Opinion

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8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 TAKE-TWO INTERACTIVE CASE NO. 2:25-cv-01880-ODW (JDEx)

SOFTWARE, INC.,

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Judge: Hon. Otis D. Wright, II

Plaintiff,

12 Magistrate Judge: Hon. John D. Early

v.

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PLAYERAUCTIONS, INC., a company STIPULATED PROTECTIVE

14 organized under the laws of Delaware; ORDER

IMI EXCHANGE LLC, a company

15 organized under the laws of Delaware;

PAIAO NETWORK TECHNOLOGY

16 (SHANGHAI) CO., LTD. (拍奥网络科

技（上海）有限公司), a/k/a

17 PLAYERAUCTIONS (SH) CO. LTD., a

company organized under the laws of

18 China; and DOES 1 through 10,

inclusive,

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Defendants.

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21 Based on the Parties’ Stipulation (Dkt. 43) and for good cause shown, the

22 Court finds and orders as follows.

23 1. PURPOSES AND LIMITATIONS

24 Discovery in this action is likely to involve production of confidential,

25 proprietary or private information for which special protection from public

26 disclosure and from use for any purpose other than pursuing this litigation may be

27 warranted. This Order does not confer blanket protections on all disclosures or

responses to discovery and the protection it affords from public disclosure and use

1 extends only to the limited information or items that are entitled to confidential

2 treatment under the applicable legal principles.

3 2. GOOD CAUSE STATEMENT

4 This action is likely to involve trade secrets, customer and pricing lists and

5 other valuable research, development, commercial, financial, technical and/or

6 proprietary information for which special protection from public disclosure and

7 from use for any purpose other than prosecution of this action is warranted. Such

8 confidential and proprietary materials and information consist of, among other

9 things, confidential business or financial information, information regarding

10 confidential business practices, or other confidential research, development, or

11 commercial information (including information implicating privacy rights of third

12 parties), information otherwise generally unavailable to the public, or which may

13 be privileged or otherwise protected from disclosure under state or federal statutes,

14 court rules, case decisions, or common law. Accordingly, to expedite the flow of

15 information, to facilitate the prompt resolution of disputes over confidentiality of

16 discovery materials, to adequately protect information the parties are entitled to

17 keep confidential, to ensure that the parties are permitted reasonable necessary uses

18 of such material in preparation for and in the conduct of trial, to address their

19 handling at the end of the litigation, and serve the ends of justice, a protective order

20 for such information is justified in this matter. It is the intent of the parties that

21 information will not be designated as confidential for tactical reasons and that

22 nothing be so designated without a good faith belief that it has been maintained in

23 a confidential, non-public manner, and there is good cause why it should not be

24 part of the public record of this case.

25 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE

26 The parties further acknowledge, as set forth in Section 14.3, below, that this

27 Stipulated Protective Order does not entitle them to file confidential information

1 under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed

2 and the standards that will be applied when a party seeks permission from the court

3 to file material under seal. There is a strong presumption that the public has a right

4 of access to judicial proceedings and records in civil cases. In connection with non-

5 dispositive motions, good cause must be shown to support a filing under seal. See

6 Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006),

7 Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-

8 Welbon v. Sony Electrics, Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even

9 stipulated protective orders require good cause showing), and a specific showing of

10 good cause or compelling reasons with proper evidentiary support and legal

11 justification, must be made with respect to Protected Material that a party seeks to

12 file under seal. The parties’ mere designation of Disclosure or Discovery Material

13 as CONFIDENTIAL does not— without the submission of competent evidence by

14 declaration, establishing that the material sought to be filed under seal qualifies as

15 confidential, privileged, or otherwise protectable—constitute good cause.

16 Further, if a party requests sealing related to a dispositive motion or trial,

17 then compelling reasons, not only good cause, for the sealing must be shown, and

18 the relief sought shall be narrowly tailored to serve the specific interest to be

19 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.

20 2010). For each item or type of information, document, or thing sought to be filed

21 or introduced under seal, the party seeking protection must articulate compelling

22 reasons, supported by specific facts and legal justification, for the requested sealing

23 order. Again, competent evidence supporting the application to file documents

24 under seal must be provided by declaration.

25 Any document that is not confidential, privileged, or otherwise protectable

26 in its entirety will not be filed under seal if the confidential portions can be

27 redacted. If documents can be redacted, then a redacted version for public viewing,

1 omitting only the confidential, privileged, or otherwise protectable portions of the

2 document, shall be filed. Any application that seeks to file documents under seal in

3 their entirety should include an explanation of why redaction is not feasible.

4 4. DEFINITIONS

5 4.1 Action: Take-Two Interactive Software, Inc. vs. PlayerAuctions, Inc.,

6 et al. – Case No. 2:25-cv-01880-ODW (JDEx).

7 4.2 Challenging Party: a Party or Non-Party that challenges the

8 designation of information or items under this Order.

9 4.3 “CONFIDENTIAL” Information or Items: information (regardless of

10 how it is generated, stored or maintained) or tangible things that qualify for

11 protection under Federal Rule of Civil Procedure 26(c), and as specified above in

12 the Good Cause Statement.

13 4.4 CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE

14 SECRET/COMMERCIALLY SENSITIVE)” Information or Items: information

15 (regardless of how it is generated, stored or maintained) or tangible things that

16 qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified

17 above in the Good Cause Statement, and which are available only for review as

18 specified below in section 9.3.

19 Material designated as “CONFIDENTIAL – ATTORNEYS’ EYES ONLY

20 (TRADE SECRET/COMMERCIALLY SENSITIVE)” may include the following

21 types of information: (1) sensitive technical information, including current research

22 and development information; (2) sensitive business information, including highly

23 sensitive financial or marketing information; (3) competitive technical information,

24 including technical analyses or comparisons of competitor’s products or services;

25 (4) competitive business information, including non-public financial and marketing

26 analyses, and strategic product/service expansion plans; (5) personal health or

27 medical information; (6) personally identifiable information, including “personal

1 information” as defined under the California Consumer Privacy Act; (7) an

2 individual’s personal credit, banking or other financial information; or (8) any

3 other commercially sensitive information the disclosure of which to non-qualified

4 persons subject to this Order the producing party reasonably and in good faith

5 believes would likely cause harm.

6 4.5 Counsel: Outside Counsel of Record and House Counsel (as well as

7 their support staff).

8 4.6 Designating Party: a Party or Non-Party that designates information or

9 items that it produces in disclosures or in responses to discovery as

10 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY

11 (TRADE SECRET/COMMERCIALLY SENSITIVE).”

12 4.7 Disclosure or Discovery Material: all items or information, regardless

13 of the medium or manner in which it is generated, stored, or maintained (including,

14 among other things, testimony, transcripts, and tangible things), that are produced

15 or generated in disclosures or responses to discovery.

16 4.8 Expert: a person with specialized knowledge or experience in a matter

17 pertinent to the litigation who has been retained by a Party or its counsel to serve

18 as an expert witness or as a consultant in this Action.

19 4.9 House Counsel: attorneys who are employees of a party to this Action.

20 House Counsel does not include Outside Counsel of Record or any other outside

21 counsel.

22 4.10 Non-Party: any natural person, partnership, corporation, association or

23 other legal entity not named as a Party to this action.

24 4.11 Outside Counsel of Record: attorneys who are not employees of a

25 party to this Action but are retained to represent a party to this Action and have

26 appeared in this Action on behalf of that party or are affiliated with a law firm that

27 has appeared on behalf of that party, and includes support staff.

1 4.12 Party: any party to this Action, including all of its officers, directors,

2 employees, consultants, retained experts, and Outside Counsel of Record (and their

3 support staffs).

4 4.13 Producing Party: a Party or Non-Party that produces Disclosure or

5 Discovery Material in this Action.

6 4.14 Professional Vendors: persons or entities that provide litigation

7 support services (e.g., photocopying, videotaping, translating, preparing exhibits or

8 demonstrations, and organizing, storing, or retrieving data in any form or medium)

9 and their employees and subcontractors.

10 4.15 Protected Material: any Disclosure or Discovery Material that is

11 designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES

12 ONLY (TRADE SECRET/COMMERCIALLY SENSITIVE).”

13 4.16 Receiving Party: a Party that receives Disclosure or Discovery

14 Material from a Producing Party.

15 5. SCOPE

16 The protections conferred by this Stipulation and Order cover not only

17 Protected Material (as defined above), but also (1) any information copied or

18 extracted from Protected Material; (2) all copies, excerpts, summaries, or

19 compilations of Protected Material; and (3) any testimony, conversations, or

20 presentations by Parties or their Counsel that might reveal Protected Material.

21 Any use of Protected Material at trial shall be governed by the orders of the

22 trial judge and other applicable authorities. This Order does not govern the use of

23 Protected Material at trial.

24 6. DURATION

25 Once a case proceeds to trial, information that was designated as

26 CONFIDENTIAL or CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE

27 SECRET/COMMERCIALLY SENSITIVE) or maintained pursuant to this

1 protective order used or introduced as an exhibit at trial becomes public and will be

2 presumptively available to all members of the public, including the press, unless

3 compelling reasons supported by specific factual findings to proceed otherwise are

4 made to the trial judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81

5 (distinguishing “good cause” showing for sealing documents produced in

6 discovery from “compelling reasons” standard when merits-related documents are

7 part of court record). Accordingly, the terms of this protective order do not extend

8 beyond the commencement of the trial.

9 7. DESIGNATING PROTECTED MATERIAL

10 7.1 Exercise of Restraint and Care in Designating Material for Protection.

11 Each Party or Non-Party that designates information or items for protection under

12 this Order must take care to limit any such designation to specific material that

13 qualifies under the appropriate standards. The Designating Party must designate for

14 protection only those parts of material, documents, items or oral or written

15 communications that qualify so that other portions of the material, documents,

16 items or communications for which protection is not warranted are not swept

17 unjustifiably within the ambit of this Order.

18 Mass, indiscriminate or routinized designations are prohibited. Designations

19 that are shown to be clearly unjustified or that have been made for an improper

20 purpose (e.g., to unnecessarily encumber the case development process or to

21 impose unnecessary expenses and burdens on other parties) may expose the

22 Designating Party to sanctions.

23 If it comes to a Designating Party’s attention that information or items that it

24 designated for protection do not qualify for protection, that Designating Party must

25 promptly notify all other Parties that it is withdrawing the inapplicable designation.

26 7.2 Manner and Timing of Designations. Except as otherwise provided in

27 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material

1 that qualifies for protection under this Order must be clearly so designated before

2 the material is disclosed or produced.

3 Designation in conformity with this Order requires:

4 (a) for information in documentary form (e.g., paper or electronic

5 documents, but excluding transcripts of depositions or other pretrial or trial

6 proceedings), that the Producing Party affix at a minimum, the legend

7 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY

8 (TRADE SECRET/COMMERCIALLY SENSITIVE)” (hereinafter

9 “CONFIDENTIAL legend”), to each page that contains protected material. If only

10 a portion of the material on a page qualifies for protection, the Producing Party

11 also must clearly identify the protected portion(s) (e.g., by making appropriate

12 markings in the margins).

13 A Party or Non-Party that makes original documents available for inspection

14 need not designate them for protection until after the inspecting Party has indicated

15 which documents it would like copied and produced. During the inspection and

16 before the designation, all of the material made available for inspection shall be

17 deemed “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES

18 ONLY (TRADE SECRET/COMMERCIALLY SENSITIVE).” After the

19 inspecting Party has identified the documents it wants copied and produced, the

20 Producing Party must determine which documents, or portions thereof, qualify for

21 protection under this Order. Then, before producing the specified documents, the

22 Producing Party must affix the “CONFIDENTIAL legend” to each page that

23 contains Protected Material. If only a portion of the material on a page qualifies for

24 protection, the Producing Party also must clearly identify the protected portion(s)

25 (e.g., by making appropriate markings in the margins).

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1 (b) for testimony given in depositions that the Designating Party

2 identifies the Disclosure or Discovery Material on the record, before the close of

3 the deposition all protected testimony.

4 (c) for information produced in some form other than documentary

5 and for any other tangible items, that the Producing Party affix in a prominent

6 place on the exterior of the container or containers in which the information is

7 stored the legend “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’

8 EYES ONLY (TRADE SECRET/COMMERCIALLY SENSITIVE).” If only a

9 portion or portions of the information warrants protection, the Producing Party, to

10 the extent practicable, shall identify the protected portion(s).

11 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

12 failure to designate qualified information or items does not, standing alone, waive

13 the Designating Party’s right to secure protection under this Order for such

14 material. Upon timely correction of a designation, the Receiving Party must make

15 reasonable efforts to assure that the material is treated in accordance with the

16 provisions of this Order.

17 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS

18 8.1 Timing of Challenges. Any Party or Non-Party may challenge a

19 designation of confidentiality at any time that is consistent with the Court’s

20 Scheduling Order.

21 8.2 Meet and Confer. The Challenging Party shall initiate the dispute

22 resolution process under Local Rule 37-1 et seq.

23 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a

24 joint stipulation pursuant to Local Rule 37-2.

25 8.4 The burden of persuasion in any such challenge proceeding shall be

26 on the Designating Party. Frivolous challenges, and those made for an improper

27 purpose (e.g., to harass or impose unnecessary expenses and burdens on other

1 parties) may expose the Challenging Party to sanctions. Unless the Designating

2 Party has waived or withdrawn the confidentiality designation, all parties shall

3 continue to afford the material in question the level of protection to which it is

4 entitled under the Producing Party’s designation until the Court rules on the

5 challenge.

6 9. ACCESS TO AND USE OF PROTECTED MATERIAL

7 9.1 Basic Principles. A Receiving Party may use Protected Material that is

8 disclosed or produced by another Party or by a Non-Party in connection with this

9 Action only for prosecuting, defending or attempting to settle this Action. Such

10 Protected Material may be disclosed only to the categories of persons and under

11 the conditions described in this Order. When the Action has been terminated, a

12 Receiving Party must comply with the provisions of section 15 below (FINAL

13 DISPOSITION).

14 Protected Material must be stored and maintained by a Receiving Party at a

15 location and in a secure manner that ensures that access is limited to the persons

16 authorized under this Order.

17 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

18 otherwise ordered by the court or permitted in writing by the Designating Party, a

19 Receiving Party may disclose any information or item designated

20 “CONFIDENTIAL” only to:

21 (a) the Receiving Party’s Outside Counsel of Record in this Action,

22 as well as employees of said Outside Counsel of Record to whom it is reasonably

23 necessary to disclose the information for this Action;

24 (b) the officers, directors, and employees (including House

25 Counsel) of the Receiving Party to whom disclosure is reasonably necessary for

26 this Action;

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1 (c) Experts (as defined in this Order) of the Receiving Party to

2 whom disclosure is reasonably necessary for this Action and who have signed the

3 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

4 (d) the court and its personnel;

5 (e) court reporters and their staff;

6 (f) professional jury or trial consultants, mock jurors, and

7 Professional Vendors to whom disclosure is reasonably necessary for this Action

8 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

9 A);

10 (g) the author or recipient of a document containing the

11 information or a custodian or other person who otherwise possessed or knew the

12 information;

13 (h) during their depositions, witnesses, and attorneys for witnesses,

14 in the Action to whom disclosure is reasonably necessary provided: (1) the

15 deposing party requests that the witness sign the form attached as Exhibit A hereto;

16 and (2) they will not be permitted to keep any confidential information unless they

17 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless

18 otherwise agreed by the Designating Party or ordered by the court. Pages of

19 transcribed deposition testimony or exhibits to depositions that reveal Protected

20 Material may be separately bound by the court reporter and may not be disclosed

21 to anyone except as permitted under this Stipulated Protective Order; and

22 (i) any mediators or settlement officers and their supporting

23 personnel, mutually agreed upon by any of the parties engaged in settlement

24 discussions.

25 9.3 Disclosure of “CONFIDENTIAL – ATTORNEYS’ EYES ONLY

26 (TRADE SECRET/ COMMERCIALLY SENSITIVE)” Information or Items.

27 Unless otherwise ordered by the court or permitted in writing by the Designating

1 Party, a Receiving Party may disclose any information or item designated

2 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE SECRET/

3 COMMERCIALLY SENSITIVE)” only to:

4 (a) the Receiving Party’s Outside Counsel of Record in this Action,

5 as well as employees of said Outside Counsel of Record to whom it is reasonably

6 necessary to disclose the information for this Action;

7 (b) Experts (as defined in this Order) of the Receiving Party to

8 whom disclosure is reasonably necessary for this Action and who have signed the

9 “Acknowledgment and Agreement to Be Bound” (Exhibit A);

10 (c) the court and its personnel;

11 (d) court reporters and their staff;

12 (e) professional jury or trial consultants, mock jurors, and

13 Professional Vendors to whom disclosure is reasonably necessary for this Action

14 and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit

15 A);

16 (f) the author or recipient of a document containing the

17 information or a custodian or other person who otherwise possessed or knew the

18 information;

19 (g) any mediator or settlement officer, and their supporting

20 personnel, mutually agreed upon by any of the parties engaged in settlement

21 discussions.

22 10. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

23 PRODUCED IN THIS LITIGATION

24 (a) The terms of this Order are applicable to information produced

25 by a Non-Party in this Action and designated as “CONFIDENTIAL” or

26 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE SECRET/

27 COMMERCIALLY SENSITIVE).” Such information produced by Non-Parties in

1 connection with this litigation is protected by the remedies and relief provided by

2 this Order. Nothing in these provisions should be construed as prohibiting a Non-

3 Party from seeking additional protections.

4 (b) In the event that a Party is required, by a valid discovery

5 request, to produce a Non-Party’s confidential information in its possession, and

6 the Party is subject to an agreement with the Non-Party not to produce the Non-

7 Party’s confidential information, then the Party shall:

8 (1) promptly notify in writing the Requesting Party

9 and the Non-Party that some or all of the information requested is subject to a

10 confidentiality agreement with a Non-Party;

11 (2) promptly provide the Non-Party with a copy of the

12 Stipulated Protective Order in this Action, the relevant discovery request(s), and a

13 reasonably specific description of the information requested; and

14 (3) make the information requested available for

15 inspection by the Non-Party, if requested.

16 (c) If the Non-Party fails to seek a protective order from this court

17 within 14 days of receiving the notice and accompanying information, the

18 Receiving Party may produce the Non-Party’s confidential information responsive

19 to the discovery request. If the Non-Party timely seeks a protective order, the

20 Receiving Party shall not produce any information in its possession or control that

21 is subject to the confidentiality agreement with the Non-Party before a

22 determination by the court. Absent a court order to the contrary, the Non-Party

23 shall bear the burden and expense of seeking protection in this court of its

24 Protected Material.

25 11. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

26 If a Receiving Party learns that, by inadvertence or otherwise, it has

27 disclosed Protected Material to any person or in any circumstance not authorized

1 under this Stipulated Protective Order, the Receiving Party must immediately (a)

2 notify in writing the Designating Party of the unauthorized disclosures, (b) use its

3 best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform

4 the person or persons to whom unauthorized disclosures were made of all the terms

5 of this Order, and (d) request such person or persons to execute the

6 “Acknowledgment an Agreement to Be Bound” attached hereto as Exhibit A.

7 12. INADVERTENT PRODUCTION OF PRIVILEGED OR

8 OTHERWISE PROTECTED MATERIAL

9 When a Producing Party gives notice to Receiving Parties that certain

10 inadvertently produced material is subject to a claim of privilege or other

11 protection, the obligations of the Receiving Parties are those set forth in Federal

12 Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify

13 whatever procedure may be established in an e-discovery order that provides for

14 production without prior privilege review. Pursuant to Federal Rule of Evidence

15 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure

16 of a communication or information covered by the attorney-client privilege or

17 work product protection, the parties may incorporate their agreement in the

18 stipulated protective order submitted to the court.

19 13. MISCELLANEOUS

20 13.1 Right to Further Relief. Nothing in this Order abridges the right of any

21 person to seek its modification by the Court in the future.

22 13.2 Right to Assert Other Objections. By stipulating to the entry of this

23 Protective Order, no Party waives any right it otherwise would have to object to

24 disclosing or producing any information or item on any ground not addressed in

25 this Stipulated Protective Order. Similarly, no Party waives any right to object on

26 any ground to use in evidence of any of the material covered by this Protective

27 Order.

1 13.3 Filing Protected Material. A Party that seeks to file under seal any

2 Protected Material must comply with Local Civil Rule 79-5. Protected Material

3 may only be filed under seal pursuant to a court order authorizing the sealing of the

4 specific Protected Material. If a Party’s request to file Protected Material under

5 seal is denied by the court, then the Receiving Party may file the information in the

6 public record unless otherwise instructed by the court.

7 14. FINAL DISPOSITION

8 After the final disposition of this Action, as defined in paragraph 6, within

9 60 days of a written request by the Designating Party, each Receiving Party must

10 return all Protected Material to the Producing Party or destroy such material. As

11 used in this subdivision, “all Protected Material” includes all copies, abstracts,

12 compilations, summaries, and any other format reproducing or capturing any of the

13 Protected Material. Whether the Protected Material is returned or destroyed, the

14 Receiving Party must submit a written certification to the Producing Party (and, if

15 not the same person or entity, to the Designating Party) by the 60-day deadline that

16 (1) identifies (by category, where appropriate) all the Protected Material that was

17 returned or destroyed and (2) affirms that the Receiving Party has not retained any

18 copies, abstracts, compilations, summaries or any other format reproducing or

19 capturing any of the Protected Material. Notwithstanding this provision, Counsel

20 are entitled to retain an archival copy of all pleadings, motion papers, trial,

21 deposition, and hearing transcripts, legal memoranda, correspondence, deposition

22 and trial exhibits, expert reports, attorney work product, and consultant and expert

23 work product, even if such materials contain Protected Material. Any such archival

24 copies that contain or constitute Protected Material remain subject to this

25 Protective Order as set forth in Section 6 (DURATION).

26 / / /

27 / / /

1 15. VIOLATION

2 Any violation of this Order may be punished by appropriate measures

3 including, without limitation, contempt proceedings and/or monetary sanctions.

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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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Dated: December 12, 2025

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JOHN D. EARLY

United States Magistrate Judge

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1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

3 I, _____________________________ [full name], of _________________

4 [full address], declare under penalty of perjury that I have read in its entirety and

5 understand the Stipulated Protective Order that was issued by the U.S. District

6 Court for the Central District of California in the case of Take-Two Interactive

7 Software, Inc. vs. PlayerAuctions, Inc., et al. – Case No. 2:25-cv-01880-ODW

8 (JDEx). I agree to comply with and to be bound by all the terms of this Stipulated

9 Protective Order, and I understand and acknowledge that failure to so comply

10 could expose me to sanctions and punishment, including contempt. I solemnly

11 promise that I will not disclose in any manner any information or item that is

12 subject to this Stipulated Protective Order to any person or entity except in strict

13 compliance with the provisions of this Order.

14 I further agree to submit to the jurisdiction of the U.S. District Court for the

15 Central District of California for the purpose of enforcing the terms of this

16 Stipulated Protective Order, even if such enforcement proceedings occur after

17 termination of this action. I hereby appoint ____________________________

18 [full name] of _______________________________________ [full address and

19 telephone number] as my California agent for service of process in connection

20 with this action or any proceedings related to enforcement of this Stipulated

21 Protective Order.

22 Date: ______________________________________

23 City and State where signed: _________________________________

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25 Printed name: _______________________________

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27 Signature: __________________________________