Meta Platforms, Inc. v. Judang Team LLC et al

[PROPOSED] STIPULATED PROTECTIVE ORDER
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North
ern
Distri
	ct of
	Calif
	ornia
[counsel on signature page]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
META PLATFORMS, INC., a Delaware
Corporation
Plaintiff,
v.
JUDANG TEAM LLC, a Florida
Limited Liability Company,
PERFEOS LLC d/b/a SHOP AT MARS,
a Florida Limited Liability Company,
JOT & JOURNEYS aka JOT &
JOURNEY, an unincorporated Florida
business, and
ANTONIO JOSÉ LIÉVANO, in his
individual capacity and d/b/a “Judang
Team,” “Jot & Journeys,” and “Shop at
Mars,”
Defendants.
Case No. 3:25-cv-05156-TSH
[PROPOSED] STIPULATED
PROTECTIVE ORDER
1. 	PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are 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 responses to discovery and that the protection it affords from public disclosure and use extends
only to the limited information or items that are entitled to confidential treatment under the
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applicable legal principles. The parties further acknowledge, as set forth in Section 14.4, below, that
this Stipulated Protective Order does not entitle them to file confidential information under seal;
Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be
applied when a party seeks permission from the court to file material under seal.
2. 	DEFINITIONS
2.1 	Challenging Party: a Party or Non-Party that challenges the designation of
information or items under this Order.
2.2 	“CONFIDENTIAL” Information or Items: information (regardless of how it is
generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of
Civil Procedure 26(c).
2.3 	Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well
as their support staff).
2.4 	Designated House Counsel: House Counsel who seek access to “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information in this matter.
2.5 	Designating Party: a Party or Non-Party that designates information or items that it
produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	.
2.6 	Disclosure or Discovery Material: all items or information, regardless of the medium
or manner in which it is generated, stored, or maintained (including, among other things, testimony,
transcripts, and tangible things), that are produced or generated in disclosures or responses to
discovery in this matter.
2.7 	Expert: a person with specialized knowledge or experience in a matter pertinent to the
litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a
consultant in this action, (2) is not a past or current employee of a Party or of a Party’s competitor,
and (3) at the time of retention, is not anticipated to become an employee of a Party or of a Party’s
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competitor.
2.8 	“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or Items:
extremely sensitive “Confidential Information or Items,” disclosure of which to another Party or
Non-Party would create a substantial risk of serious harm that could not be avoided by less
restrictive means.
2.9 	[ INTENTIONALLY LEFT BLANK ]
2.10 	House Counsel: attorneys who are employees of a party to this action. House Counsel
does not include Outside Counsel of Record or any other outside counsel.
2.11 	Non-Party: any natural person, partnership, corporation, association, or other legal
entity not named as a Party to this action.
2.12 	Outside Counsel of Record: attorneys who are not employees of a Party to this action
but are retained to represent or advise a Party to this action and have appeared in this action on
behalf of that Party or are affiliated with a law firm which has appeared on behalf of that Party.
2.13 	Party: any party to this action, including all of its officers, directors, employees,
consultants, contractors, retained experts, and Outside Counsel of Record (and their support staff
).
2.14 	Producing Party: a Party or Non-Party that produces Disclosure or Discovery
Material in this action.
2.15 	Professional Vendors: persons or entities that provide litigation support services (e.g.,
photocopying, scanning, videotaping, translating, preparing exhibits or demonstrations, and
organizing, storing, searching, or retrieving data in any form or medium) and their employees and
subcontractors.
2.16 	Protected Material: any Disclosure or Discovery Material that is designated as
“CONFIDENTIAL” or as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
2.17 	Receiving Party: a Party that receives Disclosure or Discovery Material from a
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Producing Party.
3. 	SCOPE
The protections conferred by this Stipulation and Order cover not only Protected Material (as
defined above), but also (1) any information copied or extracted from Protected Material; (2) all
copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony,
conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
However, the protections conferred by this Stipulation and Order do not cover the following
information: (a) any information that is in the public domain at the time of disclosure to a Receiving
Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of
publication not involving a violation of this Order, another Court’s Order, unlawful conduct, or a
breach of a confidentiality obligation to the Designating Party, including becoming part of the public
record through trial or otherwise; and (b) any information known to the Receiving Party prior to the
disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the
information lawfully and under no obligation of confidentiality to the Designating Party. Any use of
Protected Material at trial shall be governed by a separate agreement or order.
4. 	DURATION
Even after final disposition of this litigation, the confidentiality obligations imposed by this
Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order
otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and
defenses in this action, with or without prejudice; and (2) final judgment herein after the completion
and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the
time limits for filing any motions or applications for extension of time pursuant to applicable law.
5. 	DESIGNATING PROTECTED MATERIAL
5.1 	Exercise of Restraint and Care in Designating Material for Protection. Each Party or
Non-Party that designates information or items for protection under this Order must take care to
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limit any such designation to specific material that qualifies under the appropriate standards. To the
extent it is practical to do so, the Designating Party must designate for protection only those parts of
material, documents, items, or oral or written communications that qualify – so that other portions of
the material, documents, items, or communications for which protection is not warranted are not
swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown
to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily
encumber or retard the case development process or to impose unnecessary expenses and burdens on
other parties) expose the Designating Party to sanctions.
If it comes to a Designating Party’s attention that information or items that it designated for
protection do not qualify for protection at all or do not qualify for the level of protection initially
asserted, that Designating Party must promptly notify all other parties that it is withdrawing the
mistaken designation.
5.2 	Manner and Timing of Designations. Except as otherwise provided in this Order (see,
e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
Discovery Material that qualifies for protection under this Order must be clearly so designated
before the material is disclosed or produced.
Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic documents, but
excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party
affix the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
ONLY” 	to each page that contains protected material. If only a portion or portions of the material
on a page qualifies for protection, to the extent it is practical, the Producing Party also must clearly
identify the protected portion(s) (e.g., by making appropriate markings in the margins) and must
specify, for each portion, the level of protection being asserted.
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For Protected Material that is produced in native electronic format, the designated legend
must be included in the file name and on any slipsheets when produced.
A Party or Non-Party that makes original documents or materials available for inspection
need not designate them for protection until after the inspecting Party has indicated which material it
would like copied and produced. During the inspection and before the designation, all of the material
made available for inspection shall be deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’
EYES ONLY.” After the inspecting Party has identified the documents it wants copied and
produced, the Producing Party must determine which documents, or portions thereof, qualify for
protection under this Order. Then, before producing the specified documents, the Producing Party
must affix the appropriate legend (“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY” 	) to each page that contains Protected Material. If only a portion or
portions of the material on a page qualifies for protection, the Producing Party also must clearly
identify the protected portion(s) (e.g., by making appropriate markings in the margins) and must
specify, for each portion, the level of protection being asserted.
(b) for testimony given in deposition or in other pretrial or trial proceedings, that the
Designating Party identify on the record, before the close of the deposition, hearing, or other
proceeding, all protected testimony and specify the level of protection being asserted. When it is
impractical to identify separately each portion of testimony that is entitled to protection and it
appears that substantial portions of the testimony may qualify for protection, the Designating Party
has up to 21 days to identify the specific portions of the testimony as to which protection is sought
and to specify the level of protection being asserted. Only those portions of the testimony that are
appropriately designated for protection within the 21 days shall be covered by the provisions of this
Stipulated Protective Order. Alternatively, a Designating Party may specify, at the deposition or up
to 21 days afterwards 	, that the entire transcript shall be treated as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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Parties shall give the other parties notice if they reasonably expect a deposition, hearing, or
other proceeding to include Protected Material so that the other parties can ensure that only
authorized individuals who have signed the “Acknowledgment and Agreement to Be Bound”
(Exhibit A) are present at those proceedings. The use of a document as an exhibit at a deposition
shall not in any way affect its designation as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL
– ATTORNEYS’ EYES ONLY.”
Transcripts containing Protected Material shall have an obvious legend on the title page
that the transcript contains Protected Material, and the title page shall be followed by a list of all
pages (including line numbers as appropriate) that have been designated as Protected Material and
the level of protection being asserted by the Designating Party. The Designating Party shall inform
the court reporter of these requirements. Any transcript that is prepared before the expiration of a
21-day period for designation shall be treated during that period as if it had been designated
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” in its entirety unless otherwise
agreed. After the expiration of that period, the transcript shall be treated only as actually
designated.
(c) for information produced in some form other than documentary and for any other
tangible items, that the Producing Party affix in a prominent place on the exterior of the container
or containers in which the information or item is stored the legend “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	. If only a portion or portions of
the information or item warrant protection, the Producing Party, to the extent practicable, shall
identify the protected portion(s) and specify the level of protection being asserted.
5.3 	Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate
qualified information or items does not, standing alone, waive the Designating Party’s right to secure
protection under this Order for such material. Upon timely correction of a designation, the Receiving
Party must make reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Order.
6. 	CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1 	Timing of Challenges. Any Party or Non-Party may challenge a designation of
confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality
designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens,
or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a
confidentiality designation by electing not to mount a challenge promptly after the original
designation is disclosed.
6.2 	Meet and Confer. The Challenging Party shall initiate the dispute resolution process
by providing written notice of each designation it is challenging and describing the basis for each
challenge. To avoid ambiguity as to whether a challenge has been made, the written notice must
recite that the challenge to confidentiality is being made in accordance with this specific paragraph
of the Protective Order. The parties shall attempt to resolve each challenge in good faith and must
begin the process by conferring directly (in voice to voice dialogue; other forms of communication
are not sufficient) within 14 days of the date of service of notice. In conferring, the Challenging
Party must explain the basis for its belief that the confidentiality designation was not proper and
must give the Designating Party an opportunity to review the designated material, to reconsider the
circumstances, and, if no change in designation is offered, to explain the basis for the chosen
designation. A Challenging Party may proceed to the next stage of the challenge process only if it
has engaged in this meet and confer process first or establishes that the Designating Party is
unwilling to participate in the meet and confer process in a timely manner.
6.3 	Judicial Intervention. If the Parties cannot resolve a challenge without court
intervention, the Designating Party shall 	follow the dispute procedures outlined in the Discovery
Standing Order for Magistrate Judge Thomas S. Hixson, within 21 days of the initial notice of
challenge or within 14 days of the parties agreeing that the meet and confer process will not resolve
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their dispute, whichever is earlier. 	Each such motion must be accompanied by a competent
declaration affirming that the movant has complied with the meet and confer requirements imposed
in the preceding paragraph. Failure by the Designating Party to 	follow such procedures, including
the required declaration within 21 days (or 14 days, if applicable), shall automatically waive the
confidentiality designation for each challenged designation. In addition, the Challenging Party may
follow the dispute procedures outlined in the Discovery Standing Order for Magistrate Judge
Thomas S. Hixson to challenge a confidentiality designation at any time if there is good cause for
doing so, including a challenge to the designation of a deposition transcript or any portions thereof.
Any motion brought pursuant to this provision must be accompanied by a competent declaration
affirming that the movant has complied with the meet and confer requirements imposed by the
preceding paragraph.
The burden of persuasion in any such challenge proceeding shall be on the Designating
Party. Frivolous challenges and those made for an improper purpose (e.g., to harass or impose
unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions.
Unless the Designating Party has waived the confidentiality designation by failing to file a motion to
retain confidentiality as described above, all parties shall continue to afford the material in question
the level of protection to which it is entitled under the Producing Party’s designation until the court
rules on the challenge.
7. 	ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 	Basic Principles. A Receiving Party may use Protected Material that is disclosed or
produced by another Party or by a Non-Party in connection with this case only for prosecuting,
defending, or attempting to settle this litigation. Such Protected Material may be disclosed only to
the categories of persons and under the conditions described in this Order. When the litigation has
been terminated, a Receiving Party must comply with the provisions of section 15 below (FINAL
DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a location and in a
secure manner 	that ensures that access is limited to the persons authorized under this Order. The
Receiving Party shall not load, import, submit, or otherwise transfer Protected Material produced by
the Producing Party to an open Large Language Model (“LLM”) (e.g., some free versions of AI
tools that would train on Protected Material) or other open Generative Artificial Intelligence (“AI”)
platform, nor may the Receiving Party utilize any closed LLM or AI platforms where the Producing
Party’s Protected Material may be used to train open models or otherwise made accessible to other
users of the LLM or AI platform not authorized to receive Protected Material under this Order.
Before the Receiving Party transfers any of the Producing party’s Protected Material to a closed
LLM or AI platform (e.g., enterprise version of an AI tool that does not train on Protected Material),
the Receiving Party shall make reasonably sure that it can delete all such Protected Material from the
platform at the final disposition of this action, as defined in paragraph 4. The Receiving Party will
be responsible for destroying such produced information from such tools at the end of the Matter.
7.2 	Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by
the court or permitted in writing by the Designating Party, a Receiving Party may disclose any
information or item designated “CONFIDENTIAL” only to:
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees
of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for
this litigation 	;
(b) the officers, directors, and employees (including House Counsel) of the Receiving
Party to whom disclosure is reasonably necessary for this litigation and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is
reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement
to Be Bound” (Exhibit A);
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(d) the court and its personnel;
(e) court reporters and their staff, professional jury or trial consultants,1 and Professional
Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A);
(f) during their depositions, witnesses in the action to whom disclosure is reasonably
necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A),
unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed
deposition testimony or exhibits to depositions that reveal Protected Material must be separately
bound by the court reporter and may not be disclosed to anyone except as permitted under this
Stipulated Protective Order;
(g) the author or recipient of a document containing the information or a custodian or
other person who otherwise possessed or knew the information 	; and
(h) any mediator who is assigned to this matter, and his or her staff, who have signed
the “Acknowledgement and Agreement to Be Bound” (Exhibit A).
7.3 	Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
Information or Items. Unless otherwise ordered by the court or permitted in writing by the
Designating Party, a Receiving Party may disclose any information or item designated “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	only to:
(a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees
of said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for
this litigation 	;
(b) Optional as deemed appropriate in case-specific circumstances: Designated House
1 Disclosure to mock jurors is acceptable with the signing of a confidentiality agreement with
provisions on dissemination and disclosure at least as strict as those included in this Protective
Order, and who have been hired by a trial consulting firm who has signed “Acknowledgment and
Agreement to Be Bound” (Exhibit A).
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Counsel of the Receiving Party2 (1) who has no involvement in competitive decision-making, (2) to
whom disclosure is reasonably necessary for this litigation, (3) who has signed the
“Acknowledgment and Agreement to Be Bound” (Exhibit A), and (4) as to whom the procedures set
forth in paragraph 7.4(a)(1), below, have been followed 	;3
(c) Experts of the Receiving Party (1) to whom disclosure is reasonably necessary for this
litigation, (2) who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), and
(3) as to whom the procedures set forth in paragraph 7.4(a)(2), below, have been followed 	;
(d) the court and its personnel;
(e) court reporters and their staff, professional jury or trial consultants, 	including mock
jurors, and Professional Vendors to whom disclosure is reasonably necessary for this litigation and
who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(f) the author or recipient of a document containing the information or a custodian or
other person who otherwise possessed or knew the information 	; and
(g) any mediator who is assigned to this matter, and his or her staff, who have signed
the “Acknowledgement and Agreement to Be Bound” (Exhibit A).
7.4 	Procedures for Approving or Objecting to Disclosure of “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	Information or Items to Designated House
Counsel 	or Experts.
2 It may be appropriate under certain circumstances to limit the number of Designated House
Counsel who may access “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
information under this provision.
3 It may also be appropriate under certain circumstances to limit how Designated House Counsel
may access “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information. For
example, Designated House Counsel may be limited to viewing “HIGHLY CONFIDENTIAL –
ATTORNEYS’ EYES ONLY” information only if it is filed with the court under seal, or in the
presence of Outside Counsel of Record at their offices.
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(a)(1) Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a
Party that seeks to disclose to Designated House Counsel any information or item that has been designated
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” pursuant to paragraph 7.3(b) first must
make a written request to the Designating Party that (1) sets forth the full name of the Designated House
Counsel and the city and state of his or her residence, and (2) describes the Designated House Counsel’s
current and reasonably foreseeable future primary job duties and responsibilities in sufficient detail to
determine if House Counsel is involved, or may become involved, in any competitive decision-making.4
(a)(2) Unless otherwise ordered by the court or agreed to in writing by the Designating
Party, a Party that seeks to disclose to an Expert (as defined in this Order) any information or item
that has been designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
pursuant to paragraph 7.3(c) first must make a written request to the Designating Party that (1)
identifies the general categories of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
information that the Receiving Party seeks permission to disclose to the Expert, (2) sets forth the
full name of the Expert and the city and state of his or her primary residence, (3) attaches a copy
of the Expert’s current resume, (4) identifies the Expert’s current employer(s), (5) identifies each
person or entity from whom the Expert has received compensation or funding for work in his or
her areas of expertise or to whom the expert has provided professional services, including in
connection with a litigation, at any time during the preceding five years,5 and (6) identifies (by
name and number of the case, filing date, and location of court) any litigation in connection with
which the Expert has offered expert testimony, including through a declaration, report, or
testimony at a deposition or trial, during the preceding five years.
4 It may be appropriate in certain circumstances to require any Designated House Counsel who
receives “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information pursuant to
this Order to disclose any relevant changes in job duties or responsibilities prior to final
disposition of the litigation to allow the Designating Party to evaluate any later-arising competitive
decision-making responsibilities.
5 If the Expert believes any of this information is subject to a confidentiality obligation to a third-
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(b) A Party that makes a request and provides the information specified in the preceding
respective paragraphs may disclose the subject Protected Material to the identified Designated
House Counsel or Expert unless, within 14 days of delivering the request, the Party receives a
written objection from the Designating Party. Any such objection must set forth in detail the
grounds on which it is based.
(c) A Party that receives a timely written objection must meet and confer with the
Designating Party (through direct voice to voice dialogue) to try to resolve the matter by
agreement within seven days of the written objection. If no agreement is reached, the Party
seeking to make the disclosure to Designated House Counsel or the Expert may 	follow the dispute
procedures outlined in the Discovery Standing Order for Magistrate Judge Thomas S. Hixson,
seeking permission from the court to do so. Any such motion must describe the circumstances
with specificity, set forth in detail the reasons why the disclosure to Designated House Counsel or
the Expert is reasonably necessary, assess the risk of harm that the disclosure would entail, and
suggest any additional means that could be used to reduce that risk. In addition, any such motion
must be accompanied by a competent declaration describing the parties’ efforts to resolve the
matter by agreement (i.e., the extent and the content of the meet and confer discussions) and
setting forth the reasons advanced by the Designating Party for its refusal to approve the
disclosure.
In any such proceeding, the Party opposing disclosure to Designated House Counsel or the
Expert shall bear the burden of proving that the risk of harm that the disclosure would entail
(under the safeguards proposed) outweighs the Receiving Party’s need to disclose the Protected
Material to its Designated House Counsel or Expert.
party, then the Expert should provide whatever information the Expert believes can be disclosed
without violating any confidentiality agreements, and the Party seeking to disclose to the Expert
shall be available to meet and confer with the Designating Party regarding any such engagement.
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9. 	[INTENTIONALLY LEFT BLANK]
10. 	PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER
LITIGATION
If a Party is served with a subpoena or a court order issued in other litigation that compels
disclosure of any information or items designated in this action as “CONFIDENTIAL” or “HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	that Party must:
(a) promptly notify in writing the Designating Party. Such notification shall include a
copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order to issue in the
other litigation that some or all of the material covered by the subpoena or order is subject to this
Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and
(c) cooperate with respect to all reasonable procedures sought to be pursued by the
Designating Party whose Protected Material may be affected.
If the Designating Party timely seeks a protective order, the Party served with the subpoena
or court order shall not produce any information designated in this action as “CONFIDENTIAL” or
“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” 	before a determination by the
court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s
permission. The Designating Party shall bear the burden and expense of seeking protection in that
court of its confidential material – and nothing in these provisions should be construed as
authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from
another court.
11. 	A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS
LITIGATION
(a) The terms of this Order are applicable to information produced by a Non-Party in this
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action and designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
EYES ONLY” 	. Such information produced by Non-Parties in connection with this litigation is
protected by the remedies and relief provided by this Order. Nothing in these provisions should be
construed as prohibiting a Non-Party from seeking additional protections.
(b) In the event that a Party is required, by a valid discovery request, to produce a Non-
Party’s confidential information in its possession, and the Party is subject to an agreement with the
Non-Party not to produce the Non-Party’s confidential information, then the Party shall:
1. 	promptly notify in writing the Requesting Party and the Non-Party that some
or all of the information requested is subject to a confidentiality agreement with a Non-Party;
2. 	promptly provide the Non-Party with a copy of the Stipulated Protective
Order in this litigation, the relevant discovery request(s), and a reasonably specific description of the
information requested; and
3. 	make the information requested available for inspection by the Non-Party.
(c) If the Non-Party fails to object or seek a protective order from this court within 14 days of
receiving the notice and accompanying information, the 	Producing Party may produce the Non-
Party’s confidential information responsive to the discovery request, unless doing so would not
comply with a contractual obligation of the Producing Party to the Non-Party to provide notice
longer than 14 days, in which case the applicable notice period shall be such contractual obligation
period. Regardless of such period, the Producing Party shall endeavor to resolve any concerns
regarding notice within 30 days. If the Non-Party timely seeks a protective order, the 	Producing
Party shall not produce any information in its possession or control that is subject to the
confidentiality agreement with the Non-Party before a determination by the court. 	Absent a court
order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this
court of its Protected Material.
(d) 	Any discovery requests, including subpoena and deposition notices, propounded to
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Non-Parties must be accompanied by a copy of this Stipulated Protective Order.
12. 	UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected
Material to any person or in any circumstance not authorized under this Stipulated Protective Order,
the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized
disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c)
inform the person or persons to whom unauthorized disclosures were made of all the terms of this
Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to
Be Bound” that is attached hereto as Exhibit A.
13. 	INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED
MATERIAL
13.1. 	Pursuant to Federal Rule of Evidence 502(d), the production of privileged or work-
product protected documents, electronically stored information or information (collectively
“Protected Documents”), whether inadvertent or otherwise, is not a waiver of the privilege or
protection from discovery in this case or in any other federal or state proceeding.
This Order shall be interpreted to provide the maximum protection allowed by Federal Rule
of Evidence 502(d). The provisions of Rule 502(b) do not apply.
13.2. 	A Producing Party that discovers it has produced Protected Documents shall provide
written notice of the claim of privilege or protection to the Receiving Party. If a Producing Party
makes a claim that it has produced Protected Documents, pursuant to this Stipulated Protective
Order, the Receiving Party shall, within 10 days: (i) refrain from any further examination or
disclosure of the claimed Protected Documents; (ii) return the claimed Protected Documents and all
copies thereof (including summaries and excerpts) to counsel for the Producing Party, or destroy all
such claimed Protected Documents (including summaries and excerpts) and certify in writing to that
fact; and (iii) not disclose or use the claimed Protected Documents for any purpose until further
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order of the Court expressly authorizing such use.
13.3. 	A Party may move the Court, using the dispute procedures outlined in the Discovery
Standing Order for Magistrate Judge Thomas S. Hixson, for an order compelling production of the
Protected Documents on the ground that it is not, in fact, privileged or protected. The motion shall
be filed under seal and shall not assert as a ground for entering such an order the fact or circumstance
of the production of Protected Documents. Any effort to file under seal pursuant to this paragraph
must comply with Civil Local Rule 79-5. The Producing Party retains the burden of establishing the
privileged or protected nature of any inadvertently disclosed or produced information. While such
a motion is pending, the Protected Documents at issue shall be treated in accordance with Paragraph
13.2 above.
14. 	MISCELLANEOUS
14.1 	Right to Further Relief. Nothing in this Order abridges the right of any person to seek
its modification by the court in the future.
14.2 	Right to Assert Other Objections. By stipulating to the entry of this Protective Order
no Party waives any right it otherwise would have to object to disclosing or producing any
information or item on any ground not addressed in this Stipulated Protective Order. Similarly, no
Party waives any right to object on any ground to use in evidence of any of the material covered by
this Protective Order.
14.3 	Export Control. Disclosure of Protected Material shall be subject to all applicable
laws and regulations relating to the export of technical data contained in such Protected Material,
including the release of such technical data to foreign persons or nationals in the United States or
elsewhere. The Producing Party shall be responsible for identifying any such controlled technical
data, and the Receiving Party shall take measures necessary to ensure compliance with applicable
export control laws, including confirming that no unauthorized foreign person has access to such
technical data.
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14.4 	Filing Protected Material. Without written permission from the Designating Party or a
court order secured after appropriate notice to all interested persons, a Party may not file in the
public record in this action any Protected Material. A Party that seeks to file under seal any Protected
Material must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal
pursuant to a court order authorizing the sealing of the specific Protected Material at issue. Pursuant
to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that the
Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to
protection under the law. If a Receiving Party’s request to file Protected Material under seal pursuant
to Civil Local Rule 79-5 is denied by the court, then the Receiving Party may file the Protected
Material in the public record pursuant to Civil Local Rule 79-5 unless otherwise instructed by the
court.
15. 	FINAL DISPOSITION
Within 60 days after the final disposition of this action, as defined in paragraph 4, each
Receiving Party must return all Protected Material to the Producing Party or destroy such material
except where such material exists on backup tapes or other disaster recovery systems that are
routinely deleted or written over in accordance with an established routine system maintenance
practice. As used in this subdivision, “all Protected Material” includes all copies, abstracts,
compilations, summaries, and any other format reproducing or capturing any of the Protected
Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a
written certification to the Producing Party (and, if not the same person or entity, to the Designating
Party) by the 60-day deadline that (1) identifies (by category, where appropriate) all the Protected
Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any
copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the
Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of
all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda,
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correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant
and expert work product, even if such materials contain Protected Material. Any such archival copies
that contain or constitute Protected Material remain subject to this Protective Order as set forth in
Section 4 (DURATION).
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: May 13, 2026 	/s/ Jessica I. Rothschild_____________
Jessica I. Rothschild
jrothschild@steptoe.com
STEPTOE LLP
1330 Connecticut Ave., NW
Washington, DC 20036
(202) 429-1370
One Market Plaza
Steuart Tower, 10th Floor, Suite 1070
San Francisco, CA 94105
Christopher S. Niewoehner (admitted pro hac vice)
cniewoehner@steptoe.com
STEPTOE LLP
227 W. Monroe Street, Suite 4700
Chicago, IL 60606
(312) 577-1240
Attorneys for Plaintiff META PLATFORMS, INC.
DATED: May 13, 2026 	/s/ Airene Williamson________________
Airene Williamson
awilliamson@sacattorneys.com
James Cai
jcai@sacattorneys.com
Woody Wu
wwu@sacattorneys.com
SAC ATTORNEYS, LLP
1754 Technology Drive, Suite 122
San Jose, CA 95110
(408) 436-0789
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Attorneys for Defendants PERFEOS LLC d/b/a
SHOP AT MARS, JOT & JOURNEYS aka
JOT & JOURNEY, ANTONIO JOSÉ LIÉVANO
PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATED: May 13, 2026____________ _____________________________________
Thomas S. Hixson
United States 	Magistrate Judge
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _____________________________ [print or type full name], of _________________
[print or type full address], declare under penalty of perjury that I have read in its entirety and
understand the Stipulated Protective Order that was issued by the United States District Court for the
Northern District of California on [date] in the case of 	Meta Platforms, Inc. v. Judang Team LLC
et al., Case No. 3:25-cv-05156-TSH. I agree to comply with and to be bound by all the terms of this
Stipulated Protective Order and I understand and acknowledge that failure to so comply could
expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not
disclose in any manner any information or item that is subject to this Stipulated Protective Order to
any person or entity except in strict compliance with the provisions of this Order.
I further agree to submit to the jurisdiction of the United States District Court for the
Northern District of California for the purpose of enforcing the terms of this Stipulated Protective
Order, even if such enforcement proceedings occur after termination of this action.
I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and telephone number] as
my California agent for service of process in connection with this action or any proceedings related
to enforcement of this Stipulated Protective Order.
Date: ______________________________________
City and State where sworn and signed: _________________________________
Printed name: _______________________________
Signature: __________________________________
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