# Opinion

> District Court, C.D. California · June 17, 2026

URL: https://www.frixlaw.com/law-library/cases/11383629

## Case

- **Full name:** Spoon Co., Ltd. v. Go Tuning Unlimited, LLC
- **Court:** District Court, C.D. California
- **Decided:** June 17, 2026
- **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 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10
Case No. 8:25-cv-01451-FWS-JDE
11 SPOON CO., LTD., a Japanese
corporation STIPULATED PROTECTIVE ORDER
12
Plaintiff,
13
v.
14

15 GO TUNING UNLIMITED, LLC, a
California limited liability company,
16
Defendant.
17
18 Based on the parties’ Stipulation and for good cause show, the Court finds
19 and orders as follows.
20 1. PURPOSES AND LIMITATIONS
21 Discovery in this action is likely to involve production of confidential,
22 proprietary or private information for which special protection from public
23 disclosure and from use for any purpose other than pursuing this litigation may be
24 warranted. This Order does not confer blanket protections on all disclosures or
25 responses to discovery and the protection it affords from public disclosure and use
26 extends only to the limited information or items that are entitled to confidential
27 treatment under the applicable legal principles.

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1 2. GOOD CAUSE STATEMENT
2 This action is likely to involve trade secrets, customer and pricing lists and
3 other valuable research, development, commercial, financial, technical and/or
4 proprietary information for which special protection from public disclosure and
5 from use for any purpose other than prosecution of this action is warranted. Such
6 confidential and proprietary materials and information consist of, among other
7 things, confidential business or financial information, information regarding
8 confidential business practices, or other confidential research, development, or
9 commercial information (including information implicating privacy rights of third
10 parties), information otherwise generally unavailable to the public, or which may be
11 privileged or otherwise protected from disclosure under state or federal statutes,
12 court rules, case decisions, or common law. Accordingly, to expedite the flow of
13 information, to facilitate the prompt resolution of disputes over confidentiality of
14 discovery materials, to adequately protect information the parties are entitled to
15 keep confidential, to ensure that the parties are permitted reasonable necessary uses
16 of such material in preparation for and in the conduct of trial, to address their
17 handling at the end of the litigation, and serve the ends of justice, a protective order
18 for such information is justified in this matter. It is the intent of the parties that
19 information will not be designated as confidential for tactical reasons and that
20 nothing be so designated without a good faith belief that it has been maintained in a
21 confidential, non-public manner, and there is good cause why it should not be part
22 of the public record of this case.
23 3. UNDER SEAL FILING PROCEDURE
24 As set forth in Section 14.3, below, that this Protective Order does not entitle
25 the parties to file confidential information under seal; Local Civil Rule 79-5 sets
26 forth the procedures that must be followed and the standards that will be applied
27 when a party seeks permission from the court to file material under seal. There is a
28 strong presumption that the public has a right of access to judicial proceedings and
1 records in civil cases. In connection with non-dispositive motions, good cause must
2 be shown to support a filing under seal. See Kamakana v. City and County of
3 Honolulu, 447 F.3d 1172, 1176 (9th Cir. 2006), Phillips v. Gen. Motors Corp., 307
4 F.3d 1206, 1210-11 (9th Cir. 2002), Makar-Welbon v. Sony Electrics, Inc., 187
5 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated protective orders require good
6 cause showing), and a specific showing of good cause or compelling reasons with
7 proper evidentiary support and legal justification, must be made with respect to
8 Protected Material that a party seeks to file under seal. The parties’ mere
9 designation of Disclosure or Discovery Material as CONFIDENTIAL or HIGHLY
10 CONFIDENTIAL – ATTORNEY’ ONLY does not—without the submission of
11 competent evidence by declaration, establishing that the material sought to be filed
12 under seal qualifies as confidential, privileged, or otherwise protectable—constitute
13 good cause.
14 Further, if a party requests sealing related to a dispositive motion or trial,
15 then compelling reasons, not only good cause, for the sealing must be shown, and
16 the relief sought shall be narrowly tailored to serve the specific interest to be
17 protected. See Pintos v. Pacific Creditors Ass’n., 605 F.3d 665, 677-79 (9th Cir.
18 2010). For each item or type of information, document, or thing sought to be filed
19 or introduced under seal, the party seeking protection must articulate compelling
20 reasons, supported by specific facts and legal justification, for the requested sealing
21 order. Again, competent evidence supporting the application to file documents
22 under seal must be provided by declaration.
23 Any document that is not confidential, privileged, or otherwise protectable in its
24 entirety will not be filed under seal if the confidential portions can be redacted. If
25 documents can be redacted, then a redacted version for public viewing, omitting
26 only the confidential, privileged, or otherwise protectable portions of the document,
27 shall be filed. Any application that seeks to file documents under seal in their
28 entirety should include an explanation of why redaction is not feasible.
1 4. DEFINITIONS
2 4.1 Action: this pending federal lawsuit.
3 4.2 Challenging Party: a Party or Non-Party that challenges the
4 designation of information or items under this Order.
5 4.3 “CONFIDENTIAL” Information or Items: information (regardless of
6 how it is generated, stored or maintained) or tangible things that qualify for
7 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
8 the Good Cause Statement.
9 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as
10 their support staff).
11 4.5 Designating Party: a Party or Non-Party that designates information or
12 items that it produces in disclosures or in responses to discovery as
13 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
14 ONLY.”
15 4.6 Disclosure or Discovery Material: all items or information, regardless
16 of the medium or manner in which it is generated, stored, or maintained (including,
17 among other things, testimony, transcripts, and tangible things), that are produced
18 or generated in disclosures or responses to discovery.
19 4.7 Expert: a person with specialized knowledge or experience in a matter
20 pertinent to the litigation who has been retained by a Party or its counsel to serve as
21 an expert witness or as a consultant in this Action.
22 4.8 House Counsel: attorneys who are employees of a party to this Action.
23 House Counsel does not include Outside Counsel of Record or any other outside
24 counsel.
25 4.9 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
26 Information or items: extremely sensitive “Confidential Information or Items,”
27 disclosure of which to another Party or Non-Party would create a substantial risk of
28 serious harm that could not be avoided by less restrictive means
1 4.10 Non-Party: any natural person, partnership, corporation, association or
2 other legal entity not named as a Party to this action.
3 4.11 Outside Counsel of Record: attorneys who are not employees of a party
4 to this Action but are retained to represent a party to this Action and have appeared
5 in this Action on behalf of that party or are affiliated with a law firm that has
6 appeared on behalf of that party, and includes support staff.
7 4.12 Party: a party to this Action, including its officers, directors, employees,
8 consultants, retained experts, and Outside Counsel of Record (and their support
9 staffs).
10 4.13 Producing Party: a Party or Non-Party that produces Disclosure or
11 Discovery Material in this Action.
12 4.14 Professional Vendors: persons or entities that provide litigation support
13 services (e.g., photocopying, videotaping, translating, preparing exhibits or
14 demonstrations, and organizing, storing, or retrieving data in any form or medium)
15 and their employees and subcontractors.
16 4.15 Protected Material: any Disclosure or Discovery Material that is
17 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
18 ATTORNEYS’ EYES ONLY.”
19 4.16 Receiving Party: a Party that receives Disclosure or Discovery
20 Material from a Producing Party.
21 5. SCOPE
22 The protections conferred by this Order cover not only Protected Material (as
23 defined above), but also (1) any information copied or extracted from Protected
24 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
25 and (3) any testimony, conversations, or presentations by Parties or their Counsel
26 that might reveal Protected Material. Any use of Protected Material at trial shall be
27 governed by the orders of the trial judge and other applicable authorities. This
28 Order does not govern the use of Protected Material at trial.
1 6. DURATION
2 Once a case proceeds to trial, information that was designated as
3 CONFIDENTIAL or maintained pursuant to this protective order used or
4 introduced as an exhibit at trial becomes public and will be presumptively available
5 to all members of the public, including the press, unless compelling reasons
6 supported by specific factual findings to proceed otherwise are made to the trial
7 judge in advance of the trial. See Kamakana, 447 F.3d at 1180-81 (distinguishing
8 “good cause” showing for sealing documents produced in discovery from
9 “compelling reasons” standard when merits-related documents are part of court
10 record). Accordingly, the terms of this protective order do not extend beyond the
11 commencement of the trial.
12 7. DESIGNATING PROTECTED MATERIAL
13 7.1 Exercise of Restraint and Care in Designating Material for
14 Protection. Each Party or Non-Party that designates information
15 or items for protection under this Order must take care to limit any such designation
16 to specific material that qualifies under the appropriate standards. The Designating
17 Party must designate for protection only those parts of material, documents, items
18 or oral or written communications that qualify so that other portions of the material,
19 documents, items or communications for which protection is not warranted are not
20 swept unjustifiably within the ambit of this Order.
21 Mass, indiscriminate or routinized designations are prohibited. Designations
22 that are shown to be clearly unjustified or that have been made for an improper
23 purpose (e.g., to unnecessarily encumber the case development process or to
24 impose unnecessary expenses and burdens on other parties) may expose the
25 Designating Party to sanctions.
26 If it comes to a Designating Party’s attention that information or items that it
27 designated for protection do not qualify for protection, that Designating Party must
28 promptly notify all other Parties that it is withdrawing the inapplicable designation.
1 7.2 Manner and Timing of Designations. Except as otherwise provided in
2 this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material
3 that qualifies for protection under this Order must be clearly so designated before
4 the material is disclosed or produced.
5 Designation in conformity with this Order requires:
6 (a) for information in documentary form (e.g., paper or electronic
7 documents, but excluding transcripts of depositions or other pretrial or trial
8 proceedings), that the Producing Party affix at a minimum, the legend
9 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
10 ONLY” (hereinafter “CONFIDENTIAL legend”), to each page that contains
11 protected material. If only a portion of the material on a page qualifies for
12 protection, the Producing Party also must clearly identify the protected portion(s)
13 (e.g., by making appropriate markings in the margins).
14 A Party or Non-Party that makes original documents available for inspection
15 need not designate them for protection until after the inspecting Party has indicated
16 which documents to be copied and produced. During the inspection and before the
17 designation, all material made available for inspection shall be deemed
18 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
19 ONLY.” After the inspecting Party has identified the documents to be copied and
20 produced, the Producing Party must determine which documents, or portions
21 thereof, qualify for protection under this Order. Then, before producing the
22 specified documents, the Producing Party must affix the “CONFIDENTIAL
23 legend” to each page that contains Protected Material. If only a portion of the
24 material on a page qualifies for protection, the Producing Party must clearly identify
25 the protected portion(s) (e.g., by making appropriate markings in the margins).
26 (b) for testimony given in depositions that the Designating Party
27 identifies the Disclosure or Discovery Material on the record, before the close of the
28 deposition all protected testimony.
1 (c) for information produced in some form other than documentary and
2 for any other tangible items, that the Producing Party affix in a prominent place on
3 the exterior of the container or containers in which the information is stored the
4 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
5 EYES ONLY.” If only a portion or portions of the information warrants protection,
6 the Producing Party, to the extent practicable, shall identify the protected portion(s).
7 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent
8 failure to designate qualified information or items does not, standing alone, waive
9 the Designating Party’s right to secure protection under this Order for such material.
10 Upon timely correction of a designation, the Receiving Party must make reasonable
11 efforts to assure that the material is treated in accordance with the provisions of this
12 Order.
13 8. CHALLENGING CONFIDENTIALITY DESIGNATIONS
14 8.1. Timing of Challenges. Any Party or Non-Party may challenge a
15 designation of confidentiality at any time that is consistent with the Court’s
16 Scheduling Order.
17 8.2 Meet and Confer. The Challenging Party shall initiate the dispute
18 resolution process under Local Rule 37-1 et seq.
19 8.3 Joint Stipulation. Any challenge submitted to the Court shall be via a
20 joint stipulation pursuant to Local Rule 37-2.
21 8.4 The burden of persuasion in any such challenge proceeding shall be on
22 the Designating Party. Frivolous challenges, and those made for an improper
23 purpose (e.g., to harass or impose unnecessary expenses and burdens on other
24 parties) may expose the Challenging Party to sanctions. Unless the Designating
25 Party has waived or withdrawn the confidentiality designation, all parties shall
26 continue to afford the material in question the level of protection to which it is
27 entitled under the Producing Party’s designation until the Court rules on the
28 challenge.
1 9. ACCESS TO AND USE OF PROTECTED MATERIAL
2 9.1 Basic Principles. A Receiving Party may use Protected Material that is
3 disclosed or produced by another Party or by a Non-Party in connection with this
4 Action only for prosecuting, defending or attempting to settle this Action. Such
5 Protected Material may be disclosed only to the categories of persons and under the
6 conditions described in this Order. When the Action has been terminated, a
7 Receiving Party must comply with the provisions of section 15 below (FINAL
8 DISPOSITION).
9 Protected Material must be stored and maintained by a Receiving Party at a
10 location and in a secure manner that ensures that access is limited to the persons
11 authorized under this Order.
12 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless
13 otherwise ordered by the court or permitted in writing by the Designating Party, a
14 Receiving Party may disclose any information or item designated
15 “CONFIDENTIAL” only to:
16 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
17 well as employees of said Outside Counsel of Record to whom it is reasonably
18 necessary to disclose the information for this Action;
19 (b) the officers, directors, and employees (including House Counsel) of
20 the Receiving Party to whom disclosure is reasonably necessary for this Action;
21 (c) Experts (as defined in this Order) of the Receiving Party to whom
22 disclosure is reasonably necessary for this Action and who have signed the
23 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
24 (d) the court and its personnel;
25 (e) court reporters and their staff;
26 (f) professional jury or trial consultants, mock jurors, and Professional
27 Vendors to whom disclosure is reasonably necessary for this Action and who have
28 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
1 (g) the author or recipient of a document containing the information or
2 a custodian or other person who otherwise possessed or knew the information;
3 (h) during their depositions, witnesses, and attorneys for witnesses, in
4 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
5 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
6 they will not be permitted to keep any confidential information unless they sign the
7 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
8 agreed by the Designating Party or ordered by the court. Pages of transcribed
9 deposition testimony or exhibits to depositions that reveal Protected Material may
10 be separately bound by the court reporter and may not be disclosed to anyone
11 except as permitted under this Stipulated Protective Order; and
12 (i) any mediators or settlement officers and their supporting personnel,
13 mutually agreed upon by any of the parties engaged in settlement discussions.
14 9.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
15 ONLY” Information or Items. Unless otherwise ordered by the court
16 or permitted in writing by the Designating Party, a Receiving Party may disclose
17 any information or item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’
18 EYES ONLY” only to:
19 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
20 well as employees of said Outside Counsel of Record to whom it is reasonably
21 necessary to disclose the information for this Action;
22 (b) Experts (as defined in this Order) of the Receiving Party to whom
23 disclosure is reasonably necessary for this Action and who have signed the
24 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
25 (c) the court and its personnel;
26 (d) court reporters and their staff;
27 (e) professional jury or trial consultants, mock jurors, and Professional
28 Vendors to whom disclosure is reasonably necessary for this Action and who have
1 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
2 (f) the author or recipient of a document containing the information or
3 a custodian or other person who otherwise possessed or knew the information;
4 (g) during their depositions, witnesses, and attorneys for witnesses, in
5 the Action to whom disclosure is reasonably necessary provided: (1) the deposing
6 party requests that the witness sign the form attached as Exhibit A hereto; and (2)
7 they will not be permitted to keep any confidential information unless they sign the
8 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
9 agreed by the Designating Party or ordered by the court. Pages of transcribed
10 deposition testimony or exhibits to depositions that reveal Protected Material may
11 be separately bound by the court reporter and may not be disclosed to anyone
12 except as permitted under this Stipulated Protective Order; and
13 (i) any mediators or settlement officers and their supporting personnel,
14 mutually agreed upon by any of the parties engaged in settlement discussions.
15 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED
16 PRODUCED IN OTHER LITIGATION
17 If a Party is served with a subpoena or a court order issued in other litigation
18 that compels disclosure of any information or items designated in this Action as
19 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
20 ONLY,” that Party must:
21 (a) promptly notify in writing the Designating Party. Such notification
22 shall include a copy of the subpoena or court order;
23 (b) promptly notify in writing the party who caused the subpoena or
24 order to issue in the other litigation that some or all of the material covered by the
25 subpoena or order is subject to this Protective Order. Such notification shall include
26 a copy of this Stipulated Protective Order; and
27 (c) cooperate with respect to all reasonable procedures sought to be
28 pursued by the Designating Party whose Protected Material may be affected. If the
1 Designating Party timely seeks a protective order, the Party served with the
2 subpoena or court order shall not produce any information designated in this action
3 as “CONFIDENTIAL” OR “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
4 ONLY” before a determination by the court from which the subpoena or order
5 issued, unless the Party has obtained the Designating Party’s permission. The
6 Designating Party shall bear the burden and expense of seeking protection in that
7 court of its confidential material and nothing in these provisions should be
8 construed as authorizing or encouraging a Receiving Party in this Action to disobey
9 a lawful directive from another court.
10 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO
11 BE PRODUCED IN THIS LITIGATION
12 (a) The terms of this Order are applicable to information produced by a
13 Non-Party in this Action and designated as “CONFIDENTIAL” OR HIGHLY
14 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
15 Non-Parties in connection with this litigation is protected by the remedies and relief
16 provided by this Order. Nothing in these provisions should be construed as
17 prohibiting a Non-Party from seeking additional protections.
18 (b) In the event that a Party is required, by a valid discovery request, to
19 produce a Non-Party’s confidential information in its possession, and the Party is
20 subject to an agreement with the Non-Party not to produce the Non-Party’s
21 confidential information, then the Party shall:
22 (1) promptly notify in writing the Requesting Party and the Non-Party
23 that some or all of the information requested is subject to a confidentiality
24 agreement with a Non-Party;
25 (2) promptly provide the Non-Party with a copy of the Stipulated
26 Protective Order in this Action, the relevant discovery request(s), and a reasonably
27 specific description of the information requested; and
28 (3) make the information requested available for inspection by the
1 Non-Party, if requested.
2 (c) If the Non-Party fails to seek a protective order from this court
3 within 14 days of receiving the notice and accompanying information, the
4 Receiving Party may produce the Non-Party’s confidential information responsive
5 to the discovery request. If the Non-Party timely seeks a protective order, the
6 Receiving Party shall not produce any information in its possession or control that
7 is subject to the confidentiality agreement with the Non-Party before a
8 determination by the court. Absent a court order to the contrary, the Non-Party shall
9 bear the burden and expense of seeking protection in this court of its Protected
10 Material.
11 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
12 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
13 Protected Material to any person or in any circumstance not authorized under this
14 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
15 writing the Designating Party of the unauthorized disclosures, (b) use its best
16 efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
17 person or persons to whom unauthorized disclosures were made of all the terms of
18 this Order, and (d) request such person or persons to execute the “Acknowledgment
19 an Agreement to Be Bound” attached hereto as Exhibit A.
20 13. INADVERTENT PRODUCTION OF PRIVILEGED OR
21 OTHERWISE PROTECTED MATERIAL
22 When a Producing Party gives notice to Receiving Parties that certain
23 inadvertently produced material is subject to a claim of privilege or other
24 protection, the obligations of the Receiving Parties are those set forth in Federal
25 Rule of Civil\ Procedure 26(b)(5)(B). This provision is not intended to modify
26 whatever procedure may be established in an e-discovery order that provides for
27 production without prior privilege review. Pursuant to Federal Rule of Evidence
28 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
1 of a communication or information covered by the attorney-client privilege or work
2 product protection, the parties may incorporate their agreement in the stipulated
3 protective order submitted to the court.
4 14. MISCELLANEOUS
5 14.1 Right to Further Relief. Nothing in this Order abridges the right of any
6 person to seek its modification by the Court in the future.
7 14.2 Right to Assert Other Objections. By stipulating to the entry of this
8 Protective Order, no Party waives any right it otherwise would have to object to
9 disclosing or producing any information or item on any ground not addressed in
10 this Stipulated Protective Order. Similarly, no Party waives any right to object on
11 any ground to use in evidence of any of the material covered by this Protective
12 Order.
13 14.3 Filing Protected Material. A Party that seeks to file under seal any
14 Protected Material must comply with Local Civil Rule 79-5. Protected Material
15 may only be filed under seal pursuant to a court order authorizing the sealing of the
16 specific Protected Material. If a Party’s request to file Protected Material under seal
17 is denied by the court, then the Receiving Party may file the information in the
18 public record unless otherwise instructed by the court.
19 15. FINAL DISPOSITION
20 After the final disposition of this Action, as defined in paragraph 6, within 60
21 days of a written request by the Designating Party, each Receiving Party must
22 return all Protected Material to the Producing Party or destroy such material. As
23 used in this subdivision, “all Protected Material” includes all copies, abstracts,
24 compilations, summaries, and any other format reproducing or capturing any of the
25 Protected Material. Whether the Protected Material is returned or destroyed, the
26 Receiving Party must submit a written certification to the Producing Party (and, if
27 not the same person or entity, to the Designating Party) by the 60-day deadline that
28 (1) identifies (by category, where appropriate) all the Protected Material that was
I|| returned or destroyed and (2) affirms that the Receiving Party has not retained any
2|| copies, abstracts, compilations, summaries or any other format reproducing or
3|| capturing any of the Protected Material. Notwithstanding this provision, Counsel
4|| are entitled to retain an archival copy of all pleadings, motion papers, trial,
5|| deposition, and hearing transcripts, legal memoranda, correspondence, deposition
6|| and trial exhibits, expert reports, attorney work product, and consultant and expert
7|| work product, even if such materials contain Protected Material. Any such archival
8]| copies that contain or constitute Protected Material remain subject to this Protective
9|| Order as set forth in Section 6 (DURATION).
10 16. VIOLATION
11 Any violation of this Order may be punished by appropriate measures
including, without limitation, contempt proceedings and/or monetary sanctions.
13
14|| FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
15
16|| DATED: June 17, 2026 LL
18 J D. EARLY
19 nited States Magistrate Judge

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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 perjury
5 that I have read in its entirety and understand the Stipulated Protective Order that
6 was issued by the United States District Court for the Central District of California
7 in the case of Spoon Co., Ltd. v. Go Tuning Unlimited, LLC, Case No. 8:25-cv-
8 01451-FWS-JDE. I agree to comply with and to be bound by all the terms of this
9 Stipulated Protective Order and I understand and acknowledge that failure to so
10 comply could expose me to sanctions and punishment in the nature of contempt. I
11 solemnly promise that I will not disclose in any manner any information or item
12 that is subject to this Stipulated Protective Order to any person or entity except in
13 strict compliance with the provisions of this Order.
14 I further agree to submit to the jurisdiction of the United States District Court
15 for the Northern District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action.
18 I hereby appoint __________________________ [print or type full name] of
19 _______________________________________ [print or type 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 sworn and signed: _________________________________

25
Printed name: ______________________________
26 [printed name]
Signature: __________________________________
27
[signature]
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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11383629. Public record. Not legal advice.