ACCEPTED 15-25-00109-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 6/23/2025 5:08 PM NO. __-__-______-CV CHRISTOPHER A. PRINE CLERK FILED IN IN THE FIFTEENTH COURT OF APPEALS 15th COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 6/23/2025 5:08:40 PM CHRISTOPHER A. PRINE Clerk
IN RE STORABLE, INC.; REDNOVA LABS, INC. (D/B/A STOREDGE); SITELINK SOFTWARE, LLC; EASY STORAGE SOLUTIONS, LLC; BADER CO.; AND PROPERTY FIRST GROUP, LP Relators.
Relating to Trial Court Cause No. 25-BC03A-0001 In the Third Division of the Texas Business Court
PETITION FOR WRIT OF MANDAMUS
GREENBERG TRAURIG, LLP
Dale Wainwright State Bar No. 00000049 dale.wainwright@gtlaw.com Justin Bernstein State Bar No. 24105462 justin.bernstein@gtlaw.com 300 West 6th Street Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210
COUNSEL FOR RELATORS
ORAL ARGUMENT REQUESTED IDENTITIES OF PARTIES AND COUNSEL Relators Storable, Inc.; RedNova Labs, Inc. (d/b/a storEDGE); Sitelink Software, LLC; Easy Storage Solutions, LLC; Bader Co.; and Property First Group, LP Counsel for Relators
Dale Wainwright Ray T. Torgerson State Bar No. 00000049 State Bar No. 24003067 dale.wainwright@gtlaw.com rtorgerson@porterhedges.com Justin Bernstein Jonna N. Summers State Bar No. 24105462 State Bar No. 24060649 justin.bernstein@gtlaw.com jsummers@porterhedges.com GREENBERG TRAURIG, LLP Elizabeth “Liza” Eoff 300 West 6th Street, State Bar No. 24095062 Suite 2050 leoff@porterhedges.com Austin, Texas 78701 Lakshmi N. Kumar T: (512) 320-7200 State Bar No. 24144581 F: (512) 320-7210 lkumar@porterhedges.com PORTER HEDGES LLP 1000 Main Street, 36th Floor Houston, Texas 77002 T: (713) 226-6000 F: (713) 226-6000
Katherine G. Treistman State Bar No. 00796632 katherine.treistman@arnoldporter.com Andrew D. Bergman State Bar No. 24101507 andrew.bergman@arnoldporter.com ARNOLD & PORTER KAYE SCHOLER LLP 700 Louisiana Street, Suite 4000 Houston, Texas 77002 T: (713) 576-2400 F: (713) 576-2499
-ii- Real Party in Interest SafeLease Insurance Services, LLC Counsel for Real Party
Judd E. Stone II R. Paul Yetter State Bar No. 2407670 State Bar No. 22154200 judd@stonehilton.com pyetter@yettercoleman.com Christopher D. Hilton Susanna R. Allen State Bar No. 24087727 State Bar No. 24126616 STONE HILTON PLLC sallen@yettercoleman.com 600 Congress Ave., Luke A. Schamel Austin, Texas 78701 State Bar No. 24106403 T: (737) 465-7248 lschamel@yettercoleman.com Shannon N. Smith State Bar No. 24110378 ssmith@yettercoleman.com YETTER COLEMAN LLP 811 Main Street, Suite 4100 Houston, Texas 77002 T: (713) 632-8000
Respondent Honorable Melissa Andrews Third Division of the Texas Business Court Herman Marion Sweatt Courthouse Courtroom 421 1000 Guadalupe St. Austin, Texas 78701
-iii- TABLE OF CONTENTS Page NO. __-__-______-CV ................................................................................1 IDENTITIES OF PARTIES AND COUNSEL ................................................ II TABLE OF CONTENTS ............................................................................... IV STATEMENT REGARDING MANDAMUS RECORD ............................. VIII DEFINITIONS............................................................................................. IX STATEMENT OF JURISDICTION................................................................X STATEMENT REGARDING ORAL ARGUMENT....................................... XI STATEMENT OF THE CASE ..................................................................... XII ISSUE PRESENTED ................................................................................ XIII INTRODUCTION ...........................................................................................1 STATEMENT OF FACTS............................................................................... 2 I. The Parties Are Competitors Alleging Tortious Interference With Each Other’s Agreements With Clients. .......................................... 2 II. SafeLease Requested Production Of Storable’s Client List. ................... 3 III. The Trial Court Ordered Storable To Produce The Client List. ............. 4 ARGUMENT.................................................................................................. 5 I. Standard Of Review. .....................................................................................5 II. Storable’s Customer List Is A Trade Secret............................................... 6 A. Storable Takes Reasonable Measures To Keep The Client List Secret. ...........................................................................................7 B. The Client List derives economic value from its secrecy. ............. 9 C. Storable did not waive its trade secret privilege. .........................10 III. SafeLease Did Not Prove That It Needs The Client List. ......................12 IV. The Protective Order Does Not Negate The Risk Of Producing The Client List. ............................................................................................15 A. Confidentiality designations do not supersede trade secret protection...........................................................................................15
-iv- B. SafeLease may later argue that the Protective Order is void. ....................................................................................................16 C. SafeLease has shown there is a material risk that it will circumvent the Protective Order. ...................................................17 V. Storable Has No Adequate Remedy By Appeal. .....................................18 PRAYER .......................................................................................................19 RULE 52.3(J) CERTIFICATION ................................................................. 20 CERTIFICATE OF COMPLIANCE ...............................................................21 CERTIFICATE OF SERVICE....................................................................... 22 APPENDIX .................................................................................................. 24
-v- TABLE OF AUTHORITIES
Page(s)
Cases In re 4X Indus., LLC, 639 S.W.3d 801 (Tex. App.—Houston [14th Dist.] 2021, no pet.) .......12, 13, 15 Automatic Drilling Machines, Inc. v. Miller, 515 S.W.2d 256 (Tex. 1974) ..............................................................................13 In re Bass, 113 S.W.3d 735 (Tex. 2003) ..............................................................................18 In re Bridgestone/Firestone, Inc., 106 S.W.3d 730 (Tex. 2003) (orig. proceeding) ................................................12 In re Cont’l Gen. Tire, Inc., 979 S.W.2d 609 (Tex. 1998) .......................................................................passim In re Diamond Shamrock Ref. Co., L.P., No. 07-06-0315-CV, 2007 WL 63370 (Tex. App.—Amarillo Jan. 10, 2007, no pet.) ................................................................................................13 In re Durnin, 619 S.W.3d 250 (Tex. 2021) ................................................................................5
In re Energy XXI Gulf Coast, Inc., No. 01-10-00371-CV, 2010 WL 5187730 (Tex. App.—Houston [1st Dist.] Dec. 23, 2010, no pet.) .......................................................................16 In re Hewlett Packard, 212 S.W.3d 356 (Tex. App.—Austin 2006, no pet.) ..........................................15
Houston Livestock Show & Rodeo, Inc. v. Dolcefino Commc’ns, LLC, 702 S.W.3d 675 (Tex. App.—Houston [1st Dist.] 2024, no pet.) ........................ 6
Reilly v. Premier Polymers, LLC, 2020 WL 7074253 (Tex. App.—Houston [14th Dist.] Dec. 3, 2020, pet. dism’d) .................................................................................................8
-vi- In re Shipman, 540 S.W.3d 562 (Tex. 2018) (orig. proceeding) (per curiam) ...........................19
In re Union Pac. R. Co., 294 S.W.3d 589 (Tex. 2009) (orig. proceeding) ..................................6, 7, 16, 18
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) ..............................................................................19
In re Waste Mgmt of Texas, Inc., 392 S.W.3d 861 (Tex. App.—Texarkana 2013, no pet.)....................................16
Rules Tex. R. Evid. 507(a) .................................................................................6, 12, 16, 17
Statutes TEX. CIV. PRAC. & REM. CODE § 134A.002(6) .......................................................... 6
-vii- STATEMENT REGARDING MANDAMUS RECORD Relators are separately filing a sworn mandamus record in support of
this petition for writ of mandamus. TEX. R. APP. P. 52.7(a)(1). References to
the mandamus record, which is consecutively paginated, are in the form
“[Exhibit #]MR[Page #].” Selected materials from the mandamus record are
attached in the Appendix to this petition as required or appropriate. TEX. R.
APP. P. 52.3(k). References to exhibits in the Appendix are in the form “Appx.
[Appendix tab #], MR[ page #].”
The motion giving rise to the ruling at issue was decided without a
hearing, so no testimony was adduced regarding that motion. TEX. R. APP. P.
52.7(a)(2).
-viii- DEFINITIONS
Client List Documents containing trade secrets sufficient to show the name, city, state, and zip code of all self- storage facilities using Storable’s FMS platforms as of December 30, 2024
FMS Facility management software, which is used by operators of self-storage facilities to manage those facilities
Production Order The trial court’s May 28, 2025 order to produce the Client List
SafeLease Real Party in Interest SafeLease Insurance Services, LLC
Storable Relators Storable, Inc.; RedNova Labs, Inc. (d/b/a storEDGE); Sitelink Software, LLC; Easy Storage Solutions, LLC; Bader Co.; and Property First Group, LP
-ix- STATEMENT OF JURISDICTION This Court has the power to grant the writ of mandamus sought in this
petition under article V, section 6 of the Texas Constitution, section
22.221(b) of the Texas Government Code, and Rule 52 of the Texas Rules of
Appellate Procedure. See TEX. GOV’T CODE § 22.221(a), (c–1) (“Each court of
appeals or a justice of a court of appeals may issue a writ of mandamus and
all other writs necessary to enforce the jurisdiction of the court”).
-x- STATEMENT REGARDING ORAL ARGUMENT Relators believe that oral argument would assist the Court, in
particular by allowing the Court to probe SafeLease’s vague claims that
production of this trade secret is necessary. However, given the imminent
June 13, 2025 deadline for producing the trade secret, Relators wish to forgo
oral argument if delay from oral argument would prevent the Court from
granting a stay or a writ of mandamus before the production deadline.
-xi- STATEMENT OF THE CASE Nature of the Case: This is a lawsuit between competitors in the self- storage industry. SafeLease, which sells insurance to operators of self-storage facilities, alleges that Storable is tortiously interfering with SafeLease’s agreements with operators and attempting to achieve a monopoly in tenant insurance. 2MR47– 83. Storable, which sells both insurance and software to operators, alleges that SafeLease is tortiously interfering with Storable’s operator clients and using those clients’ logins to unlawfully harvest data from its files. 12MR246–276. Trial Court Litigation of the merits of the parties’ claims is Proceeding: ongoing. During discovery, SafeLease demanded that Storable produce a list of facilities (customers) that use Storable’s FMS. Storable objected to producing this trade secret. 11MR234–235. Respondent’s Judge Melissa Andrews, presiding over the Third Action: Division of the Texas Business Court, ordered Storable to produce the Client List by June 13, 2025. Appx. A at MR290–292; Appx. B.
-xii- ISSUE PRESENTED 1. Did the trial court clearly abuse its discretion by ordering Storable to produce its trade secret Client List to its competitor even though that competitor did not prove production is necessary to enable fair adjudication of the claims?
-xiii- INTRODUCTION SafeLease encourages Storable’s FMS clients to either switch to FMS
competitors or violate Storable’s terms of use by helping them circumvent
Storable’s security measures. Now, while the parties are litigating Storable’s
claims for tortiously interfering with clients and illegally harvesting data,
SafeLease is demanding that Storable produce to it the trade secret Client
List identifying every one of the thousands of Storable’s FMS clients
throughout the world. This Client List is a highly valuable trade secret that
Storable developed through years of effort and protects with robust
safeguards against disclosure.
SafeLease failed to meet its burden to prove that producing the Client
List is necessary for a fair adjudication. Relatedly, SafeLease also failed to
provide a legitimate reason why it cannot use alternative, less commercially
sensitive, information that would equally achieve the objectives SafeLease
articulated. This leaves troubling questions about how SafeLease will use the
trade secret.
Despite these deficiencies, the trial court ordered production of the
Client List. This Court should enforce Texas’s strong protections of trade
secrets and find ordering production of the Client List to be an abuse of
discretion for which Storable lacks an adequate remedy by appeal.
-1- STATEMENT OF FACTS I. The Parties Are Competitors Alleging Tortious Interference With Each Other’s Agreements With Clients. Storable licenses FMS products to self-storage facility operators.
12MR258. Storable also offers these operators “insurance plans that compete
directly with products and services of SafeLease.” 2MR48. However,
Storable does not require operators who use Storable’s FMS to purchase
insurance from Storable. 12MR258 ¶ 13.
SafeLease alleges that it needs access to Storable’s FMS to provide
insurance services to facilities that use Storable’s FMS. 2MR74. Rather than
reach an agreement with Storable to access Storable’s FMS, SafeLease enters
agreements with operators under which operators provide their log-in
credentials to SafeLease. 2MR74 ¶ 118. When Storable blocked this method
of access, SafeLease sued for tortious interference with their agreements with
operators, and for attempted monopolization of the market for tenant
insurance at self-storage facilities. 2MR72–74. SafeLease’s monopolization
claim relies in part on Storable’s market share in the alleged FMS market,
because SafeLease argues that Storable is leveraging power in the FMS
market to gain market share in the market for tenant insurance. 2MR67–68.
Storable filed counterclaims, two of which are relevant to this petition.
The first counterclaim alleges tortious interference with Storable’s terms of
-2- service, which prohibit operators and their vendors from enabling
SafeLease’s method of access. 12MR264. The second counterclaim alleges
that SafeLease is illegally harvesting data about facilities and tenants from
Storable’s FMS. 12MR265. More details about this vigorous dispute are
provided in Storable’s Appellant’s Brief filed in Appeal No. 15-25-00020-CV,
which is a pending interlocutory appeal challenging a temporary injunction
SafeLease obtained in this case.
II. SafeLease Requested Production Of Storable’s Client List. SafeLease demanded that Storable produce “Documents sufficient to
show all self-storage facilities that use your facility management software,
including addresses for those facilities.” 11MR234–235.1 Storable objected
that producing the Client List would reveal confidential, commercially
sensitive information and violate the privilege against disclosure of trade
secrets. 11MR234–235; 21MR794–803.
Business Court Local Rule 4(d) states that a prerequisite for discovery
motions is that the parties file discovery letters limited to 700 words. The
parties each filed a discovery letter. 13MR; 15MR. SafeLease’s letter argued
1 SafeLease later adjusted this request to require identification of the FMS used at each facility but limit the request to facilities as of a certain date. The adjusted request is: “Documents sufficient to show all self-storage facilities that use your facility management software, including the City, State, ZIP, and FMS for those facilities, as of December 30, 2024.” 11MR277. All of the arguments in this Petition apply equally to both versions of this request.
-3- that the Client List “is critical for defining the relevant antitrust market and
assessing Storable’s market power and the competitive impact of its
conduct.” 13MR277.
To satisfy that purported need, Storable offered to provide information
sufficient to show the total number of facilities that use Storable’s FMS,
including a breakdown by state. 15MR285. Storable also offered mechanisms
to verify the accuracy of this information, including allowing SafeLease’s
economic expert to review the Client List while it remained in Storable’s
possession. 15MR285. SafeLease rejected these alternative methods of
achieving its purported need. 15MR285.
III. The Trial Court Ordered Storable To Produce The Client List. Rather than request that the parties brief a discovery motion, which
would have allowed space to develop arguments more fully, the trial court
ordered Storable to produce the Client List. 16MR290, 292. The ruling based
on the word limits under Rule 4(d) surprised Storable.
Storable filed a motion for reconsideration, supported by a declaration
and company handbook, establishing that the Client List is a protected trade
secret, that SafeLease had not met its burden to invade that protection, and
that the Protective Order does not moot the need for that protection.
-4- 21MR794–862. Storable also filed a motion requesting the trial court stay
the production deadline. 19MR.
The trial court set the motion for stay and motion for reconsideration
for written submission on June 12 at 2 p.m. and June 23, respectively. 22MR.
On June 12, the trial court stayed the production deadline until June 24.
25MR.
On June 23, 2025, the trial court signed an order titled “Order on
Motions for Reconsideration; Other Relief.” Appx. B, 32MR. This order
denied, without providing reasons, reconsideration of the Production Order
and reconsideration of Storable’s motion to modify the general protective
order so that it barred Adam Locke 2 from viewing documents designated
“outside counsel’s eyes only.” Id. This order prohibited Adam Locke from
viewing one specific document designated outside counsel eyes only—the
Client List. Id.
ARGUMENT I. Standard Of Review. “Mandamus relief is appropriate if the relator establishes a clear abuse
of discretion for which there is no adequate appellate remedy.” In re Durnin,
2 The issue of whether Adam Locke should be permitted to view produced documents is described below in Section IV.C. Mr. Locke was SafeLease’s general counsel at one time and states his role has changed to outside counsel.
-5- 619 S.W.3d 250, 252 (Tex. 2021). “If the information is a trade secret and the
requesting parties do not need it, an order that requires disclosure is a clear
abuse of discretion.” In re Union Pac. R. Co., 294 S.W.3d 589, 592 (Tex.
2009) (orig. proceeding).
II. Storable’s Customer List Is A Trade Secret. “A person has a privilege to refuse to disclose and to prevent other
persons from disclosing a trade secret owned by that person, unless the court
finds that non-disclosure will tend to conceal fraud or otherwise work
injustice.” TEX. R. EVID. 507(a). A trade secret is:
any formula, design, … or list of actual or potential customers … if: (A) the owner of the trade secret has taken reasonable measures under the circumstances to keep the information secret; and (B) the information derives independent economic value, actual or potential, from not being generally known to, and not being readily ascertainable through proper means by, another person who can obtain economic value from the disclosure or use of the information. TEX. CIV. PRAC. & REM. CODE § 134A.002(6) (emphasis added).
“Courts generally recognize that customer lists or financial information
that can be used to obtain customers or to negotiate pricing or fees to obtain
an advantage in the market qualifies as a trade secret.” Houston Livestock
Show & Rodeo, Inc. v. Dolcefino Commc’ns, LLC, 702 S.W.3d 675, 690 (Tex.
-6- App.—Houston [1st Dist.] 2024, no pet.). The subsections below show that
the Client List meets both the “reasonable measures” and “economic value”
elements of the definition of trade secret. 3
A. Storable Takes Reasonable Measures To Keep The Client List Secret. In a declaration submitted to the trial court, Storable’s CEO Chuck
Gordon details Storable’s efforts to maintain the secrecy of its Client List.
21MR807–809. This list does not exist as a standalone document and only
select few Storable employees have the ability to aggregate the data
underlying the Client List. Id. ¶ 5. The Client List exists only in electronic
format; no hard copies are created, and electronic versions of the list are not
created for any other purposes and thus are not disseminated outside of
Storable. Id.
Storable maintains strict privacy and security policies for its employees
to protect trade secrets and other proprietary materials, including those in
3 Before the effective date of this statute defining trade secret, the Texas Supreme Court stated: “To determine whether a trade secret exists, we weigh the six factors set forth in the Restatement of Torts in the context of the surrounding circumstances: (1) the extent to which the information is known outside of the business; (2) the extent to which it is known by employees and others involved in the business; (3) the extent of measures taken to guard the secrecy of the information; (4) the value of the information to the business and to its competitors; (5) the amount of effort or money expended in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others.” In re Union Pac. R. Co., 294 S.W.3d 589, 592 (Tex. 2009). It is not clear whether these factors are still relevant, but to the extent they are, the subsections below also establish these factors.
-7- electronic format such as client lists. Id. ¶ 6. For example, Storable provides
all of its staff with securely configured company laptops. 21MR837.
Storable’s employees are required to use their company-issued laptops for
their work and are strictly prohibited from conducting company business on
personal computers. Id.
While Storable allows employees to use personal smartphones to
access email and other business applications when they are not able to use
their company-issued laptops, employees are prohibited from saving
confidential company information on those personal devices. Id. Storable
provides its employees with guidelines to ensure that their use of those
devices for work is secure. 21MR837–838.
Storable takes security awareness among its employees seriously. Staff
members are required to undergo security awareness training at least twice
each year, and new hires are trained promptly upon starting. 21MR838.
Storable also conducts simulated “phishing” exercises to raise awareness
among employees regarding security practices; any employee who fails the
exercise is required to undergo remedial training. Id. Storable also regularly
publishes a security awareness newsletter. Id. These are reasonable
measures to maintain the secrecy of Storable’s trade secrets, including its
client lists. See, e.g., Reilly v. Premier Polymers, LLC, 2020 WL 7074253, at
-8- *5–6 (Tex. App.—Houston [14th Dist.] Dec. 3, 2020, pet. dism’d) (trade
secret found where party exercised information security practices including
password protection and access limitations).
B. The Client List derives economic value from its secrecy. The Client List is among Storable’s most competitively sensitive
secrets. 21MR808 ¶ 7. Even an inadvertent disclosure of part of the Client
List could threaten the core of Storable’s business. 21MR808 ¶ 11.
Much of the Client List’s value derives from the fact that the
information it contains is not publicly known or accessible. 21MR808 ¶ 9.
Storable developed the Client List through extensive efforts over years of
building its FMS customer base. 21MR808 ¶ 9. If disclosed, the Client List
would provide Storable’s competitors with thousands of potential customer
leads, nonpublic information regarding Storable’s presence in different
geographic areas, and other competitive intelligence. 21MR808 ¶ 9. In
addition, disclosure would make the Client List less valuable because the
facility and tenant clients would be subject to increased risk that competitors
will poach them after Storable put in the hard work of identifying those
clients and convincing them of the benefits of FMS and insurance.
21MR808 ¶ 9.
-9- The trial court overlooked the damage from disclosing the Client List
to SafeLease because it believed “SafeLease does not compete in the FMS
market.” 16MR291 n.2. This reasoning is inaccurate in three ways. First,
SafeLease admitted that it is actively encouraging clients to switch from
Storable’s FMS to other competitors’ FMS. 3MR90 (Feb. 13 Tr. 82:11-14).
Therefore, disclosing the Client List to SafeLease will destroy value Storable
created by keeping the Client List secret. Second, while SafeLease does not
compete against Storable directly in the FMS market, it draws approximately
70% of its insurance customers from Storable’s FMS customer pool. 4MR100
(Feb. 14 Tr. 28:17-21). SafeLease and Storable do compete for insurance
clients, so giving SafeLease access to Storable’s FMS client list would enable
SafeLease to directly target Storable’s clients. 21MR808 ¶¶ 8, 10. Third,
courts must protect trade secrets from disclosure even “in actions that are
not between business competitors” and are “subject to an appropriate
protective order.” In re Cont’l Gen. Tire, Inc., 979 S.W.2d 609, 613 (Tex.
1998).
C. Storable did not waive its trade secret privilege. Waiver is an “intentional relinquishment of a known right or
intentional conduct inconsistent with claiming that right.” Paxton v. City of
Dallas, 509 S.W.3d 247, 263 (Tex. 2017). “[T]he burden of proof is on the
-10- party relying on the waiver.” Lang v. Lee, 777 S.W.2d 158, 164 (Tex. App.—
Dallas 1989, no writ). Trade secret privilege is extraordinarily difficult to
waive. Even disclosure of the trade secret itself is not necessarily waiver.
HouseCanary, Inc. v. Title Source, Inc., 622 S.W.3d 254, 266 (Tex. 2021).
Storable has adequately preserved its trade secret privilege for the
Customer List by objecting in a response to the request for production, in a
pre-motion letter, and in the motion for reconsideration. Storble’s response
to SafeLease’s request to produce the Client List objected that the request
sought “confidential, proprietary, and commercially sensitive information of
the highest degree.” MR882–883. Storable’s response to SafeLease’s pre-
motion letter argued it should not have to produce the Client List because it
is “a highly confidential document—to a hostile competitor,” which describes
the trade secret privilege. 15MR285.
Asserting a privilege does not require “magic words.” Univ. of Tex. Sys.
v. Franklin Ctr. for Gov’l & Pub. Integrity, 675 S.W.3d 273, 285 (Tex. 2023).
Therefore, Storable was not required to use the magic words “trade secret”
to preserve when objecting to production of commercially sensitive
information, especially because customer lists are “generally recognize[d]”
as trade secrets. Houston Livestock Show & Rodeo, Inc. v. Delcefino
-11- Commc’ns, LLC, 702 S.W.3d 675, 690 (Tex. App.—Houston [1st Dist.] 2024,
no pet.).
III. SafeLease Did Not Prove That It Needs The Client List. “Trial courts should apply Rule 507 as follows: First, the party resisting
discovery must establish that the information is a trade secret. The burden
then shifts to the requesting party to establish that the information is
necessary for a fair adjudication of its claims.” In re Cont’l Gen. Tire, Inc.,
979 S.W.2d 609, 613 (Tex. 1998) (orig. proceeding). Necessary means
“essential” or something that “must exist or happen and cannot be avoided;
inevitable.” NECESSARY, Black’s Law Dictionary (12th ed. 2024).
To meet that burden, SafeLease “cannot merely assert unfairness but
must demonstrate with specificity exactly how the lack of the information
will impair the presentation of the case on the merits to the point that an
unjust result is a real, rather than a merely possible, threat.” In re
Bridgestone/Firestone, Inc., 106 S.W.3d 730, 732–33 (Tex. 2003) (orig.
proceeding). “The supreme court has made clear that this is an evidentiary
burden.” In re 4X Indus., LLC, 639 S.W.3d 801, 813 (Tex. App.—Houston
[14th Dist.] 2021, no pet.). Therefore, in 4X Industrial, the trial court abused
its discretion by ordering production of a trade secret because, while the
requesting party asserted that it could not prove its claim for trade secret
-12- misappropriation without production of trade secrets, the requesting party
failed to provide evidence of “specific facts” demonstrating “why the
requested documents from 4X Industrial are essential—as opposed to
helpful—to a fair adjudication.” Id. at 814; see also In re Diamond Shamrock
Ref. Co., L.P., No. 07-06-0315-CV, 2007 WL 63370, at *1 (Tex. App.—
Amarillo Jan. 10, 2007, no pet.) (holding the requesting party must prove
necessity “through the presentation of competent evidence. If it does not,
then compelling disclosure amounts to an instance of abused discretion
warranting mandamus relief”). SafeLease’s asserted “need” for the Client
List is inadequate for several reasons.
First, SafeLease has not explained why alternatives to producing the
Client List are insufficient for the purpose SafeLease articulated—calculating
Storable’s FMS market share. See Automatic Drilling Machines, Inc. v.
Miller, 515 S.W.2d 256, 260 (Tex. 1974) (holding the trial court abused its
discretion by ordering production of a trade secret without considering
alternatives). SafeLease failed to articulate why it could not calculate this
market share using the total number of facilitates using Storable’s FMS,
without the names and addresses of the individual facilities. SafeLease
vaguely argued that it must possess the Client List to “verify this
information,” 13MR277, but SafeLease provided no reason to believe that
-13- verification would be necessary or even feasible. Verification would require
subpoenaing all self-storage facilities in the world to determine if Storable
erroneously included or excluded them from the Client List. 4 Such an
outrageous process is not “necessary for a fair adjudication of its claims.” In
re Cont’l Gen. Tire, Inc., 979 S.W.2d 609, 613 (Tex. 1998) (orig. proceeding).
If SafeLease used the term “verification” to refer to scrutinizing the list itself,
that could be achieved by Storable’s offer to allow SafeLease’s economic
expert to analyze the Client List while it remains in Storable’s possession.
Third, even if SafeLease’s interest in the Client List were legitimate,
that interest may be mooted by Storable’s partial motion for summary
judgment, which challenges SafeLease’s attempted monopolization claim on
grounds unrelated to Storable’s alleged FMS market share. Potentially moot
information cannot be “necessary.” Storable’s motion for summary
judgment argues that SafeLease’s monopolization claim fails as a matter of
law because, among other reasons, Storable’s conduct is not anticompetitive,
Storable is not dangerously close to monopolizing the alleged tenant
insurance market, and Storable has no intent to monopolize that market.
4 It would not help SafeLease’s attempted-monopolization claim to determine that facilities were erroneously added to the Client List because each such determination would reduce Storable’s FMS market share.
-14- 17MR. The reply supporting this motion for summary judgment is due July
18.
IV. The Protective Order Does Not Negate The Risk Of Producing The Client List. The trial court ordered production of the Client List because the
Protective Order, which sets rules for confidentiality of all documents
produced in this case, allows Storable to designate the Client List “outside
counsel’s eyes only.” 16MR291; 6MR. This is insufficient because
confidentiality designations do not supersede trade secret protection, and
because the particular Protective Order in this case is currently subject to
challenges that may void it and have identified gaps in its protection.
A. Confidentiality designations do not supersede trade secret protection. “That a trial court has ordered the parties to enter into a protective
order with respect to trade secret information does not dispense with the
requesting party’s burden to establish the necessity for the discovery of the
trade secret information to fairly adjudicate a claim.” In re Hewlett Packard,
212 S.W.3d 356, 364 (Tex. App.—Austin 2006, no pet.); see also In re 4X
Indus., LLC, 639 S.W.3d 801, 814–15 (Tex. App.—Houston [14th Dist.] 2021,
no pet.) (collecting cases holding that a requesting party “must first show
that it met its burden” to prove necessity before a court should “address
whether the parties’ agreed protective order is sufficient to protect [the
-15- resisting party’s] trade secrets”); In re Waste Mgmt of Texas, Inc., 392
S.W.3d 861, 869 (Tex. App.—Texarkana 2013, no pet.). The Texas Supreme
Court relied on this rule to grant mandamus vacating an order requiring
production of a trade secret. In In re Union Pacific R. Co., 294 S.W.3d 589
(Tex. 2009). The court noted: “The trial court did enter an order restricting
those who could view the rate structures, but that alone does not ensure that
an order [to produce] will not violate the trade secret privilege.” Id. at 593.
This rule applies even when the protective order tightly restricts who
can view a produced document. “There is no authority that would allow a
trial court to order a party to produce privileged documents to the opposing
party’s attorney, even with the qualification that the documents be produced
for ‘attorney’s eyes only’ and subject to the parties’ protective order.” In re
Energy XXI Gulf Coast, Inc., No. 01-10-00371-CV, 2010 WL 5187730, at *8
(Tex. App.—Houston [1st Dist.] Dec. 23, 2010, no pet.) (orig. proc.); Tex. R.
Evid. 507(a) (describing trade secret protection as a “privilege to refuse to
disclose”).
B. SafeLease may later argue that the Protective Order is void. Storable filed a separate appeal from the same case (Appeal No. 15-25-
00020-CV). In that appeal, Storable argues that the trial court was required
to remand this case to the district court before signing any orders because
-16- SafeLease untimely filed its notice of removal. See Appellant’s Br. Argument
Section I. If Storable prevails on that issue, SafeLease may argue that the
Protective Order is void or not enforceable by the business court that issued
it, which might endanger any trade secrets relying on the Protective Order.
C. SafeLease has shown there is a material risk that it will circumvent the Protective Order. “[T]he trial court should consider any potential inadequacies of the
protective order in weighing the competing interests of the parties under
Rule 507. … This is especially true when the trial court has specific, fact-
based grounds for believing that trade secrets may be disclosed in violation
of its protective order.” In re Cont’l Gen. Tire, Inc., 979 S.W.2d 609, 614 (Tex.
Several facts indicate that trade secrets might be used for SafeLease’s
business purposes despite the Protective Order. First, SafeLease has been
sharing “Outside Counsel’s Eyes Only” documents with Adam Locke, who as
recently as June 2023 served as SafeLease’s “Chief Operating Officer and
General Counsel.” 8MR169.5 Second, SafeLease has repeatedly
circumvented Storable’s security measures, including through creating
5 Today the trial court ordered that Adam Locke may not view the Client List, 32MR1077, but that does not negate the point that SafeLease has shared confidential information with Adam Locke and planned to share the Client List with him until ordered to desist.
-17- alternative user accounts and through using bots to emulate customers.6 For
example, SafeLease’s petition admits SafeLease “was able to engineer a
solution to restore access” to Storable’s FMS after Storable’s security
initiative blocked SafeLease’s access. 2MR62. This cavalier attitude toward
security safeguards shows that the Protective Order will not ensure that the
Client List stays secret if SafeLease obtains it. Third, the Protective Order
allows documents designated “Outside Counsel’s Eyes Only” to be shared
with vendors and “potential” independent experts or consultants and their
staff. 6MR109–110. These third parties may remain outside of the trial
court’s contempt power to enforce the Protective Order.
V. Storable Has No Adequate Remedy By Appeal. A party has no adequate remedy by appeal if it is improperly ordered
to produce a trade secret. In re Cont’l Gen. Tire, Inc., 979 S.W.2d 609, 615
(Tex. 1998); see also In re Bass, 113 S.W.3d 735, 745 (Tex. 2003) (granting
mandamus because “no adequate appellate remedy exists if a trial court
orders a party to produce privileged trade secrets absent a showing of
necessity”); In re Union Pac. R. Co., 294 S.W.3d 589, 593 (Tex. 2009)
(similar).
6 This behavior, and the evidence showing it (including SafeLease’s admissions), is described in Appeal No. 15-25-00020-CV, in Appellant’s Brief pages 5–6, 58–59.
-18- Once Storable produces the Client List, the trade secret will be exposed
and may be irretrievably disseminated regardless of whether Storable
prevails on appeal after a final judgment. “After the [privileged documents]
had been inspected, examined and reproduced ... a holding that the court had
erroneously issued the order would be of small comfort to relators.” Walker
v. Packer, 827 S.W.2d 833, 843 (Tex. 1992) (alterations in original). For this
reason, it is well-settled that mandamus is the proper remedy for a discovery
order that compels production beyond what is permissible. In re Shipman,
540 S.W.3d 562, 565 (Tex. 2018) (orig. proceeding) (per curiam).
PRAYER For these reasons, Relators request that this Court grant this petition
for writ of mandamus and vacate the Production Order. Relators also pray
for such further relief, in law or equity, to which they may be entitled.
-19- Respectfully submitted, GREENBERG TRAURIG, LLP By: /s/Dale Wainwright______ Dale Wainwright State Bar No. 00000049 dale.wainwright@gtlaw.com Justin Bernstein State Bar No. 24105462 justin.bernstein@gtlaw.com 300 West 6th Street, Suite 2050 Austin, Texas 78701 T: (512) 320-7200 F: (512) 320-7210
RULE 52.3(J) CERTIFICATION In compliance with Rule 52.3(j) of the Texas Rules of Appellate
Procedure, I certify that I have reviewed the Petition for Writ of Mandamus
and have concluded that every factual statement in the petition is supported
by competent evidence included in the appendix or record.
/s/ Justin Bernstein Justin Bernstein
-20- CERTIFICATE OF COMPLIANCE This brief complies with the length limitations of TEX. R. APP. P.
9.4(i)(2) because this brief consists of 4,076 words as determined by
Microsoft Word Count, excluding the parts of the petition exempted by TEX.
R. APP. P. 9.4(i)(1).
-21- CERTIFICATE OF SERVICE I certify that a copy of the foregoing document was served on counsel of record by using the Court’s CM/ECF system on the 23rd day of June 2025, addressed as follows:
STONE HILTON PLLC
Judd E. Stone II State Bar No. 2407670 judd@stonehilton.com Christopher D. Hilton State Bar No. 24087727 600 Congress Ave., Austin, Texas 78701 T: (737) 465-7248
YETTER COLEMAN LLP
R. Paul Yetter State Bar No. 22154200 pyetter@yettercoleman.com Susanna R. Allen State Bar No. 24126616 sallen@yettercoleman.com Luke A. Schamel State Bar No. 24106403 lschamel@yettercoleman.com Shannon N. Smith State Bar No. 24110378 ssmith@yettercoleman.com 811 Main Street, Suite 4100 Houston, Texas 77002 T: (713) 632-8000
COUNSEL FOR REAL PARTY
-22- I also certify that a copy of the foregoing document will be served by email on Respondent on the 23rd day of June 2025, addressed as follows:
Honorable Melissa Andrews Third Division of the Texas Business Court Herman Marion Sweatt Courthouse Courtroom 421 1000 Guadalupe St. Austin, Texas 78701 BCDivision3A@txcourts.gov
-23- APPENDIX
Tab A The trial court’s May 28, 2025 order to produce the Client List
Tab B The trial court’s June 23, 2025 order denying Storable’s motion to reconsider the Production Order
-24- Appendix A FILED IN BUSINESS COURT OF TEXAS BEVERLY CRUMLEY, CLERK ENTERED 5/28/2025
The Business Court of Texas, Third Division
SAFELEASE INSURANCE § SERVICES LLC, § Plaintiff, § § v. § Cause No. 25-BC03A-0001 STORABLE, INC., et al., § § Defendants. § ═══════════════════════════════════════ Discovery Order ═══════════════════════════════════════
Before the Court is plaintiff SafeLease’s discovery-dispute letter, filed under
Business Court Local Rule 4(d), and the response letter filed by defendants
(collectively, Storable). SafeLease seeks, and Storable resists, production of
documents responsive to SafeLease’s requests for production (RFPs) numbers 10,
12, and 20. The Court ORDERS as follows:
RFP 10: Storable is ORDERED to produce documents sufficient to show the
name, city, state, and zip code of all self-storage facilities using Storable’s FMS
platforms as of December 30, 2024. Storable asserts that its customer list with addresses is “a highly confidential
document” 1 and that SafeLease is “a hostile competitor with whom Storable is in
litigation.” 2 The agreed protective order in this case contains “confidential” and
“outside counsel’s eyes only” (OCEO) designations, both available to Storable to
protect its confidential information as appropriate. Because the parties previously
disputed whether certain counsel should have access to OCEO material, the Court
directs them to Westlake Longview Corp. v. Eastman Chemical Co., 2025 Tex. Bus.
19, for guidance on the evidentiary standards applicable to such disputes. 3
RFP 12: Storable is ORDERED to either (a) produce documents sufficient to
show all authorized users on storEDGE and SiteLink as of December 30, 2024 or
(b) amend its RFP 12 response to state that no responsive documents exist and give
the number of authorized users on storEDGE and SiteLink on December 30, 2024.
Storable states that “no [] documents exist” that are responsive to RFP 12, it
“does not maintain lists of authorized users,” and it will amend its discovery
responses “to reflect that no responsive documents exist.” If that is the case,
amending the discovery responses is sufficient. Storable is correct that it is not
1 Storable did not assert that the information at issue constitutes a trade secret. 2 While SafeLease may be a competitor of Storable’s insurance affiliates, the customer list at issue is for Storable’s FMS customers. SafeLease does not compete in the FMS market. 3 The Westlake decision addresses access for in-house counsel but notes that federal courts have applied the same test for both outside and in-house lawyers. Westlake, 2025 Tex. Bus. 19 at n.16.
2 obligated to create a document that does not exist in response to this RFP.
The Court notes, however, that RFP 12 is not limited to a list of authorized
users and “documents” is broadly defined to include not just physical files but also,
for example, electronic data. 4 If Storable has data that shows the authorized users
on storEDGE and SiteLink as of December 30, 2024, Storable need not process such
data to create a list for SafeLease but must produce the data (subject to privilege). 5
The Court raises this because Storable offered “to produce the total number of
authorized users and information showing whether other tenant insurance providers
have authorized users,” and it is plausible that the data from which Storable would
derive that information would be responsive to RFP 12.
RFP 20: Storable is ORDERED to produce documents evidencing the specific
security measures it took that affected SafeLease’s access to Storable’s FMS, other
than computer code, and when it took such measures.
This reflects SafeLease’s offer to limit its request to exclude computer code
and Storable’s offer to produce “documents sufficient to show the specific security
measures that affected SafeLease and when it took those measures.”
Storable is ORDERED to comply with this order by June 13, 2025.
4 Under the parties’ agreed ESI protocols, electronic data should be produced in TIF format. 5 Storable need not produce data that is duplicative—only data that is “sufficient to show” the authorized users on the given date.
3 Date signed: May 28, 2025
Hon. Melissa Andrews Judge of the Texas Business Court, Third Division
4 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Envelope ID: 101329629 Filing Code Description: No Fee Documents Filing Description: Discovery Order Status as of 5/28/2025 12:43 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Ray TTorgerson rtorgerson@porterhedges.com 5/28/2025 12:37:00 PM SENT
Delonda Dean ddean@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Yetter Coleman efile@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Carolyn Reed creed@porterhedges.com 5/28/2025 12:37:00 PM SENT
Courtney Smith csmith@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Melissa Sanchez Melissa.Sanchez@arnoldporter.com 5/28/2025 12:37:00 PM SENT
Edockets Calendaring eDocketsCalendaring@arnoldporter.com 5/28/2025 12:37:00 PM SENT
Andrew Bergman andrew.bergman@arnoldporter.com 5/28/2025 12:37:00 PM SENT
Elizabeth FEoff leoff@porterhedges.com 5/28/2025 12:37:00 PM SENT
Katherine G.Treistman Katherine.Treistman@arnoldporter.com 5/28/2025 12:37:00 PM SENT
Luke A.Schamel lschamel@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Christopher Hilton chris@stonehilton.com 5/28/2025 12:37:00 PM SENT
Judd Stone Judd@stonehilton.com 5/28/2025 12:37:00 PM SENT
Alyssa Smith asmith@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Bonnie Chester bonnie@stonehilton.com 5/28/2025 12:37:00 PM SENT
Jonna NSummers jsummers@porterhedges.com 5/28/2025 12:37:00 PM SENT
Lakshmi NKumar lkumar@porterhedges.com 5/28/2025 12:37:00 PM SENT
R. PaulYetter pyetter@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Susanna R.Allen sallen@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Justin Bernstein bernsteinju@gtlaw.com 5/28/2025 12:37:00 PM SENT
Business Court Division 3A bcdivision3a@txcourts.gov 5/28/2025 12:37:00 PM SENT
Dolores Brunelle dbrunelle@porterhedges.com 5/28/2025 12:37:00 PM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.
Envelope ID: 101329629 Filing Code Description: No Fee Documents Filing Description: Discovery Order Status as of 5/28/2025 12:43 PM CST
Dolores Brunelle dbrunelle@porterhedges.com 5/28/2025 12:37:00 PM SENT
Cathy Hodges catherine.hodges@aporter.com 5/28/2025 12:37:00 PM SENT
Mikaila Skaroff mikaila.skaroff@arnoldporter.com 5/28/2025 12:37:00 PM SENT
Rosalinda Luna rosie@stonehilton.com 5/28/2025 12:37:00 PM SENT
Adam Locke adam@lockelaw.com 5/28/2025 12:37:00 PM SENT
Alexander Dvorscak alex@stonehilton.com 5/28/2025 12:37:00 PM SENT
Shannon Smith ssmith@yettercoleman.com 5/28/2025 12:37:00 PM SENT
Dale Wainwright dale.wainwright@gtlaw.com 5/28/2025 12:37:00 PM SENT
Julia C.Risley jrisley@yettercoleman.com 5/28/2025 12:37:00 PM SENT Appendix B ÿjklm ÿÿÿÿÿÿÿÿnollÿ ÿÿÿÿÿÿÿÿdefghÿeiruÿtovwl qrkstÿ ÿÿyz{z|} ÿÿÿÿÿÿÿÿÿÿÿÿÿÿÿ~ÿ |} z~ÿ}z| ÿÿÿÿÿÿÿÿÿÿ
ÿ 123ÿ56789377ÿ 6 ÿÿ137ÿ 128ÿ88789ÿ ÿ ÿ 7ÿÿ ÿ ÿ 7ÿÿ !"#$%&$''(ÿ 7ÿÿ *+ÿ 7ÿÿ 7ÿ 189/ÿ:+ÿ;<=. >?=>>>@ÿ ,- .ÿ +ÿ/0ÿ12+ÿ 7ÿ 34'4%5#%&6+ÿ 7ÿ 7ÿ AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAÿ B 3ÿ9ÿC 897ÿ ÿD3E978389FÿB 23ÿD3G83ÿ AAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAAÿ ÿ ./H:I/ÿ0J/ÿ :8I0ÿ1I/ÿ0:I1K2/L9ÿM:0N:OÿH:Iÿ /P:O9NQ/I10N:Oÿ:Hÿ0J/ÿ :8I0L9ÿ RIN2ÿ@<ÿ;>;<ÿ-IQ/IÿS/OTNOUÿM:QNHNP10N:Oÿ:Hÿ0J/ÿVI:0/P0N*/ÿ-IQ/Iÿ1OQÿ0:I1K2/L9ÿ M:0N:OÿH:IÿV1I0N12ÿ /P:O9NQ/I10N:Oÿ:Hÿ0J/ÿ :8I0L9ÿM1Tÿ;Wÿ;>;<ÿSN9P:*/ITÿ-IQ/Iÿ XP:22/P0N*/2Tÿ0J/ÿM:0N:O9Y+ÿ,J/ÿ :8I0ÿZ[\Z]ÿK:0JÿM:0N:O9ÿK80ÿ/2/P09ÿ0:ÿRI:*NQ/ÿ 0:I1K2/ÿ^N0Jÿ:0J/IÿI/2N/HÿQ/01N2/QÿK/2:^+ÿ,J/ÿ :8I0ÿ0J/I/H:I/ÿBDZD]ÿ19ÿH:22:^9_ÿ @+ÿ ,J/ÿP890:a/IÿNOH:Ia10N:OÿI/b8/90/QÿNOÿ1H//19/L9ÿ /b8/90ÿH:Iÿ VI:Q8P0N:OÿX VYÿ:+ÿ@>ÿb812NHN/9ÿH:Iÿ- -ÿRI:0/P0N:Oÿ8OQ/Iÿ0J/ÿUI//QÿVI:0/P0N*/ÿ -IQ/IÿNOÿ0JN9ÿP19/+ÿ ÿ ÿ ÿ ÿ 23ÿ 567ÿ9 796 ÿ6ÿ67ÿ976 6ÿÿ7 96 ÿ6ÿ5ÿ63ÿ ÿ6 ÿ 73ÿ6!ÿ"ÿÿ#ÿ76$ÿ%ÿ67 ÿ6ÿ767ÿ97$ÿ6ÿ&"ÿ'()'ÿ $7ÿ7ÿ%ÿ*+7 ÿ76&ÿ'773ÿÿ ,3ÿ 567ÿÿ6%7ÿ'()'ÿ$7 ÿ 73ÿ6!ÿ$ ÿ6 ÿ6ÿ%&ÿ ÿÿ ÿ67 ÿ6ÿ767ÿÿ%ÿ 3ÿÿ -3ÿ (6ÿ"%ÿ%ÿ6 7ÿÿ%ÿ 7%ÿ2. ÿ2 2/ÿ7 ÿ 73ÿ6!ÿ$ ÿ 7 7ÿ76$ÿ979+ÿÿ ÿ 7ÿ ÿ+66ÿ" ÿ ÿ ÿ67ÿ%ÿ7ÿ6 ÿ%ÿ6#ÿ6ÿ+ÿ9 ÿ67ÿ96ÿ $ ÿ 6ÿ+ÿ9 ÿ ÿÿ97 ÿ+7 ÿ6%7" 3ÿ ÿ 0ÿ+1ÿ2 ÿ2, ÿ2 2/3ÿ ÿ
ÿ 363ÿ ÿ*7" ÿ 2 +ÿ6ÿ%ÿ4 #ÿ5 ÿ(6 7 ÿ 4%7ÿ0&6ÿ
ÿ ÿ4%ÿ976ÿÿ6ÿ" ÿ7 ÿ6ÿ%ÿ+7 ÿ67ÿ976 6$ÿ6ÿ 73ÿ6! ÿ"%%ÿ%ÿ (6 7ÿ6 ÿ6ÿ6 63ÿÿ 1ÿ 012 345 267ÿ96 2 526ÿ3ÿ66 6 ÿÿ ÿ ÿ ÿÿ ÿ!"ÿÿ #$%ÿ"& '( ) ÿ+ ,-) .ÿ/ ) . 0 ) 1 ÿ2 ( , / ÿ1 3 45 6) 7 2 ÿ0, 8ÿ)68,- ÿ9) 7 ).82)1ÿ : ;ÿ2( ) ÿ ) + ,- ,79ÿ/;/2 )6 P
xy z {|} ~{ÿ ÿ ÿÿ ¢£¤¥¦ÿ §¨©ªÿ«¦ ¬£¦ÿÿ ©ÿÿ ©¨ÿ© ¤ÿ̈© ÿ®£¥©¤¬£¦ ¯°±°²³ÿ±³ÿµ¶ÿ·¹̧º¹̧»¹¼ÿ½»¾¼¿ÿÀÁÿ¯à ÄÅÆÇÿÄÉÊËÅÌËÆ ÍÎÏÐ ÓÔÕÖ×ØÙÚÕ ÛÜÝÞß 01234562789:21553; Z[\[]^ ÑÒÓÿÕÕÖ×ØÙ×ÚÖÛ àáâàãäàåâæçèâàáäàéäêãäåëìâí <=>?=>@>AÿC@DEFD>AÿGH _`ab ÜÝÞßàáâÿÜÝâà îîïðñòóïôôïõö÷øïùðñúö÷ù IJKLJKMKNÿPMQRSQKNÿTU cdef äåææåçÿéêëåìíî ûüýþûÿ0û11û234þû5678345 VWXYWXZX[ÿ]Z^_`^X[ÿab ghij ïðñòóôõÿ÷øøù 9 9 cdefdegehÿjgklmkehÿno klmn úûüýþÿ01ÿ345þ6 ! "#$ pqrsqrtruÿwtxyzxruÿ{| opqr 789 ÿ 8 %&'())*+,*-./&01*2-3'45326&2+.37 }~~ÿÿ stuv ÿ ! " 89:;<8=>?@A8BC@DEBFG@DB:ACH:D=8DI;:J ÿÿ wxyz #$%&'(ÿ*'&+,-$ KLMNOPQRONSTKLUKNLVWMXVNYONQZVT ÿ¡ÿ¢£ {|}~ ./0123456ÿ8.9:: [\]^^_`]ab\ac\de\fgh]i ¤¥¦§¥¦¨¦©ÿ«¨¬®¬¦©ÿ̄° ;<=>?@AB?ÿDEF@?AG=H? «¬® º»¼½¾¿¼¼ÿÁ»ÃÄÿŽƽ¼½Â¾ÿÇÈ @ABCABDBEÿGDHIJHBEÿKL ¯°±² ÉÊËÊÌÍÎÿÐÌÑÒÍËËÍ !"#$%%$&'(!)$!*$ +$,-.(/ MNOPNOQORÿTQUVWUORÿXY ³´µ¶ 012 345 267ÿ96 2 526ÿ3ÿ66 6 ÿÿ ÿ ÿ ÿÿ ÿ!"ÿÿ #$%ÿ"& '( ) ÿ+ ,-) .ÿ/ ) . 0 ) 1 ÿ2 ( , / ÿ1 3 45 6) 7 2 ÿ0, 8ÿ)68,- ÿ9) 7 ).82)1ÿ : ;ÿ2( ) ÿ ) + ,- ,79ÿ/;/2 )6 P
xy z {|} ~{ÿ ÿ ÿÿ ¢£¤¥¦ÿ §¨©ªÿ«¦ ¬£¦ÿÿ ©ÿÿ ©¨ÿ© ¤ÿ̈© ÿ®£¥©¤¬£¦ ¯°±°²³ÿ±³ÿµ¶ÿ·¹̧º¹̧»¹¼ÿ½»¾¼¿ÿÀÁÿ¯à ÄÅÆÇÿÄÉÊËÅÌËÆ ÍÎÏÎÐÑÒÿÔÐÕÖÑÏÏÑ <=>?@ABBACDE>FA>GAÿ@=ABCA;>ÿDE stuv 01234ÿ678392:; ÂÃÄÅÆÇÈÉÈÇÊÊÇÃËÌÆÇÍÎÏÐËÌÍ FGHIGHJHKÿMJNOPNHKÿQR wxyz