Voip Pal Com Inc (VPLM)

[penny2pound]

DESMARAIS LLP
John M. Desmarais (SBN 320875)
Ameet A. Modi (pro hac vice)
Robert C. Harrits (pro hac vice)
Michael J. X. Matulewicz-Crowley (pro
hac vice)
230 Park Avenue
New York, NY 10169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Peter C. Magic (SBN 278917)
[e-mail]
101 California Street, Suite 3070
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant Apple Inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
VOIP-PAL.COM, INC.,
Plaintiff,
v.
APPLE INC.,
Defendant.
Case No. 5:18-cv-06216-LHK
Case No. 5:18-cv-06217-LHK
JOINT STIPULATION REGARDING
TREATMENT OF CONFIDENTIAL
INFORMATION
JURY TRIAL DEMANDED

Plaintiff VoIP-Pal.com, Inc. (“Plaintiff”) and Defendant Apple Inc. (“Apple”) agree and
stipulate as follows:
WHEREAS the parties are in ongoing negotiations over a proposed protective order
governing the confidentiality and disclosure of discovery produced during this litigation and intend
to file a joint letter brief outlining the disputed issues in the coming days;
WHEREAS pursuant to the Court’s Case Management Orders (Case No. 5:18-cv-06216-
LHK, ECF 53; Case No. 5:18-cv-06217-LHK, ECF 77) and Patent Local Rule 3-4, Defendant Apple
Case 5:18-cv-06217-LHK Document 93 Filed 03/18/19 Page 1 of 3
JOINT STIPULATION REGARDING
TREATMENT OF CONFIDENTIAL
INFORMATION
5:18-cv-06177-LHK
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is required to and intends to produce documents on March 18, 2019, some of which will contain
highly sensitive and confidential information;
WHEREAS because the Model Protective Order in the Northern District of California does
not resolve the disputes between the parties, IT IS HEREBY STIPULATED that both parties and
their counsel will be bound by the proposed protective order governing the treatment of confidential
information (attached as Exhibit 1), including Apple’s/Defendants’ proposals, for the limited
duration of the period between this stipulation and the Court’s resolution of the parties’ forthcoming
letter brief on the disputed protective order issues.
The parties agree that the fact that Plaintiff so-stipulated shall not be used against Plaintiff
to argue that the stipulation itself proves that Defendants’ proposals are acceptable to or workable
for Plaintiff.
This Stipulation is filed in good faith and is not intended to cause unnecessary delay.