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Compass Productions International, LLC v. Charter Communications, Inc.

United States District Court, S.D. New York

January 9, 2020

COMPASS PRODUCTIONS INTERNATIONAL, LLC, Plaintiff,
v.
CHARTER COMMUNICATIONS, INC., Defendant.

          Jonathan E. Neuman Counsel for Plaintiff Compass Productions International, LLC

          John P. Del Monaco Kirkland & Ellis LLP Jeffrey S. Powell, P. Judson Brown, P.C. Devin S. Anderson K. Ross Powell Kirkland & Ellis LLP Attorneys for Defendant Charter Communications, Inc.

          Victor Marrero Judge

          STIPULATED PROTECTIVE ORDER

          Barbara Moses, U.S.M.J.

         The parties having agreed to the following terms of confidentiality, and the Court having found that good cause exists for issuance of an appropriately-tailored confidentiality order governing the pre-trial phase of this action, it is therefore hereby ORDERED that any person subject to this Order-including without limitation the parties to this action, their representatives, agents, experts and consultants, all third parties providing discovery in this action, and all other interested persons with actual or constructive notice of this Order-shall adhere to the following terms, upon pain of sanctions set forth in Rule 37(b) of the Federal Rules of Civil Procedure and contempt:

         1. Any person subject to this Order who receives from any other person any “Discovery Material” (i.e., information of any kind provided in the course of discovery in this action) that is designated as “Confidential” pursuant to the terms of this Order shall not disclose such Confidential Discovery Material to anyone else except as expressly permitted hereunder.

         2. The party producing any given Discovery Material may designate as Confidential only such portion of such material as consists of:

(a) proprietary business information;
(b) competitively sensitive information;
(c) business plans, product development information, or marketing plans;
(d) non-public commercial, financial, research, or technical information, in accordance with Federal Rule of Civil Procedure 26(c)(1)(G) including without limitation profitability reports or estimates, percentage fees, design fees, royalty rates, minimum guarantee payments, sales reports and sale margins;
(e) material relating to ownership or control of any non-public company;
(f) any information of a personal or intimate nature regarding any individual; or
(g) any other category of information hereinafter given confidential ...

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