Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`JOINT MOTION FOR MODIFICATION OF
`DEFAULT PROTECTIVE ORDER
`
`
`
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`JOINT MOTION FOR MODIFICATION OF
`DEFAULT PROTECTIVE ORDER
`
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`In accordance with the Board’s May 31, 2018 order denying the Parties’ joint
`
`motion for entry of protective order (Paper 20), the Parties submit a modified
`
`proposed protective order attached as Exhibit A.1 In particular, this modified
`
`proposed protective order includes the “sua sponte” language set forth in
`
`Subsections 4(A)(i) and 4(A)(ii) of the default Protective Order to ensure that the
`
`Parties may not use their own agreement to limit the Board’s ability to determine
`
`whether information qualifies for confidential treatment in this proceeding. See id.
`
`at 2-3. This modified proposed protective order also deletes that portion of
`
`originally-proposed Subsection 5(B)(ii) allowing a party to submit mutually-
`
`agreeable redactions to confidential materials to redact sensitive information that is
`
`not relevant to the case. See id. at 4-5. Lastly, Section 3 of the originally-proposed
`
`protective order has been modified to make clear that the individuals listed in
`
`Subsections 2(B), 2(F), and 2(G) of the default protective order do not have to sign
`
`
`
`1 Appendix B is a redline showing the proposed modifications to the PTAB’s default
`
`protective order (published in Appendix B of the Office Patent Trial Practice Guide,
`
`77 Fed. Reg. 48756, 48769-71 (Aug. 14, 2012).
`
`1
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`an Acknowledgement in order to access a party’s attorneys’ eyes only information.
`
`See id. at 5-6.
`
`Pursuant to 37 C.F.R. § 42.54, the Parties have met and conferred in good
`
`faith and agree to the proposed modifications to the current default Protective Order.
`
`WHEREFORE, the Parties request that the Board enter the Parties’ modified
`
`proposed protective order attached as Appendix A.
`
`
`
`
`
`
`
`Date: June 14, 2018
`
`
`
`
`
`/Wayne O. Stacy/
`
`
`
`Wayne O. Stacy
`
`
`
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
`2
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 14th day
`
`of June 2018, this document was filed with the Patent Trial and Appeal Board End
`
`to End (PTAB E2E) System and a copy was provided via email to Patent Owner’s
`
`counsel of record:
`
`Wayne Stacy
`Sarah J. Guske
`Michelle Jacobson Eber
`
`wayne.stacy@bakerbotts.com
`sarah.guske@bakerbotts.com
`michelle.eber@bakerbotts.com
`
`
`
`
`
`
`Date: June 14, 2018
`
`
`
`Respectfully submitted,
`SHOOK, HARDY & BACON LLP
`
`/Jesse Camacho/
`Jesse Camacho
`Lead Counsel
`
`
`
`
`
`
`
`
`
`3
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`
`
`
`
`APPENDIX
` A
`
`
`
`
`
`
`
`4
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`[PROPOSED] STIPULATED PROTECTIVE ORDER
`
`
`
`
`
`
`
`
`5
`
`
`
`
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`Protective Order
`
`This protective order governs the treatment and filing of confidential
`
`information, including documents and testimony.
`
`1. Confidential information shall be clearly marked PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL.”
`
`2. Access to confidential information marked as “PROTECTIVE ORDER
`
`MATERIAL” is limited to the following individuals who have executed the
`
`Acknowledgment appended to this order:
`
`(A) Parties. Designated officers, directors, and employees of the
`
`Receiving Party to whom disclosure is reasonably necessary;
`
`(B) Outside Counsel. Outside counsel of record for a party in the
`
`Proceeding (and they shall have such access without the requirement to sign
`
`the Acknowledgement).
`
`(C) Experts. Retained experts of a party in the Proceeding who further
`
`certify in the Acknowledgement that they are not a competitor to any party,
`
`or a consultant for, or employed by, such a competitor with respect to the
`
`subject matter of the proceeding.
`
`(D) In-house counsel. In-house counsel of a party.
`
`6
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`(E) Other Persons Associated With a Party. Consultants or other
`
`persons performing work for a party, other than in-house counsel and in-
`
`house counsel’s support staff, who sign the Acknowledgement shall be
`
`extended access to confidential information only upon agreement of the
`
`parties or by order of the Board upon a motion brought by the party seeking
`
`to disclose confidential information to that person. The party opposing
`
`disclosure to that person shall have the burden of proving that such person
`
`should be restricted from access to confidential information.
`
`(F) The Office. Employees and representatives of the Office who have
`
`a need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees and
`
`representatives shall include the Director, members of the Board and their
`
`clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
`
`(G) Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons who are
`
`reasonably necessary to assist those persons in the proceeding shall not be
`
`required to sign an Acknowledgement, but shall be informed of the terms
`
`and requirements of the Protective Order by the person they are supporting
`
`7
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`who receives confidential information.
`
`3. A party or non-party may designate certain confidential material as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL,” by
`
`marking it as such, provided that the party or non-party has a good faith basis to
`
`believe that such information is particularly sensitive and a substantial competitive
`
`harm might result if it were made public. Access to any material marked as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL” is
`
`limited to the individuals identified in subsections 2(B), 2(F), and 2(G) (and they
`
`shall have such access without the requirement to sign the Acknowledgement) and
`
`the individuals identified in subsection 2(C) who have executed the
`
`Acknowledgment appended to this order. Nothing in this Order, or the parties’
`
`consent thereto, should be construed to supersede or replace any other
`
`confidentiality obligations held by a disclosing party under a protective order
`
`entered by another tribunal including the International Trade Commission or any
`
`U.S. district court.
`
`4. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which
`
`persons not authorized to receive the information shall not have access;
`
`8
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality
`
`of the information, which efforts shall be no less rigorous than those the
`
`recipient uses to maintain the confidentiality of information not received
`
`from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access
`
`to the confidential information understand and abide by the obligation to
`
`maintain the confidentiality of information received that is designated as
`
`confidential; and
`
`(D) Limiting the copying of confidential information to only those
`
`copies needed for conduct of the proceeding and maintaining a record of the
`
`locations of such copies.
`
`5. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board
`
`under seal, together with a non-confidential description of the nature
`
`of the confidential information that is under seal and the reasons why
`
`the information is confidential and should not be made available to
`
`the public. The submission shall be treated as confidential and remain
`
`9
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`under seal, unless, upon motion of a party and after a hearing on the
`
`issue, or sua sponte, the Board determines that the documents or
`
`information do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`locations of information that has been redacted. The confidential
`
`version of the submission shall be filed under seal. The redacted
`
`information shall remain under seal unless, upon motion of a party
`
`and after a hearing on the issue, or sua sponte, the Board determines
`
`that some or all of the redacted information does not qualify for
`
`confidential treatment.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`Information designated as confidential that is disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`10
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” or
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” and shall be produced in a manner that maintains its
`
`confidentiality.
`
`6. If the producing party seeks to keep “PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” sealed, the other party will cooperate in those efforts, including by
`
`not opposing a request by the producing party to keep the documents sealed.
`
` “Acknowledgement” of Protective Order. The following form may be used
`
`to acknowledge a protective order and gain access to information covered by the
`
`protective order:
`
`
`
`
`
`
`
`
`
`
`
`Dated: June 14, 2018
`
`
`
`
`
`/Wayne O. Stacy/
`
`
`
`Wayne O. Stacy
`
`
`
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
`
`
`
`
`
`
`
`
`
`
`
`
`11
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`ACKNOWLEDGEMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
`
`
`
`
`12
`
`
`
`
`
`
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`Acknowledgment for Access to Protective Order Material
`
` ________________, affirm that I have read the Protective Order; that I will
`
` I
`
`abide by its terms; that I will use the confidential information only in connection
`
`with this proceeding and for no other purpose; that I will only allow access to support
`
`staff who are reasonably necessary to assist me in this proceeding; that prior to any
`
`disclosure to such support staff I informed or will inform them of the requirements
`
`of the Protective Order; that I am personally responsible for the requirements of the
`
`terms of the Protective Order and I agree to submit to the jurisdiction of the Office
`
`and the United States District Court for the Eastern District of Virginia for purposes
`
`of enforcing the terms of the Protective Order and providing remedies for its breach.
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: _______________________
`
`
`
`Date:________________________
`
`13
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`APPENDIX B
`
`
`
`14
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`
`
`
`
`[PROPOSED] STIPULATED PROTECTIVE ORDER
`
`
`15
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`Standing Protective Order
`
`This standing protective order governs the treatment and filing of
`
`confidential information, including documents and testimony.
`
`1. Confidential information shall be clearly marked PROTECTIVE ORDER
`
`MATERIAL.”” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL.”
`
`2. Access to confidential information marked as “PROTECTIVE ORDER
`
`MATERIAL” is limited to the following individuals who have executed the
`
`acknowledgmentAcknowledgment appended to this order:
`
`(A) Parties. Persons who are ownersDesignated officers, directors,
`
`and employees of a patent involved in the proceeding and other persons who
`
`are named parties Receiving Party to the proceeding.whom disclosure is
`
`reasonably necessary;
`
`(B) Party Representatives. RepresentativesOutside Counsel. Outside
`
`counsel of record for a party in the proceeding.Proceeding (and they shall
`
`have such access without the requirement to sign the Acknowledgement).
`
`(C) Experts. Retained experts of a party in the proceedingProceeding
`
`who further certify in the Acknowledgement that they are not a competitor
`
`to any party, or a consultant for, or employed by, such a competitor with
`
`16
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`respect to the subject matter of the proceeding.
`
`(D) In-house counsel. In-house counsel of a party.
`
`(E) Other Employees ofPersons Associated With a Party. Employees,
`
`consultantsConsultants or other persons performing work for a party, other
`
`than in-house counsel and in-house counsel’s support staff, who sign the
`
`Acknowledgement shall be extended access to confidential information only
`
`upon agreement of the parties or by order of the Board upon a motion
`
`brought by the party seeking to disclose confidential information to that
`
`person. The party opposing disclosure to that person shall have the burden of
`
`proving that such person should be restricted from access to confidential
`
`information.
`
`(F) The Office. Employees and representatives of the Office who have
`
`a need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees and
`
`representatives shall include the Director, members of the Board and their
`
`clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
`
`(G) Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons who are
`
`17
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`reasonably necessary to assist those persons in the proceeding shall not be
`
`required to sign an Acknowledgement, but shall be informed of the terms
`
`and requirements of the Protective Order by the person they are supporting
`
`who receives confidential information.
`
`3. A party or non-party may designate certain confidential material as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL,” by
`
`marking it as such, provided that the party or non-party has a good faith basis to
`
`believe that such information is particularly sensitive and a substantial competitive
`
`harm might result if it were made public. Access to any material marked as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL” is
`
`limited to the individuals identified in subsections 2(B), 2(F), and 2(G) (and they
`
`shall have such access without the requirement to sign the Acknowledgement) and
`
`the individuals identified in subsection 2(C) who have executed the
`
`Aacknowledgment appended to this order: outside counsel of record for a party in
`
`this IPR Proceeding and the individuals identified in subsection 2(C). Nothing in
`
`this Order, or the parties’ consent thereto, should be construed to supersede or
`
`replace any other confidentiality obligations held by a disclosing party under a
`
`protective order entered by another tribunal including the International Trade
`
`Commission or any U.S. district court.
`
`18
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`4. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which
`
`persons not authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality
`
`of the information, which efforts shall be no less rigorous than those the
`
`recipient uses to maintain the confidentiality of information not received
`
`from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access
`
`to the confidential information understand and abide by the obligation to
`
`maintain the confidentiality of information received that is designated as
`
`confidential; and
`
`(D) Limiting the copying of confidential information to a reasonable
`
`number ofonly those copies needed for conduct of the proceeding and
`
`maintaining a record of the locations of such copies.
`
`45. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board
`
`19
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`under seal, together with a non-confidential description of the nature
`
`of the confidential information that is under seal and the reasons why
`
`the information is confidential and should not be made available to
`
`the public. The submission shall be treated as confidential and remain
`
`under seal, unless, upon motion of a party and after a hearing on the
`
`issue, or sua sponte, the Board determines that the documents or
`
`information do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`locations of information that has been redacted. The confidential
`
`version of the submission shall be filed under seal. The redacted
`
`information shall remain under seal unless, upon motion of a party
`
`and after a hearing on the issue, or sua sponte, the Board determines
`
`that some or all of the redacted information does not qualify for
`
`20
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`confidential treatment.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`Information designated as confidential that is disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” or
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” and shall be produced in a manner that maintains its
`
`confidentiality.
`
`Standard 6. If the producing party seeks to keep “PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” sealed, the other party will cooperate in those efforts, including by
`
`not opposing a request by the producing party to keep the documents sealed.
`
` “Acknowledgement” of Protective Order. The following form may be used
`
`to acknowledge a protective order and gain access to information covered by the
`
`protective order:
`
`
`
`
`
`Dated: June 14, 2018
`
`
`
`
`
`/Wayne O. Stacy/
`
`
`
`Wayne O. Stacy
`
`
`
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
`
`
`
`
`
`
`
`
`21
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case: IPR2017-01976 (Patent 8,837,465)
`Case: IPR2017-01977 (Patent 8,755,376)
`
`––––––––––
`
`ACKNOWLEDGEMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
`
`
`
`
`
`
`
`
`
`
`22
`
`
`
`Case IPR2017-01976 (Patent 8,837,465)
`Case IPR2017-01977 (Patent 8,755,376)
`
`Acknowledgment for Access to Protective Order Material
`
` ________________, affirm that I have read the Protective Order; that I will
`
` I
`
`abide by its terms; that I will use the confidential information only in connection
`
`with this proceeding and for no other purpose; that I will only allow access to support
`
`staff who are reasonably necessary to assist me in this proceeding; that prior to any
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`disclosure to such support staff I informed or will inform them of the requirements
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`of the Protective Order; that I am personally responsible for the requirements of the
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`terms of the Protective Order and I agree to submit to the jurisdiction of the Office
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`and the United States District Court for the Eastern District of Virginia for purposes
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`of enforcing the terms of the Protective Order and providing remedies for its breach.
`
`
`
`
`
`By: _______________________
`
`
`
`Date:________________________
`
`23
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`
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