355271.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
GOOGLE INc. , a Delaware corporation
Plaintiff
14 AMERICAN BLIND & WALLPAPER
FACTORY, INC. , a Delaware corporation
15 d/b/a decoratetoday.com, Inc. , and DOES I-
100, inclusive
Defendants.
AMERICAN BLIND & W ALLP APER
18 FACTORY, INc., a Delaware corporation
d/b/a decoratetoday.com, Inc.
Counter Plaintiff
GOOGLE INc. , AMERICA ONLINE, INC.
22 NETSCAPE COMMUNICATIONS
CORPORATION, COMPUSERVE
23 INTERACTIVE SERVICES , INC. , ASK
JEEVES , INC. and EARTH LINK, INC.
Counter Defendant/
Third-Partv Defendants.
Case No. C 03-5340-JF (EAI)
(PROPOSED) STIPULATED
PROTECTIVE ORDER
(PROPOSED) STIPULATED PROTECTIVE ORDER
CASE NO. C 03-5340-JF (EM)
*
*E-FILED 9/19/05*
Case 5:03-cv-05340-JF Document 60 Filed 09/19/2005 Page 1 of 14
Google Inc. v. American Blind & Wallpaper Factory, Inc.
Doc. 60
Dockets.Justia.com
355271.
The parties, by counsel, hereby stipulate to the entry of the following Protective Order
pursuant to Federal Rule of Civil Procedure 26(c) and Federal Rule of Evidence 501:
Designated Material
Designated Material" means any document or other information, including magnetic
media, electronic media and any material derived from such media, provided during discovery in
this action which is believed in good faith to contain or reflect confidential, proprietary or other
sensitive matter by the person or entity producing or filing it (the "Designating Party ). Such
material may be designated as either "CONFIDENTIAL" or, in limited circumstances, as
CONFIDENTIAL - ATTORNEYS' EYES ONLY" by the Designating Party in accordance
with the procedures set forth below. Such designations are intended to avoid invasions of
individual privacy and to protect proprietary information, confidential business or financial
information, and/or trade secrets relating to the Designating Party s business , personal , or
financial affairs.
Materials That May Be Marked "CONFIDENTIAL"
The following information may be designated as "CONFIDENTIAL" : information
docu