# Opinion

> District Court, C.D. California · April 16, 2026

URL: https://www.frixlaw.com/law-library/cases/11373848

## Case

- **Full name:** Hot Girl Walk LLC v. Fashion Nova, LLC
- **Court:** District Court, C.D. California
- **Decided:** April 16, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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11 HOT GIRL WALK LLC, a Delaware Case No. 2:25-cv-10800-JFW(DSRx)

12 limited liability company, [PROPOSED] STIPULATED
PROTECTIVE ORDER
13 Plaintiff,
NOTE CHANGES BY COURT SHOWN
14 v. IN RED TYPE (NEW SECTION 4)

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FASHION NOVA, LLC, a California
16 limited liability company,

17 Defendant.
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FASHION NOVA, LLC, a California
19 limited liability company,

20 Counterclaimant,
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v.
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HOT GIRL WALK LLC, a Delaware
23 limited liability company,
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Counterclaim Defendant.
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1 1. INTRODUCTION
2 1.1. PURPOSES AND LIMITATIONS
3 Discovery in this action is likely to involve production of confidential,
4 proprietary, or private information for which special protection from public disclosure
5 and from use for any purpose other than prosecuting this litigation may be warranted.
6 Accordingly, the parties hereby stipulate to and petition the Court to enter the
7 following Stipulated Protective Order. The parties acknowledge that this Order does
8 not confer blanket protections on all disclosures or responses to discovery and that
9 the protection it affords from public disclosure and use extends only to the limited
10 information or items that are entitled to confidential treatment under the applicable
11 legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
12 that this Stipulated Protective Order does not entitle them to file confidential
13 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
14 followed and the standards that will be applied when a party seeks permission from
15 the court to file material under seal.
16 1.2. GOOD CAUSE STATEMENT
17 This action is likely to involve trade secrets, customer and pricing lists and
18 other valuable research, development, commercial, financial, technical and/or
19 proprietary information for which special protection from public disclosure and from
20 use for any purpose other than prosecution of this action is warranted. Such
21 confidential and proprietary materials and information consist of, among other things,
22 confidential business or financial information, information regarding confidential
23 business practices, or other confidential research, development, or commercial
24 information (including information implicating privacy rights of third parties),
25 information otherwise generally unavailable to the public, or which may be privileged
26 or otherwise protected from disclosure under state or federal statutes, court rules, case
27 decisions, or common law. Accordingly, to expedite the flow of information, to
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1 facilitate the prompt resolution of disputes over confidentiality of discovery materials,
2 to adequately protect information the parties are entitled to keep confidential, to
3 ensure that the parties are permitted reasonable necessary uses of such material in
4 preparation for and in the conduct of trial, to address their handling at the end of the
5 litigation, and serve the ends of justice, a protective order for such information is
6 justified in this matter. It is the intent of the parties that information will not be
7 designated as confidential for tactical reasons and that nothing be so designated
8 without a good faith belief that it has been maintained in a confidential, non-public
9 manner, and there is good cause why it should not be part of the public record of this
10 case.
11 2. DEFINITIONS
12 2.1. Action: Hot Girl Walk LLC v. Fashion Nova, LLC; Fashion Nova, LLC
13 v. Hot Girl Walk LLC, Case No. 2:25-cv-10800-JFW(DSRx).
14 2.2. Challenging Party: a Party or Non-Party that challenges the designation
15 of information or items under this Order.
16 2.3. “CONFIDENTIAL” Information or Items: information (regardless of
17 how it is generated, stored or maintained) or tangible things that qualify for protection
18 under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
19 Cause Statement.
20 2.4. CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
21 SECRET/COMMERCIALLY SENSITIVE)” Information or Items: information
22 (regardless of how it is generated, stored or maintained) or tangible things that qualify
23 for protection under Federal Rule of Civil Procedure 26(c), and as specified above in
24 the Good Cause Statement, and which are available only for review as specified below
25 in section 7.3.
26 (a) Material designated as “CONFIDENTIAL – ATTORNEYS’ EYES
27 ONLY (TRADE SECRET/COMMERCIALLY SENSITIVE)” may include the
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1 following types of information: (1) sensitive technical information, including current
2 research and development information; (2) sensitive business information, including
3 highly sensitive financial or marketing information; (3) competitive technical
4 information, including technical analyses or comparisons of competitor’s products or
5 services; (4) competitive business information, including non-public financial and
6 marketing analyses, and strategic product/service expansion plans; (5) personal health
7 or medical information; (6) an individual’s personal credit, banking or other financial
8 information; or (7) information that is sensitive, confidential, or proprietary to a third
9 party for which the producing party has an obligation to that third party to maintain
10 confidentiality.
11 (b) For clarity, to avoid being overly inclusive, Material designated as
12 “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
13 SECRET/COMMERCIALLY SENSITIVE)” should not include the following,
14 unless it contains information listed in (a)(1)-(7) above: (1) documents and
15 communications with influencers and brand ambassadors regarding “hot girl walk,”
16 but excluding financial and non-public personal information, and excluding any
17 documents or communications regarding celebrity deals, if any; (2) documents and
18 communications concerning the conception, selection, design, clearance and/or
19 adoption of “hot girl walk” (for Fashion Nova, with respect to the products that had
20 “hot girl walk(s)” and other words in the style name, and the webpages which
21 collected some preexisting products and displayed “hot girl walk” or “plus size hot
22 girl walk” at the top of the pages); (3) documents concerning labels, hang tags, and
23 packaging stickers bearing “hot girl walk”; (4) the consumer-facing “front” portions
24 of either Party’s websites and any “view page source” information that was publicly
25 available via Chrome, and excluding non-public website data that constitutes sensitive
26 technical or competitive business information; (5) documents pertaining to
27 advertising and marketing materials with “hot girl walk,” but excluding non-public
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1 competitive business information; (6) documents showing HGW and its licensees’
2 use of “hot girl walk,” and HGW’s quality-control efforts, except information that is
3 protected by the attorney-client privilege and/or work product doctrine; (7) documents
4 and communications pertaining to third-party use of “hot girl walk” that was not
5 authorized by HGW; (8) total revenue and cost amounts from (1) the sale of products
6 or a collection of products offered by HGW or its licensees/partners in connection
7 with “hot girl walk; and (b) as to Fashion Nova, the sale of the products that had “hot
8 girl walk(s)” and other words in the style name, and from the webpages which
9 collected some preexisting products and displayed “hot girl walk” or “plus size hot
10 girl walk” at the top of the pages (the foregoing shall be treated as Confidential, and
11 other financial information shall be treated as Highly Confidential); (9) documents
12 pertaining to market research or trademark applications not subject to the protections
13 of the attorney-client privilege or work-product doctrine; and/or (10) consumer
14 reviews or testimonials referring to “hot girl walk,” excluding personal information.
15 The foregoing should not be construed to mean that any of the listed categories exists,
16 is relevant, or is discoverable or to include any documents subject to the protections
17 of the attorney-client privilege or attorney work product doctrine. This subparagraph
18 does not constitute an agreement by either Party that these categories of documents
19 are relevant and discoverable, or a waiver by either Party of its objections to any
20 discovery requests (including on grounds of privilege, overbreadth,
21 disproportionality, or undue burden), or any future argument that some documents
22 that arguably fall within these categories, or portions thereof, should be designated
23 “Highly Confidential.”
24 2.5. Counsel: Outside Counsel of Record and House Counsel (as well as their
25 support staff).
26 2.6. Designating Party: a Party or Non-Party that designates information or
27 items that it produces in disclosures or in responses to discovery as
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1 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
2 SECRET/COMMERCIALLY SENSITIVE).”
3 2.7. Disclosure or Discovery Material: all items or information, regardless of
4 the medium or manner in which it is generated, stored, or maintained (including,
5 among other things, testimony, transcripts, and tangible things), that are produced or
6 generated in disclosures or responses to discovery in this matter.
7 2.8. Expert: a person with specialized knowledge or experience in a matter
8 pertinent to the litigation who has been retained by a Party or its counsel to serve as
9 an expert witness or as a consultant in this Action.
10 2.9. House Counsel: attorneys who are employees of a party to this Action.
11 House Counsel does not include Outside Counsel of Record or any other outside
12 counsel.
13 2.10. Non-Party: any natural person, partnership, corporation, association, or
14 other legal entity not named as a Party to this action.
15 2.11. Outside Counsel of Record: attorneys who are not employees of a party
16 to this Action but are retained to represent or advise a party to this Action and have
17 appeared in this Action on behalf of that party or are affiliated with a law firm which
18 has appeared on behalf of that party, and includes support staff.
19 2.12. Party: any party to this Action, including all of its officers, directors,
20 employees, consultants, retained experts, and Outside Counsel of Record (and their
21 support staffs).
22 2.13. Producing Party: a Party or Non-Party that produces Disclosure or
23 Discovery Material in this Action.
24 2.14. Professional Vendors: persons or entities that provide litigation support
25 services (e.g., photocopying, videotaping, translating, preparing exhibits or
26 demonstrations, and organizing, storing, or retrieving data in any form or medium)
27 and their employees and subcontractors.
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1 2.15. Protected Material: any Disclosure or Discovery Material that is
2 designated as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES
3 ONLY (TRADE SECRET/COMMERCIALLY SENSITIVE).”
4 2.16. Receiving Party: a Party that receives Disclosure or Discovery Material
5 from a Producing Party.
6 3. SCOPE
7 The protections conferred by this Stipulation and Order cover not only
8 Protected Material (as defined above), but also (1) any information copied or extracted
9 from Protected Material; (2) all copies, excerpts, summaries, or compilations of
10 Protected Material; and (3) any testimony, conversations, or presentations by Parties
11 or their Counsel that might reveal Protected Material.
12 Any use of Protected Material at trial will be governed by the orders of the trial
13 judge. This Order does not govern the use of Protected Material at trial.
14 4. DURATION
15 Once a case proceeds to trial, all of the court-filed information to be introduced
16 that was previously designated as confidential or maintained pursuant to this
17 protective order becomes public and will be presumptively available to all members
18 of the public, including the press, unless compelling reasons supported by specific
19 factual findings to proceed otherwise are made to the trial judge in advance of the
20 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
21 2006) (distinguishing “good cause” showing for sealing documents produced in
22 discovery from “compelling reasons” standard when merits-related documents are
23 part of court record). Accordingly, the terms of this protective order do not extend
24 beyond the commencement of the trial.
25 5. DESIGNATING PROTECTED MATERIAL
26 5.1. Exercise of Restraint and Care in Designating Material for Protection.
27 Each Party or Non-Party that designates information or items for protection under this
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1 Order must take care to limit any such designation to specific material that qualifies
2 under the appropriate standards. The Designating Party must designate for protection
3 only those parts of material, documents, items, or oral or written communications that
4 qualify so that other portions of the material, documents, items, or communications
5 for which protection is not warranted are not swept unjustifiably within the ambit of
6 this Order.
7 Mass, indiscriminate, or routinized designations are prohibited. Any
8 designations that are determined by the Court to be unjustified or have been made for
9 an improper purpose (e.g., to unnecessarily encumber the case development process
10 or to impose unnecessary expenses and burdens on other parties) may expose the
11 Designating Party to sanctions.
12 If it comes to a Designating Party’s attention that information or items that it
13 designated for protection do not qualify for protection, that Designating Party must
14 promptly notify all other Parties that it is withdrawing the inapplicable designation.
15 5.2. Manner and Timing of Designations. Except as otherwise provided in
16 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
17 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
18 under this Order must be clearly so designated before the material is disclosed or
19 produced. Designation in conformity with this Order requires:
20 (a) for information in documentary form (e.g., paper or electronic
21 documents, but excluding transcripts of depositions or other pretrial or trial
22 proceedings), that the Producing Party affix at a minimum, the legend
23 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
24 SECRET/COMMERCIALLY SENSITIVE)” (hereinafter “CONFIDENTIAL
25 legend”), to each page that contains protected material. If only a portion or portions
26 of the material on a page qualifies for protection, the Producing Party also must clearly
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1 identify the protected portion(s) (e.g., by making appropriate markings in the
2 margins).
3 A Party or Non-Party that makes original documents available for inspection
4 need not designate them for protection until after the inspecting Party has indicated
5 which documents it would like copied and produced. During the inspection and before
6 the designation, all of the material made available for inspection will be deemed
7 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
8 SECRET/COMMERCIALLY SENSITIVE).” After the inspecting Party has
9 identified the documents it wants copied and produced, the Producing Party must
10 determine which documents, or portions thereof, qualify for protection under this
11 Order. Then, before producing the specified documents, the Producing Party must
12 affix the “CONFIDENTIAL legend” to each page that contains Protected Material. If
13 only a portion or portions of the material on a page qualifies for protection, the
14 Producing Party also must clearly identify the protected portion(s) (e.g., by making
15 appropriate markings in the margins).
16 (b) for testimony given in depositions that the Designating Party identify the
17 Disclosure or Discovery Material on the record, before the close of the deposition or
18 within 7 days of the Designating Party’s receipt of the final transcript.
19 (c) for information produced in some form other than documentary and for
20 any other tangible items, that the Producing Party affix in a prominent place on the
21 exterior of the container or containers in which the information is stored the legend
22 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
23 SECRET/COMMERCIALLY SENSITIVE).” If only a portion or portions of the
24 information warrants protection, the Producing Party, to the extent practicable, will
25 identify the protected portion(s).
26 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent
27 failure to designate qualified information or items does not, standing alone, waive the
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1 Designating Party’s right to secure protection under this Order for such material.
2 Upon timely correction of a designation, the Receiving Party must make reasonable
3 efforts to assure that the material is treated in accordance with the provisions of this
4 Order.
5 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6 6.1. Timing of Challenges. Any Party or Non-Party may challenge a
7 designation of confidentiality at any time that is consistent with the Court’s
8 Scheduling Order.
9 6.2. Meet and Confer. The Challenging Party will initiate the dispute
10 resolution process under Local Rule 37-1 et seq. Any discovery motion must strictly
11 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
12 6.3. Burden. The burden of persuasion in any such challenge proceeding will
13 be on the Designating Party. Frivolous challenges, and those made for an improper
14 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties)
15 may expose the Challenging Party to sanctions. Unless the Designating Party has
16 waived or withdrawn the confidentiality designation, all parties will continue to afford
17 the material in question the level of protection to which it is entitled under the
18 Producing Party’s designation until the Court rules on the challenge.
19 7. ACCESS TO AND USE OF PROTECTED MATERIAL
20 7.1. Basic Principles. A Receiving Party may use Protected Material that is
21 disclosed or produced by another Party or by a Non-Party in connection with this
22 Action only for prosecuting, defending, or attempting to settle this Action. Such
23 Protected Material may be disclosed only to the categories of persons and under the
24 conditions described in this Order. When the Action has been terminated, a Receiving
25 Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
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1 Protected Material must be stored and maintained by a Receiving Party at a
2 location and in a secure manner that ensures that access is limited to the persons
3 authorized under this Order.
4 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless
5 otherwise ordered by the court or permitted in writing by the Designating Party, a
6 Receiving Party may disclose any information or item designated
7 “CONFIDENTIAL” only to:
8 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
9 as employees of said Outside Counsel of Record to whom it is reasonably necessary
10 to disclose the information for this Action;
11 (b) the officers, directors, and employees (including House Counsel) of the
12 Receiving Party to whom disclosure is reasonably necessary for this Action;
13 (c) Experts (as defined in this Order) of the Receiving Party to whom
14 disclosure is reasonably necessary for this Action and who have signed the
15 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
16 (d) the Court and its personnel;
17 (e) court reporters and their staff
18 (f) professional jury or trial consultants, mock jurors, and Professional
19 Vendors to whom disclosure is reasonably necessary for this Action and who have
20 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
21 (g) the author or recipient of a document containing the information or a
22 custodian or other person who otherwise possessed or knew the information;
23 (h) during their depositions, witnesses, and attorneys for witnesses, in the
24 Action to whom disclosure is reasonably necessary provided: (1) the deposing party
25 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
26 not be permitted to keep any confidential information unless they sign the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
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1 agreed by the Designating Party or ordered by the court. Pages of transcribed
2 deposition testimony or exhibits to depositions that reveal Protected Material may be
3 separately bound by the court reporter and may not be disclosed to anyone except as
4 permitted under this Stipulated Protective Order; and
5 (i) any mediator or settlement officer, and their supporting personnel,
6 mutually agreed upon by any of the parties engaged in settlement discussions.
7 7.3. Disclosure of “CONFIDENTIAL – ATTORNEYS’ EYES ONLY
8 (TRADE SECRET/ COMMERCIALLY SENSITIVE)” Information or Items. Unless
9 otherwise ordered by the court or permitted in writing by the Designating Party, a
10 Receiving Party may disclose any information or item designated “CONFIDENTIAL
11 – ATTORNEYS’ EYES ONLY (TRADE SECRET/ COMMERCIALLY
12 SENSITIVE)” only to:
13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
14 as employees of said Outside Counsel of Record to whom it is reasonably necessary
15 to disclose the information for this Action;
16 (b) Experts (as defined in this Order) of the Receiving Party to whom
17 disclosure is reasonably necessary for this Action and who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
19 (c) the court and its personnel;
20 (d) court reporters and their staff;
21 (e) professional jury or trial consultants, mock jurors, and Professional
22 Vendors to whom disclosure is reasonably necessary for this Action and who have
23 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (f) the author or recipient of a document containing the information or a
25 custodian or other person who otherwise possessed or knew the information;
26 (g) any mediator or settlement officer, and their supporting personnel,
27 mutually agreed upon by any of the parties engaged in settlement discussions.
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1 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
2 OTHER LITIGATION.
3 If a Party is served with a subpoena or a court order issued in other litigation
4 that compels disclosure of any information or items designated in this Action as
5 “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY (TRADE
6 SECRET/ COMMERCIALLY SENSITIVE),” that Party must:
7 (a) promptly notify in writing the Designating Party. Such notification will
8 include a copy of the subpoena or court order;
9 (b) promptly notify in writing the party who caused the subpoena or order to
10 issue in the other litigation that some or all of the material covered by the subpoena
11 or order is subject to this Protective Order. Such notification will include a copy of
12 this Stipulated Protective Order; and
13 (c) cooperate with respect to all reasonable procedures sought to be pursued
14 by the Designating Party whose Protected Material may be affected.
15 If the Designating Party timely seeks a protective order, the Party served with
16 the subpoena or court order will not produce any information designated in this action
17 as “CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY
18 (TRADE SECRET/ COMMERCIALLY SENSITIVE)” before a determination by the
19 court from which the subpoena or order issued, unless the Party has obtained the
20 Designating Party’s permission. The Designating Party will bear the burden and
21 expense of seeking protection in that court of its confidential material and nothing in
22 these provisions should be construed as authorizing or encouraging a Receiving Party
23 in this Action to disobey a lawful directive from another court.
24 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
25 PRODUCED IN THIS LITIGATION
26 (a) The terms of this Order are applicable to information produced by a Non-
27 Party in this Action and designated as “CONFIDENTIAL” or “CONFIDENTIAL –
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1 ATTORNEYS’ EYES ONLY (TRADE SECRET/ COMMERCIALLY
2 SENSITIVE).” Such information produced by Non-Parties in connection with this
3 litigation is protected by the remedies and relief provided by this Order. Nothing in
4 these provisions should be construed as prohibiting a Non-Party from seeking
5 additional protections.
6 (b) In the event that a Party is required, by a valid discovery request, to
7 produce a Non-Party’s confidential information in its possession, and the Party is
8 subject to an agreement with the Non-Party not to produce the Non-Party’s
9 confidential information, then the Party will:
10 (1) promptly notify in writing the Requesting Party and the Non-Party
11 that some or all of the information requested is subject to a confidentiality agreement
12 with a Non-Party;
13 (2) promptly provide the Non-Party with a copy of the Stipulated
14 Protective Order in this Action, the relevant discovery request(s), and a reasonably
15 specific description of the information requested; and
16 (3) make the information requested available for inspection by the
17 Non-Party, if requested.
18 (c) If the Non-Party fails to seek a protective order from this court within 14
19 days of receiving the notice and accompanying information, the Receiving Party may
20 produce the Non-Party’s confidential information responsive to the discovery request.
21 If the Non-Party timely seeks a protective order, the Receiving Party shall not produce
22 any information in its possession or control that is subject to the confidentiality
23 agreement with the Non-Party before a determination by the court. Absent a court
24 order to the contrary, the Non-Party shall bear the burden and expense of seeking
25 protection in this court of its Protected Material.
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1 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL.
2 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
3 Protected Material to any person or in any circumstance not authorized under this
4 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
5 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
6 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
7 persons to whom unauthorized disclosures were made of all the terms of this Order,
8 and (d) request such person or persons to execute the “Acknowledgment and
9 Agreement to Be Bound” that is attached hereto as Exhibit A.
10 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
11 PROTECTED MATERIAL.
12 When a Producing Party gives notice to Receiving Parties that certain
13 inadvertently produced material is subject to a claim of privilege or other protection,
14 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
15 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
16 may be established in an e-discovery order that provides for production without prior
17 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
18 parties reach an agreement on the effect of disclosure of a communication or
19 information covered by the attorney-client privilege or work product protection, the
20 parties may incorporate their agreement in the stipulated protective order submitted
21 to the court.
22 12. MISCELLANEOUS
23 12.1. Right to Further Relief. Nothing in this Order abridges the right of any
24 person to seek its modification by the Court in the future.
25 12.2. Right to Assert Other Objections. By stipulating to the entry of this
26 Protective Order no Party waives any right it otherwise would have to object to
27 disclosing or producing any information or item on any ground not addressed in this
28
1 Stipulated Protective Order. Similarly, no Party waives any right to object on any
2 ground to use in evidence of any of the material covered by this Protective Order.
3 12.3. Filing Protected Material. A Party that seeks to file under seal any
4 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
5 only be filed under seal pursuant to a court order authorizing the sealing of the specific
6 Protected Material at issue; good cause must be shown in the request to file under
7 seal. If a Party’s request to file Protected Material under seal is denied by the court,
8 then the Receiving Party may file the information in the public record unless
9 otherwise instructed by the court.
10 13. FINAL DISPOSITION.
11 After the final disposition of this Action, within 60 days of a written request by
12 the Designating Party, each Receiving Party must return all Protected Material to the
13 Producing Party or destroy such material. As used in this subdivision, “all Protected
14 Material” includes all copies, abstracts, compilations, summaries, and any other
15 format reproducing or capturing any of the Protected Material. Whether the Protected
16 Material is returned or destroyed, the Receiving Party must submit a written
17 certification to the Producing Party (and, if not the same person or entity, to the
18 Designating Party) by the 60 day deadline that (1) identifies (by category, where
19 appropriate) all the Protected Material that was returned or destroyed and (2) affirms
20 that the Receiving Party has not retained any copies, abstracts, compilations,
21 summaries or any other format reproducing or capturing any of the Protected Material.
22 Notwithstanding this provision, Counsel are entitled to retain an archival copy of all
23 pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
24 correspondence, deposition and trial exhibits, expert reports, attorney work product,
25 and consultant and expert work product, even if such materials contain Protected
26 Material. Any such archival copies that contain or constitute Protected Material
27 remain subject to this Protective Order as set forth in Section 4 (DURATION).
28
1| 14. VIOLATION OF ORDER
2 Any willful violation of this Order may be punished by civil or criminal
3 | contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
4 | authorities, or other appropriate action at the discretion of the Court.
5
6 | IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
7
Dated: April 15, 2026 DICKINSON WRIGHT PLLC
By: /s/ John L. Krieger
10 John L. Krieger
Attorneys for Praintiff and Counter-
11 Defendant Hot Girl Walk LLC
12
3 Dated: April 15, 2026 MITCHELL SILBERBERG & KNUPP LLP

14
By: /s/ Elaine K. Kim
15 Elaine K. Kim
Attorneys for Defendant and Counter-
16 Claimant Fashion Nova, LLC
17
18 Attestation Regarding Signatures
19 I, John L. Krieger, attest that all signatories listed, and on whose behalf the
20 | filing is submitted, concur in the filing’s content and have authorized the filing.
21 | Dated: April 15, 2026 By: □□□ John L. Krieger
John L. Krieger
22
23
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

DATED: April 16, 2026
26 HON. DANIEL S. ROBERTS
United States Magistrate Judge
28

1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [print or type full name], of
4 _________________ [print or type full address], declare under penalty of
5 perjury that I have read in its entirety and understand the Stipulated Protective Order
6 that was issued by the United States District Court for the Central District of
7 California on _________ [date] in the case of Hot Girl Walk LLC v. Fashion Nova,
8 LLC; Fashion Nova, LLC v. Hot Girl Walk LLC, Case No. 2:25-cv-10800-
9 JFW(DSRx). I agree to comply with and to be bound by all the terms of this Stipulated
10 Protective Order and I understand and acknowledge that failure to so comply could
11 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
12 that I will not disclose in any manner any information or item that is subject to this
13 Stipulated Protective Order to any person or entity except in strict compliance with
14 the provisions of this Order.
15 I further agree to submit to the jurisdiction of the United States District Court
16 for the Central District of California for the purpose of enforcing the terms of this
17 Stipulated Protective Order, even if such enforcement proceedings occur after
18 termination of this action. I hereby appoint __________________________ [print or
19 type full name] of _______________________________________ [print or type full
20 address and telephone number] as my California agent for service of process in
21 connection with this action or any proceedings related to enforcement of this
22 Stipulated Protective Order.
23 Date: ______________________________________
24 City and State where signed: _________________________________
25 Printed name: _______________________________
26 Signature: __________________________________
27
28

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11373848. Public record. Not legal advice.