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Zen Design Group Ltd. v. Scholastic Inc.

United States District Court, E.D. Michigan

November 17, 2016

ZEN DESIGN GROUP LIMITED a Michigan corporation, Plaintiff,
v.
SCHOLASTIC, INC. a New York corporation Defendant.

          BROOKS KUSHMAN P.C. Thomas W. Cunningham Mark A. Cantor Attorneys for Plaintiff.

          DUANE MORRIS LLP John R. Gibson with Consent Attorneys for Defendant.

          Elizabeth A. Stafford Magistrate Judge.

          JOINT PROPOSED PROTECTIVE ORDER

          Honorable Robert H. Cleland United States District Court Judge.

         Pursuant to Federal Rule of Civil Procedure 26(c), the Court hereby enters the following protective order:

         1. Confidential Information - Any document or thing that a party reasonably and in good faith believes to contain confidential information that is not publicly available (such as research and development, commercial, or other sensitive information) may be produced by that party with the clear and obvious designation “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.”

         2. Non-Disclosure of Confidential Information - Any document or thing designated as “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” may only be used to prosecute or defend this action and shall not be disclosed to (or the content discussed with) anyone other than the following persons:

a. The named parties in this case, their attorneys, and their support staff (e.g., copying and document management personnel).
b. Independent experts or consultants engaged by a party's attorneys to assist in the preparation and trial of this case who agree to abide by the terms of this Protective Order by signing Exhibit A and who are approved by the producing party pursuant to paragraph 5 below.
c. Deposition witnesses whose testimony is being taken with respect to the document or thing, or about the subject matter of the document or thing, who agree to abide by the terms of this Protective Order.
d. This Court and its staff members.

         3. Highly Confidential Information - Attorney's Eyes Only - Any document or thing that a party in good faith believes to contain highly confidential information that is not publicly available (such as a trade secret, or highly confidential research and development, commercial, or other sensitive information) may be produced by that party with the clear and obvious designation “HIGHLY CONFIDENTIAL - ATTORNEY'S EYES ONLY.”

         4. Non-Disclosure of Highly Confidential Information - Any document or thing designated “HIGHLY CONFIDENTIAL - ATTORNEY'S EYES ONLY” may only be used to prosecute or defend this action and shall not be disclosed to (nor the content discussed with) anyone other than the following persons:

a. Outside attorneys of record in this lawsuit and their support staff (e.g., copying and document management personnel) who are not involved in patent prosecution for the ...

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