# Opinion

> District Court, C.D. California · March 5, 2026

URL: https://www.frixlaw.com/law-library/cases/11369103

## Case

- **Full name:** Seattle Cell Market, LLC v. M. Segue Corporation
- **Court:** District Court, C.D. California
- **Decided:** March 5, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/11369103

## Opinion text

1 |} UMBERG ZIPSER LLP WOLF, RIFKIN, SHAPIRO, SCHULMAN
> || Mark A. Finkelstein (SBN 173851) & RABKIN, LLP
~ || mfinkelstein@uzllp.com Matthew Oster (SBN 190541)
3 || Ellen S. Kim (SBN 329348) moster@wrslawyers.com
4 ekim@uzllp.com Paulo A. de Almeida (SBN 279168)
1920 Main Street, Suite 750 pdealmeida@wrslawyers.com
5 || Irvine, California 92614 11400 W Olympic Blvd., 9" FI.
6 || Telephone: (949) 679-0052 Los Angeles, CA 90064
Facsimile: (949) 679-0461 Telephone: (310) 478-4100
7
g || Attorneys for Plaintiff Attorneys for Defendant
SEATTLE CELL MARKET, LLC M. SEGUE CORPORATION
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4 UNITED STATES DISTRICT COURT
3 CENTRAL DISTRICT OF CALIFORNIA
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14 || SEATTLE CELL MARKET, LLC, Case No. 2:25-cv-06165-JFW (Ex)
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Plaintiff, Assigned to: Hon. Charles F. Eick
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19 Vs. DISCOVERY MATTER
M. SEGUE CORPORATION, JOINT STIPULATION AND
18 }PROPOSED] PROTECTIVE
19 Defendant. ORDER
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CASE NO. 2:25-CVv-06165-JFW (EX)
JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

1. PURPOSES AND LIMITATIONS
2 Discovery in this action is likely to involve production of confidential,
3 || proprietary or private information for which special protection from public disclosure
4 || and from use for any purpose other than pursuing this litigation may be warranted.
5 || Accordingly, Plaintiff Seattle Cell Market, LLC (“Plaintiff or “SCM”’), on the one
6 |)hand, and Defendant M. Segue Corporation (“Defendant” or “Segue”), on the other
7 ||hand (collectively, the “Parties”), hereby stipulate to and petition the Court to enter
8 || this Stipulated Protective Order (“Protective Order” or the ““Order’”). The Parties
9 || acknowledge that this Order does not confer blanket protections on all disclosures or
10 |/responses to discovery and that the protection it affords from public disclosure and use
11 || extends only to the limited information or items that are entitled to confidential
12 |! treatment under the applicable legal principles.
13 Further, as set forth in Sections 3 and 14.3 below, this Protective Order does not
14 || entitle the Parties to file confidential information under seal. Rather, when the Parties
15 || seek permission from the court to file material under seal, the Parties must comply
16 || with Civil Local Rule 79-5 and with any pertinent orders of the assigned District
17 || Judge and Magistrate Judge.
18 2 GOOD CAUSE STATEMENT
19 This action 1s likely to involve highly sensitive financial information, customer
20 || or supplier identifiers, and pricing lists and other valuable research, development,
21 ||commercial, financial, technical and/or proprietary information for which special
22 || protection from public disclosure and from use for any purpose other than prosecution
23 || of this action is warranted. Such confidential and proprietary materials and
24 || information consist of, among other things, the parties’ respective customer or
25 || supplier identifying information, sales and revenue data, business decisions, internal
26 || company communications, pricing lists, confidential business or financial information,
27 || information regarding confidential business practices, or other confidential research,
28 || development, or commercial information (including information implicating privacy

JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

| rights of third parties), information otherwise generally unavailable to the public, or
2 || which may be privileged or otherwise protected from disclosure under state or federal
3 || statutes, court rules, case decisions, or common law. Accordingly, to expedite the
4 || flow of information, to facilitate the prompt resolution of disputes over confidentiality
5 || of discovery materials, to adequately protect highly sensitive information the parties
6 |/are entitled to keep confidential (public disclosure of which would risk harming their
7 || competitive positions in their industries and could also result in reputational harm), to
8 || ensure that the parties are permitted reasonable necessary uses of such material in
9 || preparation for and in the conduct of trial, to address their handling at the end of the
10 || litigation, and to serve the ends of justice, a protective order for such information is
11 || justified in this matter. It is the intent of the Parties that information will not be
12 || designated as confidential for tactical reasons and that nothing be so designated
13 || without a good faith belief that it has been maintained in a confidential, non-public
14 manner, and there is good cause why it should not be part of the public record of this
15 case.
16 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE
17 The Parties acknowledge, as also set forth Section 14.3 below, that this
18 || Protective Order does not entitle them to file confidential information under seal.
19 || When the Parties seek permission from the court to file material under seal, the Parties
20 |)must comply with Civil Local Rule 79-5 and with any pertinent orders of the assigned
21 || District Judge and Magistrate Judge.
22 There is a strong presumption that the public has a right of access to judicial
23 || proceedings and records in civil cases. See Kamakana v. City and County of
24 || Honolulu, 447 F.3d 1172, 1178-79 (9th Cir. 2006). To overcome this presumption, a
25 || specific showing of good cause or compelling reasons with proper evidentiary support
26 || and legal justification must be made with respect to Protected Material that a party
27 || seeks to file under seal. See Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d
28 || 1092, 1097 (9th Cir. 2016). The Parties’ mere designation of Disclosure or Discovery

JOINT STIPULATION AND fPPROPROSED] PROTECTIVE ORDER

| || Material as CONFIDENTIAL does not—without the submission of competent
2 || evidence by declaration, establishing that the material sought to be filed under seal
3 || qualifies as confidential, privileged, or otherwise protectable—constitute good cause.
4 Further, if a party requests sealing, the relief sought shall be narrowly tailored to serve
5 || the specific interest to be protected.
6 Any document that is not confidential, privileged, or otherwise protectable in its
7 || entirety will not be filed under seal if the confidential portions can be redacted. If
8 || documents can be redacted, then a redacted version for public viewing, omitting only
9 || the confidential, privileged, or otherwise protectable portions of the document, shall
10 |/ be filed. Any application that seeks to file documents under seal in their entirety
11 || should include an explanation of why redaction is not feasible.
12 4. DEFINITIONS
13 4.1 Action: The instant federal lawsuit, styled as Seattle Cell Market, LLC v.
14 || M. Segue Corporation, Case No. 2:25-cv-06165-JFW (Ex).
15 4.2 Challenging Party: a Party or Non-Party that challenges the
16 || designation of information or items under this Order.
17 4.3. “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” Information or
18 || Items: information (regardless of how it is generated, stored or maintained) or tangible
19 |! things that qualify for protection under Federal Rule of Civil Procedure 26(c), and as
20 || specified above in the Good Cause Statement.
21 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their
22 || support staff).
23 4.5 Designating Party: a Party or Non-Party that designates information or
24 items that it produces in disclosures or in responses to discovery as
25 ||“CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.”
26 4.6 Disclosure or Discovery Material: all items or information, regardless of
27 |!the medium or manner in which it is generated, stored, or maintained (including,
28 || among other things, testimony, transcripts, and tangible things), that are produced or

JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

! || generated in disclosures or responses to discovery.
2 4.7 Expert: a person with specialized knowledge or experience in a matter
3 || pertinent to the litigation who has been retained by a Party or its counsel to serve as an
4 || expert witness or as a consultant in this Action.
5 4.8 House Counsel: attorneys who are employees of a party to this Action.
6 || House Counsel does not include Outside Counsel of Record or any other outside
7 |) counsel.
8 4.9 Non-Party: any natural person, partnership, corporation, association or
9 || other legal entity not named as a Party to this action.
10 4.10 Qutside Counsel of Record: attorneys who are not employees of a party
11 || to this Action but are retained to represent a party to this Action and have appeared in
12 this Action on behalf of that party or are affiliated with a law firm that has appeared
13 || on behalf of that party, and includes support staff.
14 4.11 Producing Party: a Party or Non-Party that produces Disclosure or
15 |} Discovery Material in this Action.
16 4.12 Professional Vendors: persons or entities that provide litigation support
17 || services (e.g., photocopying, videotaping, translating, preparing exhibits or
18 || demonstrations, and organizing, storing, or retrieving data in any form or medium)
19 || and their employees and subcontractors.
20 4.13 Protected Material: any Disclosure or Discovery Material that is
21 || designated as “CONFIDENTIAL” or ‘ATTORNEYS’ EYES ONLY.””
22 4.14 Receiving Party: a Party that receives Disclosure or Discovery
23 || Material from a Producing Party.
24 5. SCOPE
25 The protections conferred by this Stipulation and Order cover not only
26 || Protected Material (as defined above), but also (1) any information copied or extracted
27 || from Protected Material; (2) all copies, excerpts, summaries, or compilations of
28 || Protected Material; and (3) any testimony, conversations, or presentations by Parties
—_.JTWT———————* "Sissons oy ne WD
JOINT STIPULATION AND PROPOSED] PROTECTIVE ORDER

1 || or their Counsel that might reveal Protected Material.
2 Any use of Protected Material during a court hearing or at trial shall be
3 || governed by the orders of the presiding judge and other applicable authorities. This
4 || Order does not govern the use of Protected Material during a court hearing or at trial.
5 6. DURATION
6 Even after final disposition of this litigation, the confidentiality obligations
7 |/imposed by this Order shall remain in effect until a Designating Party agrees
8 || otherwise in writing or a court order otherwise directs. Final disposition shall be
9 || deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
10 || or without prejudice; or (2) final judgment herein after the completion and exhaustion
11 || of all appeals, rehearings, remands, trials, or reviews of this Action, including the time
12 || limits for filing any motions or applications for extension of time pursuant to
13 || applicable law.
14 Once a case proceeds to trial, information that was designated as
15 |} CONFIDENTIAL or maintained pursuant to this Protective Order used or introduced
16 as an exhibit at trial becomes public and will be presumptively available to all
17 |lmembers of the public, including the press, unless compelling reasons supported by
18 || specific factual findings to proceed otherwise are made to the trial judge in advance of
19 || the trial.
20 7. DESIGNATING PROTECTED MATERIAL
21 7.1 Exercise of Restraint and Care in Designating Material for Protection.
22 Each Party or Non-Party that designates information or items for protection
23 under this Order must take care to limit any such designation to specific material that
24 || qualifies under the appropriate standards.
25 A document should be designated “CONFIDENTIAL.” when it contains
26 || confidential information that may be reviewed by a designated manager of the
27 receiving party but must be protected against disclosure to unauthorized third parties.
28 || A document may be designated ‘ATTORNEYS’ EYES ONLY” only when it contains
|| Mark A. Finkelstein (SBN 173851) SCHULMAN & RABKIN, LLP
mfinkelstein@uzllp.com Matthew Oster (SBN 190541)
3 ||Ellen S. Kim (SBN 329348) moster@wrslawyers.com
4 |/ekim@uzllp.com Paulo A. de Almeida (SBN 279168)
1920 Main Street, Suite 750 pdealmeida@wrslawyers.com
5 || Irvine, California 92614 11400 W Olympic Blvd., 9" FI.
6 || Telephone: (949) 679-0052 Los Angeles, CA 90064
Facsimile: (949) 679-0461 Telephone: (310) 478-4100
7
g || Attorneys for Plaintiff Attorneys for Defendant
Seattle Cell Market, LLC M. Segue Corporation
9
10
UNITED STATES DISTRICT COURT
12 CENTRAL DISTRICT OF CALIFORNIA
13
'4 | SEATTLE CELL MARKET, LLC, Case No. 2:25-cv-06165-JFW (Ex)
15
ig Plaintiff, Assigned to: Hon. Charles F. Eick
17 = {PROPOSED} ORDER
1g ||M. SEGUE CORPORATION, REGARDING JOINT
STIPULATION
19 Defendant.
20 Complaint Filed: September 10, 2024
21 Trial Date: December 1, 2026
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CASE NO. 2:25-CV-06165-JFW (EX)
{PReEPeSED} ORDER REGARDING JOINT STIPULATION

PROPOSED] ORDER
2 The parties are hereby DIRECTED to file a signed copy of a protective order
3 || within five (5) days of this Order which [includes] an “Attorneys’ Eyes Only” level of
4 || protection.
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6 | IT IS SO ORDERED.
BLL
g Dated: 3/5/2026 By: SS
Hon. Charles F. Eick
9 United States Magistrate Judge
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CASE NO. 2:25-CV-06165-JFW (EX)
[PROPOSED] ORDER REGARDING JOINT STIPULATION

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11369103. Public record. Not legal advice.