# Opinion

> District Court, C.D. California · December 17, 2025

URL: https://www.frixlaw.com/law-library/cases/11229387

## Case

- **Full name:** Pop Mart Americas Inc., Pop Mart (Singapore) Holding Pte. Ltd., and Beijing Pop Mart Cultural & Creative Co. Ltd v. 7-Eleven, Inc., Mayer Brothers Group, Inc. (d/b/a 7-Eleven Store No. 37950), Hrbs Enterprises, Inc. (d/b/a
- **Court:** District Court, C.D. California
- **Decided:** December 17, 2025
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12
Case No. 2:25-cv-6555-MEMF (MBKx)
POP MART AMERICAS INC., POP
13
MART (SINGAPORE) HOLDING [PROPOSED] STIPULATED
14 PTE. LTD., AND BEIJING POP PROTECTIVE ORDER
MART CULTURAL & CREATIVE
15 CO. LTD,
16 Plaintiffs,
v.
17
7-ELEVEN, INC., MAYER
18 BROTHERS GROUP, INC. (D/B/A
7-ELEVEN STORE NO. 37950),
19
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
22
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),
26
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.
5
Defendants.
6
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).
28
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.
12
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.
21
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.
5
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.
16
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).
20
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;
28
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.
15
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:
27
28
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.
17
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.
27
28
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.
17
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.
5
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.
24
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.
1
2 DATED : December 16, 2024 By /s/Michael T. Zeller
Michael T. Zeller
3
michaelzeller@quinnemanuel.com
4
QUINN EMANUEL URQUHART &
5
SULLIVAN, LLP
6
7 Attorneys for Plaintiffs

8
9 DATED : December 12, 2024 By /s/Steven E. Lauridsen
David J. Steele
10
Steven E. Lauridsen
11 Dina Roumiantseva
TUCKER ELLIS LLP
12

13 Attorneys For Defendant 7-Eleven, Inc.

14
DATED : December 12, 2024 By /s/Keith G. Adams
15 Keith G. Adams
Nicholas C. Larson
16
Miguel Mendez-Pintado
17 MURPHY, PEARSON, BRADLEY &
FEENEY
18

19 Attorneys for Defendant
WEST ADAMS PETROLEUM, INC.
20
(D/B/A 7-ELEVEN STORE NO. 39807)
21
DATED : December 12, 2024 By /s/Matthew Yarling
22
Will Lemkul
23 Matthew Yarling
24 MORRIS, SULLIVAN, LEMKUL &
TURTZO, LLP
25
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
10
11
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
17
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.
22
/s/Steven E.. Lauridsen
23
24 || ITISSO ORDERED.
25 ;
26 || DATED: December 17, 2025 LA CG
MICHAEL B. KAUFMAN
27 UNITED STATES MAGISTRATE JUDGE
28
18

1 UNITED STATES DISTRICT COURT
2
CENTRAL DISTRICT OF CALIFORNIA
3
4

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,
8
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
14
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
18
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.
21
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,
25
AND DOES 1-10.
26
Defendants.
27

28
1 I , under penalty of perjury, 28 U.S.C. § 1746, that:
2
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
5
the Protective Order.
6
2. I have been given a copy of and have read the Protective Order.
7
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.
9
4. I submit to the jurisdiction of the United States District Court for the
10
Central District of California for enforcement of the Protective Order.
11
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
17
effect on them and me.
18
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.
24
Signed at _______________, _______, this ______, day of , 20__.
25

26
____________________________
27
Signature
28

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11229387. Public record. Not legal advice.