback, data related to sales opportunities, sales pipeline data, sales reports, information related to compensation of sales employees, sales quotations, or the needs and requirements of customers. These materials include but are not limited to the material addressed Defendant salesforce.com', inc.'s Brief in Support of Motion for Protective Order (Doc. 29): pipeline and closed opportunity reports from the Public Business Unit for fiscal years 2017 through 2020 for the states of Alabama, Tennessee, Kentucky, West Virginia, and the Town of Cary, North Carolina; (2) Public Business Unit sales reports for Wisconsin and Minnesota for fiscal years 2012 through present; (3) Documents reflecting Public Business Unit's annual sales quota for Wisconsin and Minnesota for fiscal years 2012 through the present; (4) All documents reflecting Lauren Collett's compensation for work performed in Kim Bodine's previous territory from 2017 through the present time; and (5) Documents that contain or include specific customer quotations and requirements information.

         d. The definitions of Confidential or Highly Confidential as used herein, are for purposes of this Protective Order only, and cannot be used as evidence or argument that the non-producing party otherwise concurs with the classification of the documents as Confidential or Highly Confidential.

         PROVISIONS

         4. Each party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. The non-producing party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify.

         5. If it comes to a producing party's attention that information or items that it designated for protection do not qualify for protection, the producing party must promptly notify the other party that it is withdrawing the designation 6. The following restrictions shall apply to documents that are Confidential or Highly Confidential or that contain Confidential information or Highly Confidential information, or reference to any Confidential or Highly ...


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