Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION (DAYTON)

BEDFORD SIGNALS CORPORATION, : CASE NO. 3:24-cv-00223

Plaintiff/Counterclaim Defendant, : (Judge Michael J. Newman)

v. : (Magistrate Judge Caroline H. Gentry)

RESONANT SCIENCES LLC, :

Defendant/Counterclaim Plaintiff. :

:

_________________________________________

AMENDED STIPULATED PROTECTIVE ORDER

Pursuant to the parties’ joint request that the Court enter this Order, and their agreement

that the following limitations and restrictions should apply to documents and information produced

for inspection and copying during the course of this litigation (the “Action”), the Court hereby

ORDERS that:

1. Scope. This Protective Order (hereinafter “Protective Order” or “Order”) shall

apply to all documents or other information produced in the course of discovery in this Action that

the producing person or entity (the “Producing Entity”) has designated as “CONFIDENTIAL –

SUBJECT TO PROTECTIVE ORDER” or “ATTORNEYS’ EYES ONLY – SUBJECT TO

PROTECTIVE ORDER” (either a “Confidentiality Designation” or collectively the

“Confidentiality Designations”) pursuant to this Order, including but not limited to, all initial

disclosures, all responses to discovery requests, all deposition testimony and exhibits, and all

materials (including documents or testimony) produced by non-parties in response to subpoenas

issued in connection with this matter, including all copies, excerpts, and summaries thereof

(collectively the “Confidential Information”).

2. Purpose. The purpose of this Protective Order is to protect against the unnecessary

disclosure of Confidential Information.

3. Disclosure Defined. As used herein, “disclosure” or “to disclose” means to

divulge, reveal, describe, summarize, paraphrase, quote, transmit, or otherwise communicate

Confidential Information, and the restrictions contained herein regarding disclosure of

Confidential Information also apply with equal force to any copies, excerpts, analyses, or

summaries of such materials or the information contained therein, as well as to any pleadings,

briefs, exhibits, transcripts or other documents which may be prepared in connection with this

litigation which contain or refer to the Confidential Information or information contained therein.

4. Designating Material

a. Designating Material As Confidential: Any party, or any third party

subpoenaed by one of the parties, may designate as Confidential and subject to this

Protective Order any documents, testimony, written responses, or other materials produced

in this case if they contain information that the Producing Entity asserts in good faith is

protected from disclosure by statute or common law, including, but not limited to,

confidential personal information, medical or psychiatric information, trade secrets,

personnel records, or such other sensitive commercial information that is not publicly

available. Information that is publicly available may not be designated as Confidential. The

designation of materials as Confidential pursuant to the terms of this Protective Order does

not mean that the document or other material has any status or protection by statute or

otherwise except to the extent and for the purposes of this Order.

b. Designating Material As Attorneys’ Eyes Only. Any party, or any third

party subpoenaed by one of the parties, may designate as Attorneys’ Eyes Only and subject

to this Protective Order any materials or information that meet the test set forth in

Paragraph 4.a, but as to which the Producing Entity also asserts in good faith that the

information is so competitively sensitive that the receipt of the information by parties to

the litigation could result in competitive harm to the Producing Entity.

5. Form and Timing Of Designation.

a. Documents And Written Materials. The Producing Entity shall designate

any document or other written materials as confidential pursuant to this Order by marking

each page of the material with a stamp setting forth the Confidentiality Designation, if

practical to do so. The person or entity designating the material shall place the stamp, to

the extent possible, in such a manner that it will not interfere with the legibility of the

document. Materials shall be so-designated prior to, or at the time of, their production or

disclosure.

b. Electronically Stored Information (“ESI”): If a production response

includes ESI, the Producing Entity shall make an effort to include within the electronic

files themselves the Confidentiality Designation to the extent practicable. If that is not

practicable, then the Producing Entity shall designate in a transmittal letter or email to the

party to whom the materials are produced (the “Receiving Party”) using a reasonable

identifier (e.g., the Bates range) any portions of the ESI that should be treated as

“CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” and any portions of the ESI

that should be treated as “ATTORNEYS’ EYES ONLY – SUBJECT TO PROTECTIVE

ORDER.”

c. Deposition Testimony. Deposition testimony will be deemed confidential

only if designated as such when the deposition is taken or within fourteen (14) days after

receipt of the deposition transcript. Such designation must indicate which Confidentiality

Designation applies, and must be specific as to the portions of the transcript and/or any

exhibits to which that Confidentiality Designation applies, except that any exhibit that was

marked with a Confidentiality Designation at the time of production, and which still bears

that mark at the time of its use in a deposition, shall be presumed to fall within the

provisions of this Order without further designation.

6. Limitation Of Use.

a. General Protections. All information that has received a Confidentiality

Designation, including all information derived therefrom, shall be used by any Receiving

Party solely for purposes of prosecuting or defending this Action. A Receiving Party shall

not use or disclose the Confidential Information for any other purpose, including but not

limited to any business, commercial, or competitive purpose. Except as set forth in this

Order, a Receiving Party shall not disclose Confidential Information to any third party.

This Order shall not prevent the Producing Entity from using or disclosing information it

has designated as Confidential Information, and that belongs to the Producing Entity, for

any purpose that the Producing Entity deems appropriate, except that the Producing

Entity’s voluntary disclosure of Confidential Information outside the scope of this Action

may impact the protection that this Order would otherwise provide with regard to such

information, once disclosed.

b. Persons To Whom Information Marked “Confidential” May Be

Disclosed. Use of any information, documents, or portions of documents marked

“CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” including all information

derived therefrom, shall be restricted solely to the following persons who agree to be bound

by the terms of this Protective Order, unless additional persons are stipulated by counsel

or authorized by the Court:

1. outside counsel of record for the parties, and the administrative staff of

outside counsel's firms;

2. in-house counsel for the parties, and the administrative staff for each in-

house counsel;

3. any party to this action who is an individual;

4. as to any party to this action who is not an individual, every employee,

director, officer, or manager of that party, but only to the extent necessary

to further the interest of the parties in this litigation;

5. independent consultants or expert witnesses (including partners, associates

and employees of the firm which employs such consultant or expert)

retained by a party or its attorneys for purposes of this litigation, but only to

the extent necessary to further the interest of the parties in this litigation,

and only after such persons have completed the certification attached hereto

as Attachment A, Acknowledgment of Understanding and Agreement to be

Bound;

6. the Court and its personnel, including, but not limited to, stenographic

reporters regularly employed by the Court and stenographic reporters not

regularly employed by the Court who are engaged by the Court or the parties

during the litigation of this action;

7. the authors and the original recipients of the documents;

8. any court reporter or videographer reporting a deposition;

9. employees of copy services, microfilming or database services, trial support

firms, and/or translators who are engaged by the parties during the litigation

of this action;

10. interviewees, potential witnesses, deponents, hearing or trial witnesses, and

any other person, where counsel for a party to this action in good faith

determines the individual should be provided access to such information in

order for counsel to more effectively prosecute or defend this action (as long

as the disclosure occurs in the presence of counsel, and copies, duplicates,

images, or the like are not removed or retained by any interviewee, potential

witness, deponent, or hearing or trial witness), provided, however, that in

all such cases the individual to whom disclosure is to be made has been

informed that the information contained in the disclosed document(s) is

confidential and protected by Court Order, that the individual understands

that he/she is prohibited from disclosing any information contained in the

document(s) to anyone; or

11. any other person agreed to in writing by the parties.

Prior to being shown any documents produced by another party marked “CONFIDENTIAL –

SUBJECT TO PROTECTIVE ORDER,” any person listed under paragraph 6(b)(3), 6(b)(4), or

6(b)(11) shall be advised that the confidential information is being disclosed pursuant to and

subject to the terms of this Protective Order.

c. Persons To Whom Information Marked “Attorneys’ Eyes Only” May

Be Disclosed. Use of any information, documents, or portions of documents marked

“ATTORNEYS’ EYES ONLY – SUBJECT TO PROTECTIVE ORDER,” including all

information derived therefrom, shall be restricted solely to the following persons who agree

to be bound by the terms of this Protective Order, unless additional persons are stipulated

by counsel or authorized by the Court:

1. outside counsel of record for the parties, and the administrative staff of

outside counsel's firms;

2. independent consultants or expert witnesses (including partners, associates

and employees of the firm which employs such consultant or expert)

retained by a party or its attorneys for purposes of this litigation, but only to

the extent necessary to further the interest of the parties in this litigation,

and only after such persons have completed the certification attached hereto

as Attachment A, Acknowledgment of Understanding and Agreement to be

Bound;

3. the Court and its personnel, including, but not limited to, stenographic

reporters regularly employed by the Court and stenographic reporters not

regularly employed by the Court who are engaged by the Court or the parties

during the litigation of this action;

4. the authors and the original recipients of the documents;

5. any court reporter or videographer reporting a deposition;

6. employees of copy services, microfilming or database services, trial support

firms, and/or translators who are engaged by the parties during the litigation

of this action;

7. any other person agreed to in writing by the parties.

Prior to being shown any documents produced by another party marked “ATTORNEYS’ EYES

ONLY – SUBJECT TO PROTECTIVE ORDER,” any person listed under paragraph 6(c)(8) shall

be advised that the confidential information is being disclosed pursuant to and subject to the terms

of this Protective Order.

7. Special Protection for CUI, Export Controlled, and FOUO Information.

Notwithstanding any other provision of this Order, any document, or other information produced

in the course of discovery in this Action that is marked or otherwise identified as containing

Controlled Unclassified Information ("CUI"), is marked or otherwise identified as Export

Controlled, or is marked or otherwise identified as For Official Use Only ("FOUO") shall be

handled in strict compliance with all applicable federal laws, regulations, and executive orders

governing such information.

a. Controlled Unclassified Information. To the extent that any materials

produced in this Action contain information designated as CUI, the receiving parties shall

handle and safeguard such information in accordance with Department of Defense

Instruction 5200.48, or any successor guidance, which governs the marking, safeguarding,

dissemination, and destruction of CUI.

c. Export Controlled Information. To the extent that any materials produced

in this Action contain information designated as Export Controlled or containing

information controlled under EAR or ITAR, the receiving parties shall comply with all

applicable requirements of the Export Administration Regulations, codified at 15 C.F.R.

parts 730–774, Title 50, U.S.C., Chapter 58, Sec. 4801-4852, Title 22, U.S.C., Sec 2751,

et seq., and Department of Defense Directive 5230.25, including but not limited, to

restrictions on the disclosure of export-controlled technical data to foreign person.

d. For Official Use Only Information. To the extent that any materials are

marked FOUO or otherwise identified as sensitive but unclassified information pursuant to

legacy federal agency practices, the parties shall treat such information with the same level

of care required for CUI and shall not disclose it to unauthorized individuals. Where

FOUO-marked material qualifies as CUI under current guidance, it shall be treated

accordingly.

c. Compliance and Non-Disclosure. All parties and their counsel agree not

to disclose, distribute, or otherwise make available any CUI, Export Controlled, EAR,

ITAR, or FOUO-marked materials to any individual or entity not authorized to receive

such information under applicable law. The parties shall implement appropriate safeguards

to prevent any unauthorized access, transmission, or disclosure.

d. Additional Obligations Not Waived. Nothing in this Order shall be

construed to supersede, limit, or waive any additional obligations or restrictions imposed

by federal law concerning the handling of CUI, Export Controlled, EAR, ITAR, or FOUO

materials. All parties remain independently responsible for ensuring compliance with all

applicable statutes, regulations, and directives.

e. Conflicts. In the event of any conflict between the terms of this Order and

any applicable law or regulation concerning CUI, Export Controlled, EAR, ITAR, or

FOUO materials, the applicable law or regulation shall control.

8. Inadvertent Production. Inadvertent production of any document or information

with a Confidentiality Designation shall be governed by Fed. R. Evid. 502. Pursuant to subsections

(d) and (e) of that Rule, the parties agree to, and the Court orders, protection of Protected

Information against claims of waiver (including against third parties and in other Federal and State

proceedings) in the event such information is produced during the course of the Litigation, whether

pursuant to a Court order, a parties’ discovery request, or informal production, as follows:

a. the production of documents or electronically stored information (“ESI”)

(including, without limitation, metadata) subject to a legally recognized claim of

privilege or other protection from production or other disclosure (collectively,

“Protected Information”), including without limitation the attorney-client privilege

and work-product doctrine, shall in no way constitute the voluntary disclosure of

such Protected Information;

b. the production of Protected Information shall not result in the waiver of any

privilege or protection associated with such Protected Information as to the

receiving party, or any third parties, and shall not result in any waiver of protection,

including subject matter waiver, of any kind;

c. if any document or ESI (including, without limitation, metadata) received by a party

is on its face clearly subject to a legally recognizable privilege, immunity, or other

right not to produce such information, the Receiving Party will promptly notify the

Producing Entity in writing that it has discovered Protected Information, identify

the Protected Information by Bates Number range, and return or sequester such

Protected Information until the Producing Entity confirms whether it does indeed

assert any privilege protecting this information. Once the Producing Entity asserts

privilege over such Protected Information (as described in Subparagraph (e)

below), the Receiving Party will return, sequester, or destroy all copies of such

Protected Information, along with any notes, abstracts or compilations of the

content thereof, within ten (10) business days of notice from the Producing Entity;

d. upon the request of the Producing Entity, the Receiving Party will promptly

disclose the names of any individuals who have read or have had access to the

Protected Information;

e. if the Producing Entity intends to assert a claim of privilege or other protection over

Protected Information identified by the receiving party, the Producing Entity will,

within ten (10) business days of receiving the Receiving Party’s written

notification, inform the Receiving Party of such intention in writing and shall

provide the Receiving Party with a log for such Protected Information that is

consistent with the requirements of the Federal Rules of Civil Procedure, setting

forth the basis for the claim of privilege, immunity or basis for non-disclosure, and

in the event, if any portion of the Protected Information does not contain privileged

or protected information, the Producing Entity shall also provide to the Receiving

Party a redacted copy of the Protected Information that omits the information that

the Producing Entity believes is subject to a claim of privilege, immunity or other

protection;

f. if, during the course of the litigation, a party determines it has produced Protected

Information, the Producing Entity may notify the Receiving Party of such

production in writing. The Producing Entity’s written notice must identify the

Protected Information by Bates Number range, the privilege or protection claimed,

and the basis for the assertion of the privilege and shall provide the receiving party

with a log for such Protected Information that is consistent with the requirements

of the Federal Rules of Civil Procedure, setting forth the basis for the claim of

privilege, immunity or basis for non-disclosure, and in the event any portion of the

Protected Information does not contain privileged or protected information, the

Producing Entity shall also provide to the receiving party a redacted copy of the

Protected Information that omits the information that the Producing Entity believes

is subject to a claim of privilege, immunity or other protection. The Producing

Entity must also demand the return of the Protected Information. After receiving

such written notification, the Receiving Party must, within ten (10) business days

of receiving the written notification, return, sequester, or destroy the specified

Protected Information and any copies, along with any notes, abstracts or

compilations of the content thereof;

g. a Receiving Party’s return, sequestration, or destruction of such Protected

Information as provided in the Subparagraphs above will not act as a waiver of the

Receiving Party’s right to move for the production of the returned, sequestered, or

destroyed Protected Information on grounds that the Protected Information is not

in fact subject to a viable claim of privilege or other protection. However, the

Receiving Party is prohibited and estopped from arguing that the Producing

Entity’s production of the Protected Information in this matter acts as a waiver of

applicable privileges or protections, that the disclosure of the Protected Information

by the Producing Entity was not inadvertent, that the Producing Entity did not take

reasonable steps to prevent the disclosure of the Protected Information, or that the

Producing Entity did not take reasonable steps to rectify such disclosure; and

h. nothing contained herein is intended to or shall limit a Producing Entity’s right to

conduct a review of documents or ESI (including, without limitation, metadata), for

relevance, responsiveness, and/or the segregation of privileged and/or protected

information before such information is produced to the Receiving Party;

i. prior to production to another party, all copies, electronic images, duplicates,

extracts, summaries, or descriptions (collectively “copies”) of documents marked

with a Confidentiality Designation under this Order, or in any individual portion of

such a document, shall be affixed with the same Confidentiality Designation if it

does not already appear on the copy. All such copies shall thereafter be entitled to

the protection of this Order. The term “copies” shall not include indices, electronic

databases, or lists of documents provided these indices, electronic databases, or lists

do not contain substantial portions or images of the text of confidential documents

or otherwise disclose the substance of the confidential information contained in

those documents.

9. Filing Materials Containing Information With A Confidentiality Designation.

In the event a party seeks to file with the Court any confidential information subject to protection

under this Order, that party must take appropriate action to ensure that the document receives

proper protection from public disclosure, including: (a) filing a redacted document with the

consent of the party who designated the document as confidential; (b) where appropriate (e.g., in

relation to discovery and evidentiary motions), submitting the document solely for in camera

review; or (c) when the preceding measures are inadequate, seeking permission to file the

document under seal by filing a motion for leave to file under seal.

Any motion to file a document subject to this Order under seal must meet the Sixth Circuit’s

standard set forth in Shane Group, Inc. v. Blue Cross Blue Shield of Michigan, 825 F.3d 299 (6th

Cir. 2016). The burden of demonstrating the need for and appropriateness of a sealing order is

borne by the moving party, and requires the moving party to analyze in detail, document by

document, the propriety of secrecy, providing reasons and legal citations. Regardless of whether

the parties agree, it remains the Court’s independent obligation to determine whether a seal is

appropriate for any given document or portion thereof. Any proposed sealing, even when

compelling reasons exist, must be narrowly tailored to serve the compelling reasons.

When a party to this Order seeks to file documents which it believes may warrant sealing,

but is not the party who may be prejudiced by the document or documents becoming part of the

public record, the filing party shall provide the potentially-prejudiced party or parties, or any

potentially-prejudiced third party or parties, with written notification of its intent to file such

documents at least (14) fourteen days before doing so. After being provided such notice, the

potentially harmed party or parties will then have (7) seven days to file with the Court a motion

for sealing. The Court will rule on the motion as promptly as possible.

10. Attorneys Allowed To Provide Advice. Nothing in this Order shall bar or

otherwise restrict any attorney for any party from rendering advice to his or her client with respect

to this case or from doing anything necessary to prosecute or defend this case and furthering the

interests of his or her client, except for the disclosure of the Confidential Information as proscribed

in this Order.

11. Excluding Others From Access. Whenever information bearing a Confidentiality

Designation pursuant to this Protective Order is to be discussed at a deposition, the person or entity

that designated the information may exclude from the room any person, other than persons

designated in Paragraph 6 of this Order, as appropriate, for that portion of the deposition.

12. No Voluntary Disclosure To Other Entities. The parties or anyone acting on their

behalf may not voluntarily disclose any Confidential Information to any state or federal law

enforcement or regulatory agency, or any employee thereof, except in this litigation as set forth in

Paragraph 6 of this Order or as otherwise commanded by law or provided in this Order. Nothing

in this Order shall prevent a party from providing information in its possession in response to a

valid order or subpoena from a law enforcement or regulatory agency requiring the production of

such information, except that, prior to such production, the party producing the information shall

provide as much advance notice as possible to the person or entity that designated the material as

confidential to facilitate that party’s efforts to preserve the confidentiality of the material, if

warranted.

13. Disputes As To Designations. Each party has the right to dispute the

Confidentiality Designation asserted by any other party or subpoenaed person or entity in

accordance with this Protective Order. If a party believes that any documents or materials have

been inappropriately designated by another party or subpoenaed party, that party shall confer with

counsel for the person or entity that designated the documents or materials. As part of that

conferral, the designating person or entity must assess whether redaction is a viable alternative to

complete non-disclosure. If any party challenges the Confidentiality Designation of any document

or information, the burden to properly maintain the designation shall, at all times, remain with the

person or entity that made the designation to show that said document or information should

remain protected pursuant to Federal Civil Rule 26(c). In the event of disagreement, then the

designating person or entity shall file a motion pursuant to Federal Civil Rule 26(c). A party who

disagrees with the designation must nevertheless abide by that designation until the matter is

resolved by agreement of the parties or by order of the Court.

14. Information Security Protections. Any person in possession of Confidential

Information received from another person or entity in connection with this Action shall maintain

an information security program that includes reasonable administrative, technical, and physical

safeguards designed to protect the security and confidentiality of such Confidential Information,

protect against any reasonably anticipated threats or hazards to the security of such Confidential

Information, and protect against unauthorized access to or use of such Confidential Information.

If a Receiving Party discovers a breach of security, including any actual or suspected unauthorized

access, to Confidential Information subject to this Order, they shall: (1) notify the person or entity

who designated the materials under the terms of this Order of such breach; (2) investigate and take

reasonable efforts to remediate the effects of the breach; and (3) provide sufficient information

about the breach that the Producing Entity can reasonably ascertain the size and scope of the

breach. The Receiving Party agrees to cooperate with the Producing Entity or law enforcement in

investigating any such security incident. In any event, the Receiving Party shall promptly take all

necessary and appropriate corrective action to terminate the unauthorized access.

15. All Trials Open To Public. All trials, and certain pretrial proceedings and

hearings, are open to the public (collectively a “Public Hearing” or “Public Hearings”). Absent

further order of the Court, there will be no restrictions on any Party’s ability to the use during a

Public Hearing any document or information that has marked with a Confidentiality Designation

or documents or information derived therefrom that would disclose such confidential information.

However, if a party intends to present at a Public Hearing any document or information that has

been so designated, the party intending to present such document or information shall provide

advance notice to the person or entity that made the Confidentiality Designation at least (5) five

days before the Public Hearing by identifying the documents or information at issue as specifically

as possible (i.e., by Bates Number, page range, deposition transcript line, etc.) without divulging

the actual documents or information. Any person may then seek appropriate relief from the Court

regarding restrictions on the use of such documents or information at trial, or sealing of the

courtroom, if appropriate.

16. No Waiver Of Right To Object. This Order does not limit the right of any party

to object to the scope of discovery in the above-captioned action.

17. No Determination Of Admissibility. This Order does not constitute a

determination of the admissibility or evidentiary foundation for the documents or a waiver of any

party’s objections thereto.

18. No Admissions. Designation by either party of information or documents under the

terms of this Order, or failure to so designate, will not constitute an admission that information or

documents are or are not confidential or trade secrets. Neither party may introduce into evidence

in any proceeding between the parties, other than a motion to determine whether the Protective

Order covers the information or documents in dispute, the fact that the other party designated or

failed to designate information or documents under this Order.

19. No Prior Judicial Determination. This Order is based on the representations and

agreements of the parties and is entered for the purpose of facilitating discovery in this action.

Nothing in this Order shall be construed or presented as a judicial determination that any

documents or information as to which counsel or the parties made a Confidentiality Designation

is in fact subject to protection under Rule 26(c) of the Federal Rules of Civil Procedure or

otherwise until such time as the Court may rule on a specific document or issue.

20. Order Subject To Modification. This Order shall be subject to modification by

the Court on its own motion or on motion of a party or any other person with standing concerning

the subject matter.

21. Parties May Consent To Disclosure. Nothing shall prevent disclosure beyond the

terms of this Order if all parties consent to such disclosure, or if the Court, after notice to all

affected parties, permits such disclosure. Specifically, if and to the extent any party wishes to

disclose any Confidential Information beyond the terms of this Order, that party shall provide all

other parties with reasonable notice in writing of its request to so disclose the materials. If the

parties cannot resolve their disagreement with respect to the disclosure of any Confidential

Information, then a party may petition the Court for a determination of these issues. In addition,

any interested member of the public may also challenge the designation of any material as

confidential, pursuant to the terms of this paragraph.

22. Return Of Materials Upon Termination Of Litigation. Upon the written request

and expense of the Producing Entity, within sixty (60) days after the entry of a final judgment no

longer subject to appeal on the merits of this case, or the execution of any agreement between the

parties to resolve amicably and settle this case, the parties and any person authorized by this

Protective Order to receive confidential information shall return to the Producing Entity, or

destroy, all information and documents subject to this Protective Order, unless the specific

document or information has been offered into evidence or filed without restriction as to

disclosure. The party requesting the return of materials shall pay the reasonable costs of responding

to its request. The party returning or destroying the documents or other information shall certify

that it has not maintained any copies of confidential information, except as permitted by this Order.

23. Counsel Allowed To Retain Copy Of Filings. Nothing in this Protective Order

shall prevent outside counsel for a party from maintaining in its files a copy of any filings in the

Action, including any such filings that incorporate or attach Confidential Information. Moreover,

an attorney may use his or her work product in subsequent litigation provided that such use does

not disclose any Confidential Information.

SO ORDERED.

Dated: October 17, 2025 s/ Caroline H. Gentry

United States Magistrate Judge

AGREED TO:

/s/ Kaitlyn C. Meeks (per 10/12/25 email /s/ Brian D. Wright

authorization) Brian D. Wright (0075359)

Toby K. Henderson, Esq. (0071378) Trial Attorney

Kaitlyn C. Meeks (0098949) Melissa L. Watt (0092305)

SEBALY SHILLITO + DYER Dalton L. Stewart (0105063)

A Legal Professional Association FARUKI PLL

220 East Monument Avenue, Suite 500 110 North Main Street, Suite 1600

Dayton, OH 45402 Dayton, OH 45402

Telephone: (937) 222-2500 Telephone: (937) 227-3700

Fax: (937) 222-6554 Fax: (937) 227-3717

Email: thenderson@ssdlaw.com Email: bwright@ficlaw.com

kmeeks@ssdlaw.com mwatt@ficlaw.com

dstewart@ficlaw.com

Sean J. O’Hara (#024749)

Attorneys for Defendant/Counterclaim Plaintiff

Eric B. Hull (#023934)

Resonant Sciences LLC

KERCSMAR & O’HARA PLLC

8800 East Raintree Drive, Suite 310

Scottsdale, Arizona 85260

Telephone: (480) 421-1001

Facsimile: (480) 421-1002

sjo@KandOlaw.com

ebh@KandOlaw.com

Attorneys for Plaintiff/Counterclaim

Defendant Bedford Signals Corporation

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION (DAYTON)

BEDFORD SIGNALS CORPORATION, : CASE NO. 3:24-cv-00223

Plaintiff/Counterclaim Defendant, : (Judge Michael J. Newman)

v. : (Magistrate Judge Caroline H. Gentry)

RESONANT SCIENCES LLC, :

Defendant/Counterclaim Plaintiff. :

:

_________________________________________

FORM PROTECTIVE ORDER

ATTACHMENT A

The undersigned hereby acknowledges that [he/she] has read the Protective Order dated

[INSERT DATE OF OPERATIVE PROTECTIVE ORDER] in the above-captioned action and

attached hereto, understands the terms thereof, and agrees to be bound by its terms. The

undersigned submits to the jurisdiction of the United States District Court for the Southern District

of Ohio in matters relating to the Protective Order and understands that the terms of the Protective

Order obligate [him/her] to use documents designated “CONFIDENTIAL – SUBJECT TO

PROTECTIVE ORDER” or “ATTORNEYS’ EYE ONLY – SUBJECT TO PROTECTIVE

ORDER” in accordance with the Order, solely for the purpose of the above-captioned action, and

not to disclose any such documents or information derived directly therefrom to any other person,

firm, or concern.

The undersigned acknowledges that violation of the Protective Order may result in

penalties for contempt of court.

Name:

Job Title:

Employer:

Business Address:

Date:

Signature

4918-6744-9200.2