`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`PELOTON INTERACTIVE, INC.,
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`
`
`v.
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`iFIT, INC.
`
`iFIT, INC.,
`
`
`
`v.
`
`PELOTON INTERACTIVE, INC.,
`
`Defendant.
`
`iFIT, INC.,
`
`Plaintiff
`
`
`
`v.
`
`PELOTON INTERACTIVE, INC.,
`
`Defendant.
`
`C.A. No. 20-662-RGA
`
`C.A. No. 20-1386-RGA
`
`C.A. No. 21-507-RGA
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`STIPULATION AND [PROPOSED] ORDER REGARDING PROTECTIVE ORDERS
`
`WHEREAS, the parties have agreed to review source code simultaneously in C.A. No. 20-
`
`662-RGA, C.A. No. 20-1386-RGA, and C.A. No. 21-507-RGA (the “Related Cases”);
`
`WHEREAS, a Protective Order has not yet been entered in C.A. No. 21-507-RGA; and
`
`WHEREAS, the parties agree that the provisions of the Stipulated Protective Orders
`
`governing review of source code in the Related Cases should conform;
`
`RLF1 26091572v.1
`
`
`
`Case 1:20-cv-00662-RGA Document 153 Filed 10/01/21 Page 2 of 2 PageID #: 4756
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`IT IS HEREBY STIPULATED AND AGREED, by and between the parties, subject to the
`
`approval of the Court, that:
`
`1.
`
`Paragraph 8(h) of the Stipulated Protective Orders in C.A. No. 20-662-RGA (D.I.
`
`63) and C.A. No. 20-1386-RGA (D.I. 33) is amended to read as follows:
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`h.
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`During inspection, the Receiving Party shall not be permitted to photograph, copy,
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`remove, or otherwise transfer any portion of the source code onto any recordable media or
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`recordable device. However, the Receiving Party shall be entitled to take handwritten notes
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`relating to the source code.
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`2.
`
`Paragraphs 6.3 and 8 of the Stipulated Protective Orders in C.A. No. 20-662-RGA
`
`(D.I. 63) and C.A. No. 20-1386-RGA (D.I. 33) shall govern the source code review in C.A. No.
`
`21-507-RGA unless and until a Stipulated Protective Order is entered in C.A. No. 21-507-RGA.
`
`
`/s/ Michael J. Flynn
`Michael J. Flynn (#5333)
`Morris, Nichols, Arsht & Tunnell LLP
`1201 N. Market Street
`P. O. Box 1347
`Wilmington, DE 19801
`(302) 658-9200
`mflynn@mnat.com
`
`Attorneys for Peloton Interactive, Inc.
`
`Dated: September 30, 2021
`
`/s/ Christine D. Haynes
`Frederick L. Cottrell, III (#2555)
`Christine D. Haynes (#4697)
`Valerie A. Caras (#6608)
`Richards, Layton & Finger, P.A.
`920 N. King Street
`Wilmington, DE 19801
`(302) 651-7700
`cottrell@rlf.com
`haynes@rlf.com
`caras@rlf.com
`
`Attorneys for iFit, Inc.
`
`1st
`October
`SO ORDERED this ____ day of ______________________, 2021.
`
`/s/ Richard G. Andrews
`U.S.D.J.
`
`RLF1 26091572v.1
`
`
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