Opinion

Court: District Court, C.D. California
Filed: Jun 1, 2026
Cited by: 0 cases

The opinion

8 UNITED STATES DISTRICT COURT

9 CENTRAL DISTRICT OF CALIFORNIA

10 WESTERN DIVISION

Case No. 2:25-cv-07458

ICON ACADEMY, LLC, a Delaware

limited liability company,

STIPULATED PROTECTIVE

ORDER

Plaintiff,

[With Modifications by the Court]

HASSAN MAHMOUD, an

18 individual; and NOA TECHS – FZCO

Defendants.

1. GENERAL

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

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

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

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

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

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

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

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

3 treatment under the applicable legal principles. The parties further acknowledge, as

4 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle

5 them to file confidential information under seal; Civil Local Rule 79-5 sets forth the

6 procedures that must be followed and the standards that will be applied when a party

7 seeks permission from the court to file material under seal.

8 1.2 Good Cause Statement. This action is likely to involve documents or

9 information such as trade secrets, affiliate ang genealogy data, customer data and

10 pricing lists and other valuable network marketing business, research, development,

11 commercial, financial, technical and/or proprietary information tailored to the case

12 for which special protection from public disclosure and from use for any purpose other

13 than prosecution of this action is warranted. Such confidential and proprietary

14 materials and information consist of, among other things, confidential business or

15 financial information, information regarding confidential business practices, or other

16 confidential research, development, or commercial information (including

17 information implicating privacy rights of third parties, information otherwise

18 generally unavailable to the public, or which may be privileged or otherwise protected

19 from disclosure under state or federal statutes, court rules, case decisions, or common

20 law. Accordingly, to expedite the flow of information, to facilitate the prompt

21 resolution of disputes over confidentiality of discovery materials, to adequately

22 protect information the parties are entitled to keep confidential, to ensure that the

23 parties are permitted reasonable necessary uses of such material in preparation for and

24 in the conduct of trial, to address their handling at the end of the litigation, and serve

25 the ends of justice, a protective order for such information is justified in this matter.

26 It is the intent of the parties that information will not be designated as confidential for

27 tactical reasons and that nothing be so designated without a good faith belief that it

1 has been maintained in a confidential, non-public manner, and there is good cause

2 why it should not be part of the public record of this case.

3 2. DEFINITIONS

4 2.1 Action: the above-entitled proceeding, C.D. Cal. Case No. 2:25-cv-

5 07458-PA-AYP2.2 Challenging Party: a Party or Non-Party that challenges the

6 designation of information or items under this Order.

7 2.3 “Confidential” Information or Items: information (regardless of how it

8 is generated, stored or maintained) or tangible things that qualify for protection under

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

10 Statement. For avoidance of doubt, except where this Order provides more restrictive

11 treatment, all references to “Confidential” Information or Items shall be deemed to

12 include “Highly Confidential – Attorneys’ Eyes Only” Information or Items, and all

13 procedures for designation, challenges, use, and inadvertent production that apply to

14 “Confidential” Information or Items shall apply equally to “Highly Confidential –

15 Attorneys’ Eyes Only” Information or Items.

16 2.4 Counsel: Counsel of Record (as well as their support staff).

17 2.5 Designating Party: a Party or Non-Party that designates information or

18 items that it produces in disclosures or in responses to discovery as “Confidential” or

19 “Highly Confidential.”

20 2.6 Disclosure or Discovery Material: all items or information, regardless

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

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

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

24 2.7 Expert: a person with specialized knowledge or experience in a matter

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

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

27 2.82.9 Non-Party: any natural person, partnership, corporation, association, or

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

1 2.11 Party: any party to this Action, including all of its officers, directors,

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

3 support staffs).

4 2.12 Producing Party: a Party or Non-Party that produces Disclosure or

5 Discovery Material in this Action.

6 2.13 Professional Vendors: persons or entities that provide litigation support

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

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

9 and their employees and subcontractors.

10 2.14 Protected Material: any Disclosure or Discovery Material that is

11 designated as “Confidential” or “Highly Confidential.”

12 2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

13 from a Producing Party.

14 3. SCOPE

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

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

17 from Protected Material; (2) all copies, excerpts, summaries, or compilations of

18 Protected Material; and (3) any testimony, conversations, or presentations by Parties

19 or their Counsel that might reveal Protected Material.

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

21 trial judge. This Order does not govern the use of Protected Material at trial.

22 4. DURATION

23 . Once a case proceeds to trial, all of the court-filed information to be introduced

24 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). Accordingly, the terms of this protective order do not extend

4 beyond the commencement of the trial.

5 Even after the disposition of this litigation, the confidential obligations imposed

6 by this Stipulated Protective Order shall remain in effect until a Designating Party

7 agrees otherwise in writing or a court order otherwise directs. Final disposition shall

8 be deemed to be the later of (1) dismissal of all claims and defenses in this Action,

9 with or without prejudice, and (2) final judgment herein after the completion and

10 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,

11 including the time limits for filing any motions or applications for extension of time

12 pursuant to applicable law.

13 5. DESIGNATING PROTECTED MATERIAL

14 5.1 Exercise of Restraint and Care in Designating Material for Protection.

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

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

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

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

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

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

21 this Order.

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

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

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

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

26 to sanctions.

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

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

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

4 5.2 Manner and Timing of Designations. Except as otherwise provided in

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

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

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

8 produced.

9 Designation in conformity with this Order requires:

10 (a) For information in documentary form (e.g., paper or electronic documents,

11 but excluding transcripts of depositions or other pretrial or trial

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

13 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), or “Highly

14 Confidential – Attorney’s Eyes Only” to each page that contains protected

15 material. If only a portion or portions of the material on a page qualifies

16 for protection, the Producing Party also must clearly identify the protected

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

18 (b) Testimony taken at a deposition may be designated as “Confidential” or

19 “Highly Confidential – Attorney’s Eyes Only” by making a statement to that

20 effect on the record at the deposition. Arrangements shall be made with the

21 court reporter taking and transcribing such deposition to separately bind such

22 portions of the transcript containing information designated as confidential,

23 and to label such portions appropriately;

24 (c) For Information produced by the Designating Party in some form other

25 than Documents, and for any other tangible items, including, without limitation,

26 compact discs or DVDs, the Designating Party must affix in a prominent place on the

27 exterior of the container or containers in which the Information or item is stored the

28 legend “Confidential” or “Highly Confidential – Attorneys’ Eyes Only.” If only

1 portions of the Information or item warrant protection, the Designating Party, to the

2 extent practicable, shall identify the “Confidential” or “Highly Confidential –

3 Attorneys’ Eyes Only” portions.

4 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent

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

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

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

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

9 Order.

10 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS

11 6.1 Timing of Challenges. Any Party or Non-Party may challenge a

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

13 Scheduling Order.

14 6.2 Meet and Confer. The Challenging Party shall initiate the dispute

15 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly

16 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.

17 6.3 Burden. The burden of persuasion in any such challenge proceeding

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

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

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

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

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

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

24 7. ACCESS TO AND USE OF PROTECTED MATERIAL

25 7.1 Basic Principles. A Receiving Party may use Protected Material that is

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

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

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

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

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

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

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

5 authorized under this Order.

6 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless

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

8 Receiving Party may disclose any information or item designated

9 “CONFIDENTIAL” only to:

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

11 employees of said Counsel of Record to whom it is reasonably necessary to disclose

12 the information for this Action;

13 (b) the officers, directors, and employees of the Receiving Party to

14 whom disclosure is reasonably necessary for this Action;

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

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

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

18 (d) the Court and its personnel;

19 (e) court reporters and their staff;

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

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

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

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

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

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

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

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

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

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

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

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

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

5 permitted under this Stipulated Protective Order; and

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

7 agreed upon by any of the parties engaged in settlement discussions.

8 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES

9 ONLY” Information or Items. The parties may further designate certain discovery

10 material or testimony of a highly confidential and/or proprietary nature as

11 “CONFIDENTIAL - ATTORNEY’S EYES ONLY” (hereinafter “Attorney’s Eyes

12 Only Material”), in the manner described in paragraphs 2 and 3 above. Attorney’s

13 Eyes Only Material, and the information contained therein, shall be disclosed only to

14 the Court, to counsel for the parties (including the paralegal, clerical and secretarial

15 staff employed by such counsel), and to the qualified persons listed in subparagraphs

16 7.2(a) and (c) through (h) above, but shall not be disclosed to a party, or to an officer,

17 director or employee of a party, unless otherwise agreed or ordered. If disclosure of

18 Attorney’s Eyes Only Material is made pursuant to this paragraph, all other provisions

19 in this order with respect to confidentiality shall also apply.

20 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED

21 PRODUCED IN OTHER LITIGATION

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

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

24 “Confidential” or “Highly Confidential,” that Party must:

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

26 include a copy of the subpoena or court order;

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

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

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

2 this Stipulated Protective Order; and

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

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

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

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

7 as “Confidential” or “Highly Confidential” before a determination by the court from

8 which the subpoena or order issued, unless the Party has obtained the Designating

9 Party’s permission. The Designating Party shall bear the burden and expense of

10 seeking protection in that court of its confidential material and nothing in these

11 provisions should be construed as authorizing or encouraging a Receiving Party in

12 this Action to disobey a lawful directive from another court.

13 A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE

14 PRODUCED IN THIS LITIGATION

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

16 this Action and designated as “CONFIDENTIAL.” Such information produced

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

18 and relief provided by this Order. Nothing in these provisions should be

19 construed as prohibiting a Non-Party from seeking additional protections.

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

21 Non-Party’s confidential information in its possession, and the Party is subject

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

23 information, then the Party shall:

24 (1) promptly notify in writing the Requesting Party and the Non-Party that some or

25 all of the information requested is subject to a confidentiality agreement with a

26 Non-Party;

1 (2) promptly provide the Non-Party with a copy of the Stipulated Protective Order in

2 this Action, the relevant discovery request(s), and a reasonably specific

3 description of the information requested; and

4 (3) make the information requested available for inspection by the Non-Party, if

5 requested.

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

7 receiving the notice and accompanying information, the Receiving Party may

8 produce the Non-Party’s confidential information responsive to the discovery

9 request. If the Non-Party timely seeks a protective order, the Receiving Party

10 shall not produce any information in its possession or control that is subject to

11 the confidentiality agreement with the Non-Party before a determination by the

12 Court. Absent a court order to the contrary, the Non-Party shall bear the burden

13 and expense of seeking protection in this Court of its Protected Material.

14 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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

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

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

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

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

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

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

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

23 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE

24 PROTECTED MATERIAL

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

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

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

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

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

2 privilege review.

3 Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the parties reach

4 an agreement on the effect of disclosure of a communication or information covered

5 by the attorney-client privilege or work product protection, the parties may

6 incorporate their agreement in the stipulated protective order submitted to the Court.

7 12. MISCELLANEOUS

8 12.1 Right to Further Relief. Nothing in this Order abridges the right of any

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

10 12.2 Right to Assert Other Objections. By stipulating to the entry of this

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

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

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

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

15 12.3 Filing Protected Material. A Party that seeks to file under seal any

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

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

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

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

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

21 otherwise instructed by the Court.

22 13. FINAL DISPOSITION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

11 remain subject to this Protective Order as set forth in Section 4 (DURATION).

12 14. VIOLATION OF ORDER

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

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

15 sanctions.

2 || ITIS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5 || DATED:_May 22, 2026

6 /s/Ross M. Campbell

7 || Attorneys for Plaintiff(s)

DATED: __ May 22, 2026

11. || _4s/Shahrokh Sheik

Attorneys for Defendant(s)

13 |] FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

16 || DATED:_ June 1, 2026 AD.

17 United States Mavistrate Judge

1 EXHIBIT A

2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

4 I, _____________________________ [full name], of _________________

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

6 understand the Stipulated Protective Order that was issued by the United States

7 District Court for the Central District of California in the case of Icon Academy,

8 LLC v. Hassan Mahmoud, et al., Civil Action No. 2:25-07458-PA-AYP). I agree to

9 comply with and to be bound by all the terms of this Stipulated Protective Order and

10 I understand and acknowledge that failure to so comply could expose me to

11 sanctions and punishment in the nature of contempt. I solemnly promise that I will

12 not disclose in any manner any information or item that is subject to this Stipulated

13 Protective Order to any person or entity except in strict compliance with the

14 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 __________________________ [full

19 name] of _______________________________________ [full address and

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

21 this action or any proceedings related to enforcement of this Stipulated Protective

22 Order.

23 Date: ______________________________________

24 City and State where signed: _________________________________

26 Printed name: _______________________________

28 Signature: __________________________________

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