# AirDoctor, LLC v. Lonni, Inc.

> District Court, C.D. California · June 20, 2025

URL: https://www.frixlaw.com/law-library/cases/11081328

## Case

- **Court:** District Court, C.D. California
- **Decided:** June 20, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

1 EPSTEIN DRANGEL LLP
Peter J. Farnese (SBN 251204)
2
pfarnese@ipcounselors.com
3 700 South Flower Street, Suite 1000
Los Angeles, CA 90017
4 Telephone: 310-356-4668
Facsimile: 310-388-1232
5
Grace A. Rawlins (SBN 355235)
6
grawlins@ipcounselors.com
7 Ashly E. Sands (pro hac vice)
asands@ipcounselors.com
8 Danielle Futterman (pro hac vice)
dfutterman@ipcounselors.com
9
60 East 42nd Street, Suite 1250
10 New York, NY 10165
Telephone: 212-292-5390
11 Facsimile: 212-292-5391
Attorneys for Plaintiff
12
GLACIER LAW LLP
13
Tianyu Ju
14 iris.ju@glacier.law
251 South Lake Avenue, Suite 910
15 Pasadena, CA 91101
Telephone: (323) 499-2666
16
Facsimile: (312) 801-4587
Attorneys for Defendants Lonni, Inc.,
17
Shenzhen Dazhan Pengtu Internet Co., Ltd.,
Shenzhen Mingdao Youshu E-Commerce Co., Ltd.,
18
DongGuanShiLianRuiZhongXinWangLuoKeJiYouXianGongSi d/b/a Jorair-Filter
19
20
21 UNITED STATES DISTRICT COURT
22 CENTRAL DISTRICT OF CALIFORNIA
AIRDOCTOR, LLC
23 CASE NO. 2:23-cv-00353-GW-AS
Plaintiff
24
v.
25
AMENDED STIPULATED
26 L ONNI, INC., et al. Defendants PROTECTIVE ORDER
27
1
2 1. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential, proprietary,
4 or private information for which special protection from public disclosure and from
5 use for any purpose other than prosecuting this litigation. may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the Court to enter the
7 following Amended Stipulated Protective Order. The parties acknowledge that this
8 Order does not confer blanket protections on all disclosures or responses to discovery
9 and that the protection it affords from public disclosure and use extends only to the
10 limited information or items that are entitled to confidential treatment under the
11 applicable legal principles. The parties further acknowledge, as set forth in Section
12 12.3, below, that this Amended Stipulated Protective Order does not entitle them to
13 file confidential information under seal; Civil Local Rule 79-5 sets forth the
14 procedures that must be followed and the standards that will be applied when a party
15 seeks permission from the court to file material under seal.
16 1.1 GOOD CAUSE STATEMENT
17 This action is likely to involve trade secrets, customer and pricing lists and other
18 valuable research, development, commercial, financial, technical and/or proprietary
19 information for which special protection from public disclosure and from use for any
20 purpose other than prosecution of this action is warranted. Such confidential and
21 proprietary materials and information consist of, among other things, confidential
22 business or financial information, information regarding confidential business
23 practices, or other confidential research, development, or commercial information
24 (including information implicating privacy rights of third parties), information
25 otherwise generally unavailable to the public, or which may be privileged or
26 otherwise protected from disclosure under state or federal statutes, court rules, case
27 decisions, or common law. Accordingly, to expedite the flow of information, to
1 facilitate the prompt resolution of disputes over confidentiality of discovery
2 materials, to adequately protect information the parties are entitled to keep
3 confidential, to ensure that the parties are permitted reasonable necessary uses of
4 such material in preparation for and in the conduct of trial, to address their handling
5 at the end of the litigation, and serve the ends of justice, a protective order for such
6 information is justified in this matter. It is the intent of the parties that information
7 will not be designated as confidential for tactical reasons and that nothing be so
8 designated without a good faith belief that it has been maintained in a confidential,
9 non-public manner, and there is good cause why it should not be part of the public
10 record of this case.
11 Additionally, here, there is a need for a two-tiered, attorneys’ eyes only
12 protective order that designates certain material as “HIGHLY CONFIDENTIAL –
13 ATTORNEYS’ EYES ONLY”. See Elements Spirits, Inc. v. Iconic Brands, Inc., Civ.
14 No. CV 15-02692 DDP(AGRx), 2016 WL 2642206, at *1–*2 (C.D. Cal. May 9,
15 2016) (holding that protective order with attorneys’ eyes only designation was
16 warranted to protect party’s confidential information) (citing Nutratech, Inc. v.
17 Syntech Int’l, Inc., 242 F.R.D. 552, 555 (C.D. Cal. 2008); Brown Bag Software v.
18 Symantec Corp., 960 F.2d 1465, 1470 (9th Cir. 1992)).
19 2. DEFINITIONS
20 2.1 Action: this pending federal lawsuit, AirDoctor, LLC v. Lonni, Inc. et al.,
21 Case No. 2:23-cv-00353-GW-AS.
22 2.2 Challenging Party: a Party (as defined herein) or Non-Party (as defined
23 herein) that challenges the designation of information or items under this
24 Amended Stipulated Protective Order.
25 2.3 “CONFIDENTIAL” Information or Items: information (regardless of how it
26 is generated, stored or maintained) or tangible things that qualify for
27 protection under Federal Rule of Civil Procedure 26(c), as specified in the
1 2.4 “CONFIDENTIAL – AEO” Information or Items: information or items that
2 is/are extremely confidential and/or sensitive, the disclosure of which to any
3 other Party or Non-Party would create a substantial risk of serious harm,
4 including competitive injury, that could not be avoided by less restrictive
5 means.
6 2.5 Counsel: Outside Counsel of Record (as defined herein) and In-House
7 Counsel (as defined herein), as well as their support staff.
8 2.6 Designating Party: a Party or Non-Party that designates information or items
9 that it produces in disclosures or in responses to discovery as
10 “CONFIDENTIAL” or “CONFIDENTIAL - AEO”.
11 2.7 Disclosure or Discovery Material: all items or information, regardless of the
12 medium or manner in which it is generated, stored, or maintained (including,
13 among other things, testimony, transcripts, and tangible things) that are
14 produced or generated in disclosures or responses to discovery in this matter.
15 2.8 Expert: a person with specialized knowledge or experience in a matter
16 pertinent to the litigation who has been retained by a Party or its Counsel to
17 serve as an Expert or as a consultant in this Action.
18 2.9 In-House Counsel: attorneys who are employees of a party to this Action. In-
19 House Counsel does not include Outside Counsel of Record or any other
20 outside counsel.
21 2.10 Non-Party: any natural person, partnership, corporation, association or other
22 legal entity not named as a Party to this action, including support staff.
23 2.11 Outside Counsel of Record: attorneys who are not employees of a Party to
24 this Action but are retained to represent or advise a Party to this Action and
25 have appeared in this Action on behalf of that Party or are affiliated with a
26 law firm, which has appeared on behalf of that Party, including support staff.
27 2.12 Party: any Party to this Action, including all of its officers, directors,
1 (and their support staff).
2 2.13 Producing Party: a Party or Non-Party that produces Disclosure or Discovery
3 Material in this Action.
4 2.14 Professional Vendors: persons or entities that provide litigation support
5 services (e.g., photocopying, videotaping, translating, preparing exhibits or
6 demonstrations, and organizing, storing, or retrieving data in any form or
7 medium) and their employees and subcontractors.
8 2.15 Protected Material: any Disclosure or Discovery Material that is designated
9 as “CONFIDENTIAL” or “CONFIDENTIAL - AEO”.
10 2.16 Receiving Party: a Party that receives Disclosure or Discovery Material from
11 a Producing Party.
12 3. SCOPE
13 The protections conferred by this Amended Stipulated Protective Order cover
14 not only Protected Material (as defined above), but also (1) any information copied or
15 extracted from Protected Material or information that is otherwise based in whole or
16 in part on Protected Material; (2) all copies, excerpts, summaries, or compilations of
17 Protected Material; and (3) any testimony, conversations, or presentations by Parties
18 or their Counsel that might reveal Protected Material.
19 Any use of Protected Material at trial shall be governed by the orders of the
20 trial judge. This Amended Stipulated Protective Order does not govern the use of
21 Protected Material at trial.
22 4. DURATION
23 Even after final disposition of this litigation, the confidentiality obligations
24 imposed by this Amended Stipulated Protective Order shall remain in effect until a
25 Designating Party agrees otherwise in writing or a court order otherwise directs. Final
26 disposition shall be deemed to be the later of (1) dismissal of all claims and defenses
27 in this Action, with or without prejudice; and (2) final judgment herein after the
1 this Action, including the time limits for filing any motions or applications for
2 extension of time pursuant to applicable law.
3 5. DESIGNATING PROTECTED MATERIAL
4 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each
5 Party or Non-Party that designates information or items for protection under
6 this Amended Stipulated Protective Order must take care to limit any such
7 designation to specific material that qualifies under the appropriate standards.
8 The Designating Party must designate for protection only those parts of
9 material, documents, items or oral or written communications that qualify so
10 that other portions of the material, documents, items or oral or written
11 communications for which protection is not warranted are not swept
12 unjustifiably within the ambit of this Amended Stipulated Protective Order.
13 5.2 Mass, indiscriminate or routinized designations are prohibited. Designations
14 that are shown to be clearly unjustified or that have been made for an
15 improper purpose (e.g., to unnecessarily encumber the case development
16 process or to impose unnecessary expenses and burdens on other parties) may
17 expose the Designating Party to sanctions. If it comes to a Designating
18 Party’s attention that information or items that it designated for protection do
19 not qualify for protection, that Designating Party must promptly notify all
20 other Parties that it is withdrawing the inapplicable designation.
21 5.3 Manner and Timing of Designations. Except as otherwise provided in this
22 Order (see, e.g., second paragraph of section 5.3.1 below), or as otherwise
23 stipulated or ordered, Disclosure or Discovery Material that qualifies for
24 protection under this Amended Stipulated Protective Order must be clearly
25 so designated before the material is disclosed or produced.
26 Designation in conformity with this Order requires:
27 5.3.1 for information in documentary form (e.g., paper or electronic
1 proceedings), that the Producing Party affix at a minimum, the legend
2 “CONFIDENTIAL” or “CONFIDENTIAL - AEO” (hereinafter
3 “CONFIDENTIAL Legend”), to each page that contains protected material.
4 If only a portion or portions of the material on a page qualifies for
5 protection, the Producing Party also must clearly identify the protected
6 portion(s) (e.g., by making appropriate markings in the margins).
7 5.3.2 A Party or Non-Party that makes original documents available for
8 inspection need not designate them for protection until after the inspecting
9 Party has indicated which documents it would like copied and produced.
10 During the inspection and before the designation, all of the material made
11 available for inspection shall be deemed “CONFIDENTIAL.” After the
12 inspecting Party has identified the documents it wants copied and produced,
13 the Producing Party must determine which documents, or portions thereof,
14 qualify for protection under this Amended Stipulated Protective Order.
15 Then, before producing the specified documents, the Producing Party must
16 affix the Confidential Legend to each page that contains Protected Material.
17 If only a portion of the material on a page qualifies for protection, the
18 Producing Party also must clearly identify the protected portion(s) (e.g., by
19 making appropriate markings in the margins).
20 5.3.3 for testimony given in depositions, that the Designating Party make the
21 designation of Protected Material before the close of the deposition.
22 5.3.4 for information produced in some form other than documentary and for
23 any other tangible items, that the Producing Party affix in a prominent place
24 on the exterior of the container or containers in which the information is
25 stored the CONFIDENTIAL Legend. If only a portion or portions of the
26 information warrants protection, the Producing Party, to the extent
27 practicable, shall identify the protected portion(s).
1 to designate qualified information or items does not, standing alone, waive
2 the Designating Party’s right to secure protection under this Amended
3 Stipulated Protective Order for such material. Upon timely correction of a
4 designation, the Receiving Party must make reasonable efforts to assure that
5 the material is treated in accordance with the provisions of this Amended
6 Stipulated Protective Order.
7 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
8 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation
9 of Protected Material at any time that is consistent with the Court’s
10 Scheduling Order.
11 6.2 Meet and Confer. The Challenging Party shall initiate the informal dispute
12 resolution process set forth in the Court's Procedures and Schedules. See
13 http://www.cacd.uscourts.gov/honorable-alka-sagar.
14 6.2.1 The burden of persuasion in any such challenge proceeding shall be on
15 the Designating Party. Frivolous challenges, and those made for an
16 improper purpose (e.g., to harass or impose unnecessary expenses and
17 burdens on other parties) may expose the Challenging Party to sanctions.
18 Unless the Designating Party has waived or withdrawn the confidentiality
19 designation, all parties shall continue to afford the material in question the
20 level of protection to which it is entitled under the Producing Party’s
21 designation until the Court rules on the challenge.
22 7. ACCESS TO AND USE OF PROTECTED MATERIAL
23 7.1 Basic Principles. A Receiving Party may use Protected Material that is
24 disclosed or produced by another Party or by a Non-Party in connection with
25 this Action only for prosecuting, defending or attempting to settle this Action.
26 Such Protected Material may be disclosed only to the categories of persons
27 and under the conditions described in this Amended Stipulated Protective
1 with the provisions of section 13 below (FINAL DISPOSITION).
2 7.1.1 Protected Material must be stored and maintained by a Receiving Party
3 at a location and in a secure manner that ensures that access is limited to the
4 persons authorized under this Amended Stipulated Protective Order.
5 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise
6 ordered by the Court or permitted in writing by the Designating Party, a
7 Receiving Party may disclose any information or item designated
8 “CONFIDENTIAL” only to:
9 7.2.1 the Receiving Party’s Outside Counsel of Record in this Action, as well
10 as employees of said Outside Counsel of Record to whom it is reasonably
11 necessary to disclose the information for this Action;
12 7.2.2 the officers, directors, and employees (including In-House Counsel) of
13 the Receiving Party to whom disclosure is reasonably necessary for this
14 Action;
15 7.2.3 Experts (as defined in this Order) of the Receiving Party to whom
16 disclosure is reasonably necessary for this Action and who have signed
17 the “Acknowledgment and Agreement to Be Bound” (Exhibit A hereto);
18 7.2.4 the Court and its personnel;
19 7.2.5 Court reporters and their staff;
20 7.2.6 professional jury or trial consultants, mock jurors, and Professional
21 Vendors to whom disclosure is reasonably necessary for this Action and
22 who have signed the “Acknowledgment and Agreement to Be Bound”
23 (Exhibit A hereto);
24 7.2.7 the author of the CONFIDENTIAL Information or Items or a custodian
25 or other person who otherwise possessed or knew the CONFIDENTIAL
26 Information or Items;
27 7.2.8 during their depositions, witnesses, and attorneys for witnesses, in the
1 deposing Party requests that the witness sign the “Acknowledgment and
2 Agreement to Be Bound” form attached as Exhibit A hereto; and (2) they
3 will not be permitted to keep any CONFIDENTIAL Information or Items
4 unless they sign the “Acknowledgment and Agreement to Be Bound”
5 form attached as Exhibit A hereto, unless otherwise agreed by the
6 Designating Party or ordered by the Court. Pages of transcribed
7 deposition testimony or exhibits to depositions that reveal Protected
8 Material may be separately bound by the court reporter and may not be
9 disclosed to anyone except as permitted under this Stipulated Protective
10 Order;
11 7.2.9 any mediator or settlement officer, and their supporting personnel,
12 mutually agreed upon by any of the Parties engaged in settlement
13 discussions; and
14 7.2.10 any insurance carrier and/or its representatives to whom disclosure is
15 reasonably necessary, provided that they sign the “Acknowledgment and
16 Agreement to Be Bound” form attached as Exhibit A hereto.
17 7.3 Disclosure of “CONFIDENTIAL - AEO” Information or Items. Unless
18 otherwise ordered by the court or permitted in writing by the Designating
19 Party, a Receiving Party may disclose “CONFIDENTIAL - AEO”
20 Information or Items only to those individuals identified in 7.2.1, 7.2.3-7.2.7
21 and 7.2.9-7.2.10, except that a Receiving Party may in good faith request that
22 the Designating Party consent in writing to the disclosure of particular
23 material designated “CONFIDENTIAL - AEO” Information or Items to one
24 or more representatives of the Receiving Party to whom disclosure is
25 reasonably necessary for this Action. The Receiving Party may seek leave of
26 court to designate such representatives if the Receiving Party believes that
27 the Designating Party has unreasonably withheld such consent. Before
1 designated representative shall sign the “Acknowledgment and Agreement to
2 Be Bound” (Exhibit A).
3 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
4 OTHER LITIGATION
5 8.1 If a Party is served with a subpoena or a court order issued in other litigation
6 that compels disclosure of any Protected Materials designated in this Action,
7 that Party must:
8 8.1.1 promptly notify in writing the Designating Party. Such notification shall
9 include a copy of the subpoena or court order;
10 8.1.2 promptly notify in writing the party who caused the subpoena or order to
11 issue in the other litigation that some or all of the material covered by
12 the subpoena or order is subject to this Amended Stipulated Protective
13 Order. Such notification shall include a copy of this Amended Stipulated
14 Protective Order; and
15 8.1.3 cooperate with respect to all reasonable procedures sought to be pursued
16 by the Designating Party whose Protected Material may be affected.
17 8.2 If the Designating Party timely seeks a protective order, the Party served with
18 the subpoena or court order shall not produce any Protected Material before
19 a determination by the court from which the subpoena or order issued, unless
20 the Party has obtained the Designating Party’s permission. The Designating
21 Party shall bear the burden and expense of seeking protection in that court of
22 its Protected Material and nothing in these provisions should be construed as
23 authorizing or encouraging a Receiving Party in this Action to disobey a
24 lawful directive from another court.
25 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
26 IN THIS LITIGATION
27 9.1 The terms of this Amended Stipulated Protective Order are applicable to
1 “CONFIDENTIAL” or “CONFIDENTIAL - AEO”. Such information
2 produced by Non-Parties in connection with this Action is protected by the
3 remedies and relief provided by this Amended Stipulated Protective Order.
4 Nothing in these provisions should be construed as prohibiting a Non-Party
5 from seeking additional protections.
6 9.2 In the event that a Party is required, by a valid discovery request, to produce
7 a Non-Party’s CONFIDENTIAL Information or Items in its possession, and
8 the Party is subject to an agreement with the Non-Party not to produce the
9 Non-Party’s CONFIDENTIAL Information or Items, then the Party shall:
10 9.2.1 promptly notify in writing the Requesting Party and the Non-Party that
11 some or all of the information requested is subject to a confidentiality
12 agreement with a Non-Party;
13 9.2.2 promptly provide the Non-Party with a copy of the Amended Stipulated
14 Protective Order in this Action, the relevant discovery request(s), and a
15 reasonably specific description of the information requested; and
16 9.2.3 make the information requested available for inspection by the Non-
17 Party, if requested.
18 9.3 If the Non-Party fails to seek a protective order from the relevant court within
19 14 days of receiving the notice and accompanying Information, the Receiving
20 Party may produce the Non-Party’s CONFIDENTIAL Information or Items
21 responsive to the discovery request. If the Non-Party timely seeks a protective
22 order, the Receiving Party shall not produce any information in its possession
23 or control that is subject to the confidentiality agreement with the Non-Party
24 before a determination by the court. Absent a court order to the contrary, the
25 Non-Party shall bear the burden and expense of seeking protection in this
26 court of its Protected Material.
27 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
1 Protected Material to any person or in any circumstance not authorized under
2 this Stipulated Protective Order, the Receiving Party must immediately (a)
3 notify in writing the Designating Party of the unauthorized disclosures, (b)
4 use its best efforts to retrieve all unauthorized copies of the Protected
5 Material, (c) inform the person or persons to whom unauthorized disclosures
6 were made of all the terms of this Amended Stipulated Protective Order, and
7 (d) request such person or persons to execute the “Acknowledgment and
8 Agreement to Be Bound” that is attached hereto as Exhibit A.
9 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
10 PROTECTED MATERIAL
11 11.1 When a Producing Party gives notice to Receiving Parties that certain
12 inadvertently produced material is subject to a claim of privilege or other
13 protection, the obligations of the Receiving Parties are those set forth in
14 Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended
15 to modify whatever procedure may be established in an e-discovery order that
16 provides for production without prior privilege review. Pursuant to Federal
17 Rule of Evidence 502(d) and (e), insofar as the Parties reach an agreement on
18 the effect of disclosure of a communication or information covered by the
19 attorney-client privilege or work product protection, the Parties may
20 incorporate their agreement in the stipulated protective order submitted to the
21 court.
22 12. MISCELLANEOUS
23 12.1 Right to Further Relief. Nothing in this Amended Stipulated Protective Order
24 abridges the right of any person to seek its modification by the Court in the
25 future.
26 12.2 Right to Assert Other Objections. By stipulating to the entry of this Protective
27 Order, no Party waives any right it otherwise would have to object to
1 in this Amended Stipulated Protective Order. Similarly, no Party waives any
2 right to object on any ground to use in evidence of any of the material covered
3 by this Amended Stipulated Protective Order.
4 12.3 Filing Protected Material. A Party that seeks to file under seal any Protected
5 Material must comply with Civil Local Rule 79-5. Protected Material may
6 only be filed under seal pursuant to a Court order authorizing the sealing of
7 the specific Protected Material at issue. If a Party's request to file Protected
8 Material under seal is denied by the Court, then the Receiving Party may file
9 the information in the public record unless otherwise instructed by the Court.
10 13. FINAL DISPOSITION
11 13.1 After the final disposition of this Action, as defined in Paragraph 4, within 60
12 days of a written request by the Designating Party, each Receiving Party must
13 return all Protected Material to the Producing Party or destroy such material.
14 As used in this subdivision, “all Protected Material” includes all copies,
15 abstracts, compilations, summaries, and any other format reproducing or
16 capturing any of the Protected Material. Whether the Protected Material is
17 returned or destroyed, the Receiving Party must submit a written certification
18 to the Producing Party (and, if not the same person or entity, to the
19 Designating Party) by the 60 day deadline that (1) identifies (by category,
20 where appropriate) all the Protected Material that was returned or destroyed
21 and (2) affirms that the Receiving Party has not retained any copies, abstracts,
22 compilations, summaries or any other format reproducing or capturing any of
23 the Protected Material. Notwithstanding this provision, Counsel are entitled
24 to retain an archival copy of all pleadings, motion papers, trial, deposition,
25 and hearing transcripts, legal memoranda, correspondence, deposition and
26 trial exhibits, expert reports, attorney work product, and consultant and expert
27 work product, even if such materials contain Protected Material. Any such
1 to this Protective Order as set forth in Paragraph 4.
2 14. Any violation of this Amended Stipulated Protective Order may be punished by
3 any and all appropriate measures including, without limitation, contempt
4 proceedings and/or monetary sanctions.
5 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
6 Respectfully Submitted,
7 DATED: June 17, 2025 EPSTEIN DRANGEL LLP
8
BY: /s/ Grace A. Rawlins
9
Grace A. Rawlins
10 Attorneys for Plaintiff

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DATED: June 17, 2025 GLACIER LAW LLP
14
BY: /s/Tianyu Ju
15 Tianyu Ju
Attorneys for Defendant
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1 FOR GOOD CAUSE SHOWN, the Amended Stipulated Protective Order, filed on
2
June 17, 2025 (ECF 165), IS SO ORDERED.
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/s/
5 DATED: JUNE 20, 2025 __________________________________
6 Honorable Alka Sagar
United States Magistrate Judge
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1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3
4 I, _____________________________ [print or type full name], of
5 _________________ [print or type full address], declare under penalty of perjury that
6 I have read in its entirety and understand the Amended Stipulated Protective Order
7 that was issued by the US District Court, Central District of California, on
8 _______________ in the case of AirDoctor, LLC v. Lonni, Inc. et al., 2:23-cv-00353-
9 GW-AS, I agree to comply with and to be bound by all the terms of this Amended
10 Stipulated Protective Order and I understand and acknowledge that failure to so
11 comply could expose me to sanctions and punishment in the nature of contempt. I
12 solemnly promise that I will not disclose in any manner any information or item that
13 is subject to this Amended Stipulated Protective Order to any person or entity except
14 in strict compliance with the provisions of this Order.
15
16 I further agree to submit to the jurisdiction of the US District Court, Central District
17 of California, for enforcing the terms of this Amended Stipulated Protective Order,
18 even if such enforcement proceedings occur after termination of this action. I hereby
19 appoint __________________________ [print or type full name] of
20 _______________________________________ [print or type full address and
21 telephone number] as my California agent for service of process in connection with
22 this action or any proceedings related to enforcement of this Stipulated Protective
23 Order.
24 Date: ______________________________________
25 City and State where sworn and signed: _________________________________
26
27 Printed name: _______________________________

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11081328. Public record. Not legal advice.