The opinion
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UNITED STATES DISTRICT COURT FOR THE
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CENTRAL DISTRICT OF CALIFORNIA
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9 SUPACOLOUR GROUP LIMITED Case No.: 8:25-cv-02748-FWS-KES
AND SUPACOLOR USA, INC;
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Plaintiffs and [PROPOSED] STIPULATED
11 Counter- PROTECTIVE ORDER
Defendants,
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vs.
13 [Discovery Document: Referred to
PARSONS MEDIA GROUP, LLC Magistrate Judge Karen E. Scott]
14 AND MATTHEW PARSONS;
15 Defendants and
Counter-Claimants.
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1 [PROPOSED] STIPULATED PROTECTIVE ORDER
2 1. GENERAL
3 1.1 Purposes and Limitations. Discovery in this action is likely to involve
4 production of confidential, proprietary, or private information for which special
5 protection from public disclosure and from use for any purpose other than
6 prosecuting this litigation may be warranted. Accordingly, the parties hereby
7 stipulate to and petition the Court to enter the following Stipulated Protective Order.
8 The parties acknowledge that this Order does not confer blanket protections on all
9 disclosures or responses to discovery and that the protection it affords from public
10 disclosure and use extends only to the limited information or items that are entitled
11 to confidential treatment under the applicable legal principles. The parties further
12 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective
13 Order does not entitle them to file confidential information under seal; Civil Local
14 Rule 79-5 sets forth the procedures that must be followed and the standards that will
15 be applied when a party seeks permission from the court to file material under seal.
16 1.2 Good Cause Statement.
17 This action is likely to involve trade secrets, customer, supplier, and pricing
18 information and other valuable research, development, commercial, financial,
19 technical and/or proprietary information for which special protection from public
20 disclosure and from use for any purpose other than prosecution of this action is
21 warranted. In particular, discovery is expected to include nonpublic financial
22 statements and internal financial reporting; budgets, forecasts, revenues, costs,
23 margins, and sales information; customer and supplier specific identities, terms, and
24 data; internal accounting records; confidential marketing and distribution plans; and
25 confidential strategic business information and prospective business opportunities.
26 Since the parties operate in overlapping markets, disclosure of this information to a
27 competitor could reveal financial condition, pricing, margins, costs, customer and
1 impair commercial negotiations and relationships, and cause competitive or other
2 commercial injury. Such confidential and proprietary materials and information
3 consist of, among other things, confidential business or financial information,
4 information regarding confidential business practices, or other confidential
5 research, development, or commercial information (including information
6 implicating privacy rights of third parties), information otherwise generally
7 unavailable to the public, or which may be privileged or otherwise protected from
8 disclosure under state or federal statutes, court rules, case decisions, or common
9 law. Accordingly, to expedite the flow of information, to facilitate the prompt
10 resolution of disputes over confidentiality of discovery materials, to adequately
11 protect information the parties are entitled to keep confidential, to ensure that the
12 parties are permitted reasonable necessary uses of such material in preparation for
13 and in the conduct of trial, to address their handling at the end of the litigation, and
14 serve the ends of justice, a protective order for such information is justified in this
15 matter. It is the intent of the parties that information will not be designated as
16 confidential for tactical reasons and that nothing be so designated without a good
17 faith belief that it has been maintained in a confidential, non-public manner, and
18 there is good cause why it should not be part of the public record of this case.
19 2. DEFINITIONS
20 2.1 Action: this pending federal lawsuit, Supacolour Group limited and
21 Supacolour USA, Inc. v. Parsons Media Group, LLC and Matthew Parsons, C.D.
22 Cal. Case No. 8:25-CV-02748-FWS-KES.
23 2.2 Challenging Party: a Party or Non-Party that challenges the
24 designation of information or items under this Order.
25 2.3 “CONFIDENTIAL” Information or Items: information (regardless of
26 how it is generated, stored or maintained) or tangible things that qualify for
27 protection under Federal Rule of Civil Procedure 26(c), and as specified above in
1 2.4 Counsel: Outside Counsel of Record and House Counsel (as well as
2 their support staff).
3 2.5 Designating Party: a Party or Non-Party that designates information
4 or items that it produces in disclosures or in responses to discovery as
5 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
6 ONLY.”
7 2.6 Disclosure or Discovery Material: all items or information, regardless
8 of the medium or manner in which it is generated, stored, or maintained (including,
9 among other things, testimony, transcripts, and tangible things), that are produced
10 or generated in disclosures or responses to discovery in this matter.
11 2.7 Expert: a person with specialized knowledge or experience in a matter
12 pertinent to the litigation who has been retained by a Party or its counsel to serve as
13 an expert witness or as a consultant in this Action.
14 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
15 Information or Items: information (regardless of how it is generated, stored or
16 maintained) or tangible things that qualify for protection under Federal Rule of Civil
17 Procedure 26(c) and are so commercially sensitive that disclosure to a Party or its
18 officers, directors, employees, or House Counsel would create a substantial risk of
19 serious competitive, financial, or commercial injury that cannot reasonably be
20 avoided by less restrictive means. This tier is limited to particularly sensitive
21 information, including nonpublic detailed financial statements or internal financial
22 reports; budgets, forecasts, margins, pricing, costs, or sales information at a level
23 not publicly disclosed; customer or supplier specific identities, terms, or data; and
24 confidential strategic plans or prospective business opportunities. The designation
25 may not be used merely because information is commercially sensitive,
26 embarrassing, or inconvenient to disclose.
27 2.9 House Counsel: attorneys who are employees of a party to this Action.
1 counsel.
2 2.10 Non-Party: any natural person, partnership, corporation, association,
3 or other legal entity not named as a Party to this action.
4 2.11 Outside Counsel of Record: attorneys who are not employees of a
5 party to this Action but are retained to represent or advise a party to this Action and
6 have appeared in this Action on behalf of that party or are affiliated with a law firm
7 that has appeared on behalf of that party, including support staff.
8 2.12 Party: any party to this Action, including all of its officers, directors,
9 employees, consultants, retained experts, and Outside Counsel of Record (and their
10 support staffs).
11 2.13 Producing Party: a Party or Non-Party that produces Disclosure or
12 Discovery Material in this Action.
13 2.14 Professional Vendors: persons or entities that provide litigation
14 support services (e.g., photocopying, videotaping, translating, preparing exhibits or
15 demonstrations, and organizing, storing, or retrieving data in any form or medium)
16 and their employees and subcontractors.
17 2.15 Protected Material: any Disclosure or Discovery Material that is
18 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
19 ATTORNEYS’ EYES ONLY.”
20 2.16 Receiving Party: a Party that receives Disclosure or Discovery
21 Material from a Producing Party.
22 3. SCOPE
23 The protections conferred by this Stipulation and Order cover not only
24 Protected Material (as defined above), but also (1) any information copied or
25 extracted from Protected Material; (2) all copies, excerpts, summaries, or
26 compilations of Protected Material; and (3) any testimony, conversations, or
27 presentations by Parties or their Counsel that might reveal Protected Material.
1 in the public domain when disclosed to a Receiving Party or that later enters the
2 public domain through publication that does not violate this Order; or (b)
3 information known to the Receiving Party before disclosure or later obtained from
4 a source that acquired the information lawfully and without an obligation of
5 confidentiality to the Designating Party.
6 Any use of Protected Material at trial shall be governed by the orders of the
7 trial judge. This Order does not govern the use of Protected Material at trial.
8 4. DURATION
9 Once a case proceeds to trial, all of the court-filed information to be
10 introduced that was previously designated as confidential or maintained pursuant to
11 this protective order becomes public and will be presumptively available to all
12 members of the public, including the press, unless compelling reasons supported by
13 specific factual findings to proceed otherwise are made to the trial judge in advance
14 of the trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81
15 (9th Cir. 2006) (distinguishing “good cause” showing for sealing documents
16 produced in discovery from “compelling reasons” standard when merits-related
17 documents are part of court record). Accordingly, the terms of this protective order
18 do not extend beyond the commencement of the trial.
19 5. DESIGNATING PROTECTED MATERIAL
20 5.1 Exercise of Restraint and Care in Designating Material for Protection.
21 Each Party or Non-Party that designates information or items for protection under
22 this Order must take care to limit any such designation to specific material that
23 qualifies under the appropriate standards. The Designating Party must designate for
24 protection only those parts of material, documents, items, or oral or written
25 communications that qualify so that other portions of the material, documents,
26 items, or communications for which protection is not warranted are not swept
27 unjustifiably within the ambit of this Order.
1 that are shown to be clearly unjustified or that have been made for an improper
2 purpose (e.g., to unnecessarily encumber the case development process or to impose
3 unnecessary expenses and burdens on other parties) may expose the Designating
4 Party to sanctions.
5 If it comes to a Designating Party’s attention that information or items that it
6 designated for protection do not qualify for protection, that Designating Party must
7 promptly notify all other Parties that it is withdrawing the inapplicable designation.
8 5.2 Manner and Timing of Designations. Except as otherwise provided in
9 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
10 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
11 under this Order must be clearly so designated before the material is disclosed or
12 produced.
13 Designation in conformity with this Order requires:
14 (a) for information in documentary form (e.g., paper or electronic
15 documents, but excluding transcripts of depositions or other pretrial or trial
16 proceedings), that the Producing Party affix, at a minimum, the legend
17 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
18 ONLY” (hereinafter “CONFIDENTIAL legend” and “AEO legend,” respectively),
19 to each page that contains protected material. If only a portion or portions of the
20 material on a page qualifies for protection, the Producing Party also must clearly
21 identify the protected portion(s) (e.g., by making appropriate markings in the
22 margins).
23 A Party or Non-Party that makes original documents available for inspection
24 need not designate them for protection until after the inspecting Party has indicated
25 which documents it would like copied and produced. During the inspection and
26 before the designation, all of the material made available for inspection shall be
27 deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After the
1 Producing Party must determine which documents, or portions thereof, qualify for
2 protection under this Order. Then, before producing the specified documents, the
3 Producing Party must affix the CONFIDENTIAL or AEO legend to each page that
4 contains Protected Material. If only a portion or portions of the material on a page
5 qualifies for protection, the Producing Party also must clearly identify the protected
6 portion(s) (e.g., by making appropriate markings in the margins).
7 (b) for testimony given in depositions, the Designating Party may identify
8 the Disclosure or Discovery Material on the record, before the close of the
9 deposition. In addition, the entire certified deposition transcript shall be treated as
10 “CONFIDENTIAL” for thirty (30) days after the certified transcript is first made
11 available by the court reporter to the Parties. Deposition exhibits shall retain any
12 designation previously assigned to them and, if previously undesignated, shall be
13 treated as “CONFIDENTIAL” during the same period. During that period, any
14 Party may designate specific page and line portions of the transcript and specific
15 deposition exhibits as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
16 ATTORNEYS’ EYES ONLY” by written notice to all Parties. After that period,
17 only testimony and exhibits designated on the record or by timely written notice
18 shall remain Protected Material. The Designating Party shall identify the protected
19 page and line portions and exhibits with reasonable specificity and blanket
20 designations are prohibited unless the entire transcript or exhibit qualifies for the
21 stated level of protection.
22 (c) for information produced in some form other than documentary and
23 for any other tangible items, that the Producing Party affix in a prominent place on
24 the exterior of the container or containers in which the information is stored the
25 legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
26 EYES ONLY.” If only a portion or portions of the information warrants protection,
27 the Producing Party, to the extent practicable, shall identify the protected portion(s).
1 failure to designate qualified information or items does not, standing alone, waive
2 the Designating Party’s right to secure protection under this Order for such material.
3 Upon timely correction of a designation, the Receiving Party must make reasonable
4 efforts to assure that the material is treated in accordance with the provisions of this
5 Order.
6 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
7 6.1 Timing of Challenges. Any Party or Non-Party may challenge a
8 designation of confidentiality at any time that is consistent with the Court’s
9 Scheduling Order.
10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute
11 resolution process under Local Rule 37-1, et seq. Any discovery motion must
12 strictly comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
13 6.3 Burden. The burden of persuasion in any such challenge proceeding
14 shall be on the Designating Party. Frivolous challenges, and those made for an
15 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
16 other parties) may expose the Challenging Party to sanctions. Unless the
17 Designating Party has waived or withdrawn the confidentiality designation, all
18 parties shall continue to afford the material in question the level of protection to
19 which it is entitled under the Producing Party’s designation until the Court rules on
20 the challenge.
21 7. ACCESS TO AND USE OF PROTECTED MATERIAL
22 7.1 Basic Principles. A Receiving Party may use Protected Material that
23 is disclosed or produced by another Party or by a Non-Party in connection with this
24 Action only for prosecuting, defending, or attempting to settle this Action. Such
25 Protected Material may be disclosed only to the categories of persons and under the
26 conditions described in this Order. When the Action has been terminated, a
27 Receiving Party must comply with the provisions of section 13 below (FINAL
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
9 well as employees of said Outside Counsel of Record to whom it is reasonably
10 necessary to disclose the information for this Action;
11 (b) the officers, directors, and employees (including House Counsel) of
12 the 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
26 will not be permitted to keep any confidential information unless they sign the
27 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
1 deposition testimony or exhibits to depositions that reveal Protected Material may
2 be separately bound by the court reporter and may not be disclosed to anyone except
3 as permitted under this Stipulated Protective Order; and
4 (i) any mediator or settlement officer, and their supporting personnel,
5 mutually agreed upon by any of the parties engaged in settlement discussions.
6 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
7 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted
8 in writing by the Designating Party, a Receiving Party may disclose information or
9 items designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
10 only to:
11 (a) the Receiving Party’s Outside Counsel of Record in this Action, as
12 well as employees of said Outside Counsel of Record to whom disclosure is
13 reasonably necessary for this Action;
14 (b) Experts (as defined in this Order) of the Receiving Party to whom
15 disclosure is reasonably necessary for this Action and who have signed the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17 (c) the Court and its personnel;
18 (d) court reporters, videographers, and their staff;
19 (e) professional jury or trial consultants, mock jurors, and Professional
20 Vendors to whom disclosure is reasonably necessary for this Action and who have
21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22 (f) the author or recipient of a document containing the information or a
23 custodian or other person who otherwise possessed or knew the information;
24 (g) witnesses and attorneys for witnesses, during preparation for or
25 testimony at a deposition, if disclosure is reasonably necessary and Outside Counsel
26 of Record has a good faith basis to believe that the witness authored, received,
27 reviewed, possessed, knew, or had authorized access to the information, or
1 material and the information is reasonably necessary to examine the witness
2 concerning that participation, provided that: (1) the disclosing party requests that
3 the witness sign Exhibit A; and, (2) the witness may not retain any copy of such
4 material unless the Designating Party agrees otherwise in writing or on the record,
5 or the Court orders otherwise;
6 (h) any mediator or settlement officer, and their supporting personnel,
7 mutually agreed upon by the parties engaged in settlement discussions; and
8 (i) any other person specifically authorized by the Designating Party in
9 writing or by order of the Court, provided that the person has signed the
10 “Acknowledgment and Agreement to Be Bound” (Exhibit A).
11 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED
12 PRODUCED IN OTHER LITIGATION
13 If a Party is served with a subpoena or a court order issued in other litigation
14 that compels disclosure of any information or items designated in this Action as
15 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
16 ONLY,” that Party must:
17 (a) promptly notify in writing the Designating Party. Such notification
18 shall include a copy of the subpoena or court order;
19 (b) promptly notify in writing the party who caused the subpoena or order
20 to issue in the other litigation that some or all of the material covered by the
21 subpoena or order is subject to this Protective Order. Such notification shall include
22 a copy of this Stipulated Protective Order; and
23 (c) cooperate with respect to all reasonable procedures sought to be
24 pursued by the Designating Party whose Protected Material may be affected.
25 If the Designating Party timely seeks a protective order, the Party served with
26 the subpoena or court order shall not produce any information designated in this
27 action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
1 order issued, unless the Party has obtained the Designating Party’s permission. The
2 Designating Party shall bear the burden and expense of seeking protection in that
3 court of its confidential material and nothing in these provisions should be construed
4 as authorizing or encouraging a Receiving Party in this Action to disobey a lawful
5 directive from another court.
6 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
7 PRODUCED IN THIS LITIGATION
8 (a) The terms of this Order are applicable to information produced by a
9 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
10 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
11 Non-Parties in connection with this litigation is protected by the remedies and relief
12 provided by this Order. Nothing in these provisions should be construed as
13 prohibiting a Non-Party from seeking additional protections.
14 (b) In the event that a Party is required, by a valid discovery request, to
15 produce a Non-Party’s confidential information in its possession, and the Party is
16 subject to an agreement with the Non-Party not to produce the Non-Party’s
17 confidential information, then the Party shall:
18 (1) promptly notify in writing the Requesting Party and the Non-Party that
19 some or all of the information requested is subject to a confidentiality agreement
20 with a Non-Party;
21 (2) promptly provide the Non-Party with a copy of the Stipulated
22 Protective Order in this Action, the relevant discovery request(s), and a reasonably
23 specific description of the information requested; and
24 (3) make the information requested available for inspection by the Non-
25 Party, if requested.
26 (c) If the Non-Party fails to seek a protective order from this Court within
27 14 days of receiving the notice and accompanying information, the Receiving Party
1 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
2 not produce any information in its possession or control that is subject to the
3 confidentiality agreement with the Non-Party before a determination by the Court.
4 Absent a court order to the contrary, the Non-Party shall bear the burden and
5 expense of seeking protection in this Court of its Protected Material.
6 10. UNAUTHORIZED DISCLOSURE OF PROTECTED
7 MATERIAL
8 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
9 Protected Material to any person or in any circumstance not authorized under this
10 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
11 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
12 to retrieve all unauthorized copies of the Protected Material, (c) inform the person
13 or persons to whom unauthorized disclosures were made of all the terms of this
14 Order, and (d) request such person or persons to execute the “Acknowledgment and
15 Agreement to Be Bound” that is attached hereto as Exhibit A.
16 11. INADVERTENT PRODUCTION OF PRIVILEGED OR
17 OTHERWISE PROTECTED MATERIAL
18 When a Producing Party gives notice to Receiving Parties that certain
19 inadvertently produced material is subject to a claim of privilege or other protection,
20 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
21 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
22 may be established in an e-discovery order that provides for production without
23 prior privilege review. Pursuant to Federal Rule of Evidence 502(d), the production
24 of a document or information protected by the attorney-client privilege, attorney
25 work product doctrine, or any other applicable privilege or protection shall not
26 constitute a waiver of the privilege or protection in this Action or in any other
27 federal or state proceeding, whether the production was inadvertent or otherwise. A
1 sequestration, or destruction in accordance with Federal Rule of Civil Procedure
2 26(b)(5)(B).
3 12. MISCELLANEOUS
4 12.1 Right to Further Relief. Nothing in this Order abridges the right of any
5 person to seek its modification by the Court in the future.
6 12.2 Right to Assert Other Objections. By stipulating to the entry of this
7 Protective Order, no Party waives any right it otherwise would have to object to
8 disclosing or producing any information or item on any ground not addressed in this
9 Stipulated Protective Order. Similarly, no Party waives any right to object on any
10 ground to use in evidence of any of the material covered by this Protective Order.
11 12.3 Filing Protected Material. A Party that seeks to file under seal any
12 Protected Material must comply with Civil Local Rule 79-5 and any applicable
13 order of the District Judge. Nothing in this Order requires a Party to challenge or
14 obtain withdrawal of a confidentiality designation before using Protected Material
15 in a court filing. An application to file under seal may be submitted
16 contemporaneously with the motion or other filing that the Protected Material is
17 intended to support. Protected Material may only be filed under seal pursuant to a
18 court order authorizing the sealing of the specific Protected Material at issue; good
19 cause or compelling reasons, as applicable, must be shown in the request to file
20 under seal. If a Party’s request to file Protected Material under seal is denied by the
21 Court, then the Receiving Party may file the information in the public record unless
22 otherwise instructed by the Court.
23 13. FINAL DISPOSITION
24 After the final disposition of this Action, within 60 days of a written request
25 by the Designating Party, each Receiving Party must return all Protected Material
26 to the Producing Party or destroy such material. As used in this subdivision, “all
27 Protected Material” includes all copies, abstracts, compilations, summaries, and any
1 Protected Material is returned or destroyed, the Receiving Party must submit a
2 written certification to the Producing Party (and, if not the same person or entity, to
3 the Designating Party) by the 60 day deadline that (1) identifies (by category, where
4 appropriate) all the Protected Material that was returned or destroyed, and (2)
5 affirms that the Receiving Party has not retained any copies, abstracts, compilations,
6 summaries or any other format reproducing or capturing any of the Protected
7 Material. Notwithstanding this provision, counsel are entitled to retain an archival
8 copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal
9 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney
10 work product, and consultant and expert work product, even if such materials
11 contain Protected Material. Any such archival copies that contain or constitute
12 Protected Material remain subject to this Protective Order as set forth in Section 4
13 (DURATION).
14 14. VIOLATION OF ORDER
15 Any violation of this Order may be punished by any and all appropriate
16 measures including, without limitation, contempt proceedings and/or monetary
17 sanctions.
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1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
3 || Dated: September 3, 2026 MARTORELL LAW APC
5 By: _/s/ Evan Miller
6 Eduardo Martorell
Evan Miller
8 BRAND COUNSEL, P.C.
10 By: _/s/ Manoj N. Shah
11 Manoj N. Shah
12 Attorneys for Plaintiffs and
13 Counter-Defendants
SUPACOLOUR GROUP LIMITED
14 AND SUPACOLOR USA, INC.
15
16 || Dated: September 3, 2026 RUFUS-ISAACS ACLAND &
7 GRANTHAM LLP
18
19 By: _/s/ Alexander Rufus-Isaacs
Alexander Rufus-Isaacs
20 Paul D. Supnik
21
Attorneys for Defendants and
22 Counterclaimants
73 PARSONS MEDIA GROUP, LLC,
AND MATTHEW PARSONS
24
2 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
26
27 DATED: September 3, 2026 "Veen. 6. Scot 2
28 THE HON. KAREN E. SCOTT
1 EXHIBIT A
2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
3 I, _____________________________ [full name], of _________________
4 [full address], declare under penalty of perjury that I have read in its entirety and
5 understand the Stipulated Protective Order that was issued by the United States
6 District Court for the Central District of California on ____________ [date] in the
7 case of Supacolour Group Limited and Supacolor USA, Inc., v. Parsons Media
8 Group, LLC, and Matthew Parsons, C.D. Cal. Case No. 8:25-CV-02748-FWS-
9 KES. 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
12 promise that I will not disclose in any manner any information or item that is subject
13 to this Stipulated Protective Order to any person or entity except in strict compliance
14 with 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 __________________________ [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: _________________________________
25 Printed name: _______________________________
26 Signature: __________________________________
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1 LOCAL RULE 5-4.3.4(a)(2)(i) CERTIFICATION
2 The filer of this document attests that all other signatories listed above on
3 whose behalf this filing is submitted concur in the filing’s content and have
4 authorized the filing.
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