Opinion

Court: District Court, C.D. California
Filed: Dec 17, 2025
Cited by: 0 cases

The opinion

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION

Case No. 2:25-cv-6555-MEMF (MBKx)

POP MART AMERICAS INC., POP

MART (SINGAPORE) HOLDING [PROPOSED] STIPULATED

14 PTE. LTD., AND BEIJING POP PROTECTIVE ORDER

MART CULTURAL & CREATIVE

15 CO. LTD,

16 Plaintiffs,

7-ELEVEN, INC., MAYER

18 BROTHERS GROUP, INC. (D/B/A

7-ELEVEN STORE NO. 37950),

HRBS ENTERPRISES, INC. (D/B/A

20 7-ELEVEN STORE NO. 34765),

CHITTA CHANNIN (D/B/A 7-

21 ELEVEN STORE NO. 39569), TERA

TERA, INC. (D/B/A 7-ELEVEN

STORE NO. 32606), B&K SIDHU

23 ENTERPRISES, INC. (D/B/A/

STORE NO. 32606), NEETTRIO

24 INC. (D/B/A 7-ELEVEN STORE

NO. 16027); SANDHU MCHENRY

25 & MORRIS STORE, LLC, (D/B/A

7-ELEVEN STORE NO. 42272),

SANDHU SE STORES INC. (D/B/A

27 7-ELEVEN STORE NO. 42272),

WEST ADAMS PETROLEUM, INC.

28 (D/B/A 7-ELEVEN STORE NO.

1 (D/B/A 7-ELEVEN STORE NOS.

2 25801 AND 16254), KRISH

HARBANS, INC. (D/B/A 7-ELEVEN

3 STORE NO. 33278), HARNEK

SINGH THIARA,

4 SUKHVINDERJEET SANDHU,

AND DOES 1-10.

Defendants.

7 1. GENERAL

8 1.1 Purposes and Limitations. Discovery in this action is likely to involve

9 production of confidential, proprietary, or private information for which special

10 protection from public disclosure and from use for any purpose other than prosecuting

11 this litigation may be warranted. Accordingly, the parties hereby stipulate to and

12 petition the Court to enter the following Stipulated Protective Order. The parties

13 acknowledge that this Order does not confer blanket protections on all disclosures or

14 responses to discovery and that the protection it affords from public disclosure and

15 use extends only to the limited information or items that are entitled to Confidential

16 or Highly Confidential – Attorneys’ Eyes Only treatment under the applicable legal

17 principles. The parties further acknowledge, as set forth in Section 12.3, below, that

18 this Stipulated Protective Order does not entitle them to file confidential information

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

20 the standards that will be applied when a party seeks permission from the court to file

21 material under seal.

22 1.2 Good Cause Statement. This action is likely to involve trade secrets,

23 customer and pricing lists and other highly confidential business, commercial,

24 financial, technical and/or proprietary information for which special protection from

25 public disclosure and from use for any purpose other than prosecution of this action

26 is warranted. Such confidential and proprietary materials and information consist of,

27 among other things, confidential business or financial information, information

28 regarding confidential business practices, or other confidential research,

1 development, or commercial information (including information implicating privacy

2 rights of third parties), information otherwise generally unavailable to the public, or

3 which may be privileged or otherwise protected from disclosure under state or federal

4 statutes, court rules, case decisions, or common law. Accordingly, to expedite the

5 flow of information, to facilitate the prompt resolution of disputes over confidentiality

6 of discovery materials, to adequately protect information the parties are entitled to

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

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

9 at the end of the litigation, and serve the ends of justice, a protective order for such

10 information is justified in this matter. It is the intent of the parties that information

11 will not be designated as confidential for tactical reasons and that nothing be so

12 designated without a good faith belief that it has been maintained in a confidential,

13 non-public manner, and there is good cause why it should not be part of the public

14 record of this case.

15 2. DEFINITIONS

16 2.1 Action: this pending federal lawsuit, Case No. 2:25-cv-6555-MEMF

17 (MBKx).

18 2.2 Challenging Party: a Party or Non-Party that challenges the designation

19 of information or items under this Order.

20 2.3 “CONFIDENTIAL” Information or Items: information (regardless of

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

22 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good

23 Cause Statement.

24 2.4 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”:

25 designation means that the document contains information that the producing party

26 deems especially sensitive, disclosure of which to another Party or Non-Party would

27 create a substantial risk of serious harm that could not be avoided by less restrictive

28 means.

1 2. 5 Counsel: Outside Counsel of Record and House Counsel (as well as their

2 support staff).

3 2.6 Designating Party: a Party or Non-Party that designates information or

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

5 “CONFIDENTIAL.”

6 2.7 Designated House Counsel: House Counsel who seek access to

7 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information in this

8 matter.

9 2.8 Disclosure or Discovery Material: all items or information, regardless

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

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

12 generated in disclosures or responses to discovery in this matter.

13 2.9 Expert: a person with specialized knowledge or experience in a matter

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

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

16 2.10 House Counsel: attorneys who are employees or contract employees of

17 a party to this Action. House Counsel does not include Outside Counsel of Record or

18 any other outside counsel.

19 2.11 Non-Party: any natural person, partnership, corporation, association, or

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

21 2.12 Outside Counsel of Record: attorneys who are not employees of a party

22 to this Action but are retained to represent or advise a party to this Action and have

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

24 has appeared on behalf of that party, including support staff.

25 2.13 Party: any party to this Action, including all of its officers, directors,

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

27 support staffs).

1 2.14 Producing Party: a Party or Non-Party that produces Disclosure or

2 Discovery Material in this Action.

3 2.15 Professional Vendors: persons or entities that provide litigation support

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

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

6 and their employees and subcontractors.

7 2.16 Protected Material: any Disclosure or Discovery Material that is

8 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’

9 EYES ONLY.”

10 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material

11 from a Producing Party.

13 3. SCOPE

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

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

16 from 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 Order does not govern the use of Protected Material at trial.

22 4. DURATION

23 Once a case proceeds to trial, only the court-filed information to be introduced

24 at trial that was previously designated as confidential or maintained pursuant to this

25 protective order becomes public and will be presumptively available to all members

26 of the public, including the press, unless compelling reasons supported by specific

27 factual findings to proceed otherwise are made to the trial judge in advance of the

28 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.

1 2006) (distinguishing “good cause” showing for sealing documents produced in

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

3 part of court record). The terms for disposition of other Protected Material are set

4 forth in Section 13 below.

6 5. DESIGNATING PROTECTED MATERIAL

7 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

9 Order must take care to limit any such designation to specific material that qualifies

10 under the appropriate standards. The Designating Party must designate for protection

11 only those parts of material, documents, items, or oral or written communications that

12 qualify so that other portions of the material, documents, items, or communications

13 for which protection is not warranted are not swept unjustifiably within the ambit of

14 this Order.

15 Mass, indiscriminate, or routinized designations are prohibited. Designations

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

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

18 unnecessary expenses and burdens on other parties) may expose the Designating Party

19 to sanctions.

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

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

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

23 5.2 Manner and Timing of Designations. Except as otherwise provided in

24 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise

25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection

26 under this Order must be clearly so designated before the material is disclosed or

27 produced.

28 Designation in conformity with this Order requires:

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

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

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

4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY

5 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” (hereinafter “AEO legend”) to

6 each page that contains Protected Material. If only a portion or portions of the

7 material on a page qualifies for protection, the Producing Party also must clearly

8 identify the protected portion(s) (e.g., by making appropriate markings in the

9 margins).

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

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

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

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

14 deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After the

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

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

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

18 Producing Party must affix the CONFIDENTIAL legend or AEO legend to each page

19 that contains Protected Material. If only a portion or portions of the material on a

20 page qualifies for protection, the Producing Party also must clearly identify the

21 protected portion(s) (e.g., by making appropriate markings in the margins).

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

23 the Disclosure or Discovery Material on the record, before the close of the deposition.

24 Whether or not such designation is made at the time of the deposition, however, any

25 party has fourteen (14) days after that party’s receipt of the final transcript of the

26 deposition session to designate, in writing to the other parties and to the court reporter,

27 what portions of the transcript and which exhibits the party designates as Protected

28 Material. During the transcription and following fourteen (14) day period after a

1 deposition session, the transcript and exhibits must be treated as HIGHLY

2 CONFIDENTIAL – ATTORNEYS’ EYES ONLY, unless the disclosing party

3 consents to less confidential treatment of the information. Each party and the court

4 reporter must attach a copy of any final and timely written designation notice to the

5 transcript and each copy of the transcript in its possession, custody or control, and the

6 portions designated in such notice must thereafter be treated in accordance with this

7 Protective Order. It is the responsibility of counsel for each party to maintain materials

8 containing Confidential information or Highly Confidential – Attorneys’ Eyes Only

9 information in a secure manner and appropriately identified so as to allow access to

10 such information only to such persons and under such terms as is permitted under this

11 Protective Order. If no such designation is made at the deposition or within the

12 fourteen (14) day period following delivery of the transcript, then the entire deposition

13 will be considered devoid of CONFIDENTIAL INFORMATION or HIGHLY

14 CONFIDENTIAL – ATTORNEYS’ EYES ONLY INFORMATION.

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

16 for any other tangible items, that the Producing Party affix in a prominent place on

17 the exterior of the container or containers in which the information is stored the

18 CONFIDENTIAL legend or AEO legend. If only a portion or portions of the

19 information warrants protection, the Producing Party, to the extent practicable, shall

20 identify the protected portion(s).

21 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

23 Designating Party’s right to secure protection under this Order for such material.

24 Upon timely correction of a designation, the Receiving Party must make reasonable

25 efforts to assure that the material is treated in accordance with the provisions of this

26 Order.

27 ///

28 ///

1 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

2 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

4 Scheduling Order.

5 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

6 resolution process under Local Rule 37-1, et seq, as modified by Judge Kaufman’s

7 Procedures. See https://www.cacd.uscourts.gov/honorable-michael-b-kaufman. Any

8 discovery motion must strictly comply with these procedures.

9 6.3 Burden. The burden of persuasion in any such challenge proceeding

10 shall be on the Designating Party. Frivolous challenges, and those made for an

11 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on

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

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

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

15 under the Producing Party’s designation until the Court rules on the challenge.

17 7. ACCESS TO AND USE OF PROTECTED MATERIAL

18 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

23 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).

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

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

26 authorized under this Order.

27 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

28 otherwise ordered by the Court or permitted in writing by the Designating Party, a

1 Receiving Party may disclose any information or item designated

2 “CONFIDENTIAL” only to:

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

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

5 necessary to disclose the information for this Action;

6 (b) the officers, directors, and employees (including House Counsel) of

7 the Receiving Party to whom disclosure is reasonably necessary for this Action;

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

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

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

11 (d) the Court and its personnel;

12 (e) court reporters and their staff;

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

14 Vendors to whom disclosure is reasonably necessary for this Action and who have

15 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

16 (g) the author or recipient of a document containing the information or

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

18 (h) during their depositions, witnesses, and attorneys for witnesses, in

19 the Action to whom disclosure is reasonably necessary provided: (1) the deposing

20 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

21 will not be permitted to keep any confidential information unless they sign the

22 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

23 agreed by the Designating Party or ordered by the Court. Pages of transcribed

24 deposition testimony or exhibits to depositions that reveal Protected Material may be

25 separately bound by the court reporter and may not be disclosed to anyone except as

26 permitted under this Stipulated Protective Order;

27 (i) any mediator or settlement officer, and their supporting personnel,

28 mutually agreed upon by any of the parties engaged in settlement discussions; and

1 (j) a single appropriate legal counsel or representative of the Receiving

2 Party’s insurance carrier who has signed the ‘Acknowledgment and Agreement to Be

3 Bound’ (Exhibit A).

4 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

5 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in

6 writing by the Designating Party, a Receiving Party may disclose any information or

7 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only

8 to:

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

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

11 necessary to disclose the information for this Action;

12 (b) Designated House Counsel of the Receiving Party (1) who has no

13 involvement in competitive decision-making, (2) to whom disclosure is reasonably

14 necessary for this litigation, (3) who has signed the “Acknowledgment and Agreement

15 to Be Bound” (Exhibit A), and (4) unless otherwise ordered by the Court or agreed to

16 in writing by the Designating Party, a Party that seeks to disclose to Designated House

17 Counsel any information or item that has been designated “HIGHLY

18 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” first must make a written

19 disclosure to the Designating Party that (1) sets forth the full name of the Designated

20 House Counsel and the city and state of his or her residence, and (2) describes the

21 Designated House Counsel’s current and reasonably foreseeable future primary job

22 duties and responsibilities in sufficient detail to determine if House Counsel is

23 involved, or may become involved, in any competitive decision-making;

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

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

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

27 (d) the Court and its personnel;

28 (e) court reporters and their staff;

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

2 Vendors to whom disclosure is reasonably necessary for this Action and who have

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

4 (g) the author or recipient of a document containing the information or

5 a custodian or other person who otherwise possessed or knew the information;

6 (h) during their depositions, witnesses, and attorneys for witnesses, in

7 the Action to whom disclosure is reasonably necessary provided: (1) the deposing

8 party requests that the witness sign the form attached as Exhibit A hereto; and (2) they

9 will not be permitted to keep any confidential information unless they sign the

10 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise

11 agreed by the Designating Party or ordered by the Court. Pages of transcribed

12 deposition testimony or exhibits to depositions that reveal Protected Material may be

13 separately bound by the court reporter and may not be disclosed to anyone except as

14 permitted under this Stipulated Protective Order;

15 (i) any mediator or settlement officer, and their supporting personnel,

16 mutually agreed upon by any of the parties engaged in settlement discussions; and

17 (j) a single appropriate legal counsel or representative of the Receiving

18 Party’s insurance carrier who has signed the ‘Acknowledgment and Agreement to Be

19 Bound’ (Exhibit A).

21 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

22 PRODUCED IN OTHER LITIGATION

23 If a Party is served with a subpoena or a court order issued in other litigation

24 that compels disclosure of any information or items designated in this Action as

25 Protected Material, that Party must:

26 (a) promptly notify in writing the Designating Party. Such notification shall

27 include a copy of the subpoena or court order;

1 (b) promptly notify in writing the party who caused the subpoena or order to

2 issue in the other litigation that some or all of the material covered by the subpoena

3 or order is subject to this Protective Order. Such notification shall include a copy of

4 this Stipulated Protective Order; and

5 (c) cooperate with respect to all reasonable procedures sought to be pursued

6 by the Designating Party whose Protected Material may be affected.

7 If the Designating Party timely seeks a protective order, the Party served with

8 the subpoena or court order shall not produce any information designated in this action

9 as Protected Material before a determination by the court from which the subpoena or

10 order issued, unless the Party has obtained the Designating Party’s permission. The

11 Designating Party shall bear the burden and expense of seeking protection in that court

12 of its confidential material and nothing in these provisions should be construed as

13 authorizing or encouraging a Receiving Party in this Action to disobey a lawful

14 directive from another court.

16 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

17 PRODUCED IN THIS LITIGATION

18 (a) The terms of this Order are applicable to information produced by a Non-

19 Party in this Action and designated as Protected Material. Such information produced

20 by Non-Parties in connection with this litigation is protected by the remedies and

21 relief provided by this Order. Nothing in these provisions should be construed as

22 prohibiting a Non-Party from seeking additional protections.

23 (b) In the event that a Party is required, by a valid discovery request, to produce

24 a Non-Party’s confidential information in its possession, and the Party is subject to an

25 agreement with the Non-Party not to produce the Non-Party’s confidential

26 information, then the Party shall:

1 (1) promptly notify in writing the Requesting Party and the Non-Party

2 that some or all of the information requested is subject to a confidentiality agreement

3 with a Non-Party;

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

5 Protective Order in this Action, the relevant discovery request(s), and a reasonably

6 specific description of the information requested; and

7 (3) make the information requested available for inspection by the Non-

8 Party, if requested.

9 (c) If the Non-Party fails to seek a protective order from this Court within 14

10 days of receiving the notice and accompanying information, the Receiving Party may

11 produce the Non-Party’s confidential information responsive to the discovery request.

12 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce

13 any information in its possession or control that is subject to the confidentiality

14 agreement with the Non-Party before a determination by the Court. Absent a court

15 order to the contrary, the Non-Party shall bear the burden and expense of seeking

16 protection in this Court of its Protected Material.

18 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

20 Protected Material to any person or in any circumstance not authorized under this

21 Stipulated Protective Order, the Receiving Party must immediately (a) notify in

22 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts

23 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or

24 persons to whom unauthorized disclosures were made of all the terms of this Order,

25 and (d) request such person or persons to execute the “Acknowledgment and

26 Agreement to Be Bound” that is attached hereto as Exhibit A.

1 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

2 PROTECTED MATERIAL

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

4 inadvertently produced material is subject to a claim of privilege or other protection,

5 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil

6 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure

7 may be established in an e-discovery order that provides for production without prior

8 privilege review. Consistent with Federal Rule of Evidence 502(d), the production of

9 privileged or work product protected documents, electronically stored information

10 (“ESI”), or information, whether inadvertent or otherwise, is not a waiver of the

11 privilege or protection from discovery in this case or in any other federal or state

12 proceeding. This Paragraph shall be interpreted to provide the maximum protection

13 allowed by the Federal Rule of Evidence 502(d). Nothing contained herein is

14 intended to or shall serve to limit a party’s right to conduct a review of documents,

15 ESI, or information (including metadata) for relevance, responsiveness, and/or

16 segregation of privileged and/or protected information before production.

18 12. MISCELLANEOUS

19 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

21 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

23 disclosing or producing any information or item on any ground not addressed in this

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

25 ground to use in evidence of any of the material covered by this Protective Order.

26 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

28 only be filed under seal pursuant to a court order authorizing the sealing of the specific

1 Protected Material at issue; good cause must be shown in the request to file under

2 seal. If a Party’s request to file Protected Material under seal is denied by the Court,

3 then the Receiving Party may file the information in the public record unless

4 otherwise instructed by the Court.

6 13. FINAL DISPOSITION

7 After the final disposition of this Action, within 60 days of a written request by

8 the Designating Party, each Receiving Party must return all Protected Material to the

9 Producing Party or destroy such material. As used in this subdivision, “all Protected

10 Material” includes all copies, abstracts, compilations, summaries, and any other

11 format reproducing or capturing any of the Protected Material. Whether the Protected

12 Material is returned or destroyed, the Receiving Party must submit a written

13 certification to the Producing Party (and, if not the same person or entity, to the

14 Designating Party) by the 60 day deadline that (1) identifies (by category, where

15 appropriate) all the Protected Material that was returned or destroyed, and (2) affirms

16 that the Receiving Party has not retained any copies, abstracts, compilations,

17 summaries or any other format reproducing or capturing any of the Protected Material.

18 Notwithstanding this provision, counsel are entitled to retain an archival copy of all

19 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,

20 correspondence, deposition and trial exhibits, expert reports, attorney work product,

21 and consultant and expert work product, even if such materials contain Protected

22 Material. Any such archival copies that contain or constitute Protected Material

23 remain subject to this Protective Order.

25 14. VIOLATION OF ORDER

26 Any violation of this Order may be punished by any and all appropriate

27 measures including, without limitation, contempt proceedings and/or monetary

28 sanctions.

2 DATED : December 16, 2024 By /s/Michael T. Zeller

Michael T. Zeller

michaelzeller@quinnemanuel.com

QUINN EMANUEL URQUHART &

SULLIVAN, LLP

7 Attorneys for Plaintiffs

9 DATED : December 12, 2024 By /s/Steven E. Lauridsen

David J. Steele

Steven E. Lauridsen

11 Dina Roumiantseva

TUCKER ELLIS LLP

13 Attorneys For Defendant 7-Eleven, Inc.

DATED : December 12, 2024 By /s/Keith G. Adams

15 Keith G. Adams

Nicholas C. Larson

Miguel Mendez-Pintado

17 MURPHY, PEARSON, BRADLEY &

FEENEY

19 Attorneys for Defendant

WEST ADAMS PETROLEUM, INC.

(D/B/A 7-ELEVEN STORE NO. 39807)

DATED : December 12, 2024 By /s/Matthew Yarling

Will Lemkul

23 Matthew Yarling

24 MORRIS, SULLIVAN, LEMKUL &

TURTZO, LLP

26 Attorneys for Defendants,

MAYER BROTHERS GROUP, INC.

27 (D/B/A 7-ELEVEN STORE NO. 37950),

28 HRBS ENTERPRISES, INC. (D/B/A 7-

1 ELEVEN STORE NO. 34765), B&K

SIDHU ENTERPRISES, INC.

2 (D/B/A/ STORE NO. 32606),

3 NEETTRIO INC. (D/B/A 7-ELEVEN

STORE NO. 16027); SANDHU

4 MCHENRY & MORRIS STORE, LLC,

5 (D/B/A 7-ELEVEN STORE NO. 42272),

SANDHU SE STORES INC. (D/B/A

6 7-ELEVEN STORE NO. 42272),

7 DHALIWAL BROS, INC. (D/B/A 7-

ELEVEN STORE NOS. 25801 AND

8 16254), KRISH HARBANS, INC. (D/B/A

9 7-ELEVEN STORE NO. 33278), and

SUKHVINDERJEET SANDHU

DATED : December 12, 2024 By /s/Ramshin Daneshi

12 Ramshin Daneshi

13 MFox Law Group, Inc.

14 Attorneys for Defendants

15 CHITTA CHANNIN (D/B/A 7-ELEVEN

STORE NO. 39569) and HARNEK SINGH

16 THIARA

18 ATTESTATION

19 Pursuant to Local Rule 5-4.3.4(a)(2), the filing party attests that all other

20 || signatories listed, and on whose behalf the filing is submitted, concur in the filing’s

21 || content and have authorized the filing.

/s/Steven E.. Lauridsen

24 || ITISSO ORDERED.

25 ;

26 || DATED: December 17, 2025 LA CG

MICHAEL B. KAUFMAN

27 UNITED STATES MAGISTRATE JUDGE

1 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

5 Case No. 2:25-cv-6555-MEMF (MBKx)

POP MART AMERICAS INC., POP

6 MART (SINGAPORE) HOLDING

PTE. LTD., AND BEIJING POP

7 MART CULTURAL & CREATIVE

CO. LTD,

Plaintiffs,

9 v.

10 7-ELEV EN, INC., MAYER CONFIDENTIALITY

ACKNOWLEDGMENT AND

BROTHERS GROUP, INC. (D/B/A

11 7-ELEVEN STORE NO. 37950), AGREEMENT TO BE BOUND FOR

12 HRBS ENTERPRISES, INC. (D/B/A EXPERT,

7-ELEVEN STORE NO. 34765), CONSULTANT OR EMPLOYEES

13 CHITTA CHANNIN (D/B/A 7- OF ANY PARTY

ELEVEN STORE NO. 39569), TERA

TERA, INC. (D/B/A 7-ELEVEN

15 STORE NO. 32606), B&K SIDHU

ENTERPRISES, INC. (D/B/A/

16 STORE NO. 32606), NEETTRIO

INC. (D/B/A 7-ELEVEN STORE

17 NO. 16027); SANDHU MCHENRY

& MORRIS STORE, LLC, (D/B/A

7-ELEVEN STORE NO. 42272),

19 SANDHU SE STORES INC. (D/B/A

7-ELEVEN STORE NO. 42272),

20 WEST ADAMS PETROLEUM, INC.

(D/B/A 7-ELEVEN STORE NO.

39807), DHALIWAL BROS, INC.

22 (D/B/A 7-ELEVEN STORE NOS.

25801 AND 16254), KRISH

23 HARBANS, INC. (D/B/A 7-ELEVEN

STORE NO. 33278), HARNEK

24 SINGH THIARA,

SUKHVINDERJEET SANDHU,

AND DOES 1-10.

Defendants.

1 I , under penalty of perjury, 28 U.S.C. § 1746, that:

3 1. Information, including documents and things, designated as

“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

4 ONLY,” as defined in the Protective Order entered in the above-captioned action

(“Protective Order”), is being provided to me pursuant to the terms and restrictions of

the Protective Order.

2. I have been given a copy of and have read the Protective Order.

8 3. I am familiar with the terms of the Protective Order and I agree to comply

with and to be bound by its terms.

4. I submit to the jurisdiction of the United States District Court for the

Central District of California for enforcement of the Protective Order.

5. I agree not to use any “CONFIDENTIAL” or “HIGHLY

12 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information disclosed to me

13 pursuant to the Protective Order except for purposes of the above-captioned litigation

and not to disclose any of this information to persons other than those specifically

14 authorized by the Protective Order, without the express written consent of the party

15 who designated the information as confidential or by order of the presiding judge.

16 6. I also agree to notify any stenographic, clerical or technical personnel

who are required to assist me of the terms of this Protective Order and of its binding

effect on them and me.

7. I understand that I am to retain all documents or materials designated as

19 or containing “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’

20 EYES ONLY” information in a secure manner, and that all such documents and

materials are to remain in my personal custody until the completion of my assigned

21 duties in this matter, whereupon all such documents and materials, including all

22 copies thereof, and any writings prepared by me containing any “CONFIDENTIAL”

or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information are to

23 be returned to counsel who provided me with such documents and materials.

Signed at _______________, _______, this ______, day of , 20__.

____________________________

Signature

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