INI, LLC v. MMAD Games, LLC and Imagination Gaming Inc.

CourtDistrict Court, C.D. California
DecidedNovember 17, 2025
Docket2:25-cv-04685
StatusUnknown

This text of INI, LLC v. MMAD Games, LLC and Imagination Gaming Inc. (INI, LLC v. MMAD Games, LLC and Imagination Gaming Inc.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
INI, LLC v. MMAD Games, LLC and Imagination Gaming Inc., (C.D. Cal. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3

4 INI, LLC, Case No. 25-cv-4685 5 Plaintiff, 6 STIPULATED PROTECTIVE v. 7 ORDER1

8 MMAD Games, LLC and

Imagination 9 Gaming Inc., 10 11 Defendants. 12 MMAD Games, LLC and 13 Imagination 14 Gaming Inc., Counterclaimants, 15 v. 16

17 INI, LLC, 18 Counter- 19 Defendant. 20

21 22 1. INTRODUCTION 23 1.1 Purposes and Limitations. Discovery in this action is likely to 24 involve production of confidential, proprietary, or private information for 25 26 27 1 This Stipulated Protective Order is substantially based on the model protective order provided under Magistrate Judge Stephanie S. 1 which special protection from public disclosure and from use for any 2 purpose other than prosecuting this litigation may be warranted. 3 Accordingly, the parties hereby stipulate to and petition the court to 4 enter the following Stipulated Protective Order. The parties 5 acknowledge that this Order does not confer blanket protections on all 6 disclosures or responses to discovery and that the protection it affords 7 from public disclosure and use extends only to the limited information or 8 items that are entitled to confidential treatment under the applicable 9 legal principles. 10 1.2 Good Cause Statement. : 11 This action is likely to involve trade secrets, customer and pricing 12 lists and other valuable research, development, commercial, financial, 13 technical and/or proprietary information for which special protection 14 from public disclosure and from use for any purpose other than 15 prosecution of this action is warranted. Such confidential and 16 proprietary materials and information consist of, among other things, 17 confidential business or financial information, information regarding 18 confidential business practices, or other confidential research, 19 development, or commercial information (including information 20 implicating privacy rights of third parties), information otherwise 21 22 generally unavailable to the public, or which may be privileged or 23 otherwise protected from disclosure under state or federal statutes, court 24 rules, case decisions, or common law. Accordingly, to expedite the flow of 25 information, to facilitate the prompt resolution of disputes over 26 confidentiality of discovery materials, to adequately protect information 27 the parties are entitled to keep confidential, to ensure that the parties 1 for and in the conduct of trial, to address their handling at the end of the 2 litigation, and serve the ends of justice, a protective order for such 3 information is justified in this matter. It is the intent of the parties that 4 information will not be designated as confidential for tactical reasons 5 and that nothing be so designated without a good faith belief that it has 6 been maintained in a confidential, non-public manner, and there is good 7 cause why it should not be part of the public record of this case. 8 1.3 Acknowledgment of Procedure for Filing Under Seal. The 9 parties further acknowledge, as set forth in Section 12.3, below, that this 10 Stipulated Protective Order does not entitle them to file confidential 11 information under seal; Local Rule 79-5 sets forth the procedures that 12 must be followed and the standards that will be applied when a party 13 seeks permission from the court to file material under seal. 14 There is a strong presumption that the public has a right of access 15 to judicial proceedings and records in civil cases. In connection with 16 non-dispositive motions, good cause must be shown to support a filing 17 under seal. See Kamakana v. City and Cnty. of Honolulu, 447 F.3d 18 1172, 1176 (9th Cir. 2006), Phillips ex rel. Ests. of Byrd v. Gen. Motors 19 Corp., 307 F.3d 1206, 1210–11 (9th Cir. 2002), Makar-Welbon v. Sony 20 Elecs., Inc., 187 F.R.D. 576, 577 (E.D. Wis. 1999) (even stipulated 21 22 protective orders require good cause showing), and a specific showing of 23 good cause or compelling reasons with proper evidentiary support and 24 legal justification, must be made with respect to Protected Material that 25 a party seeks to file under seal. The parties’ mere designation of 26 Disclosure or Discovery Material as CONFIDENTIAL does not— 27 without the submission of competent evidence by declaration, 1 confidential, privileged, or otherwise protectable—constitute good cause. 2 Further, if a party requests sealing related to a dispositive motion 3 or trial, then compelling reasons, not only good cause, for the sealing 4 must be shown, and the relief sought shall be narrowly tailored to serve 5 the specific interest to be protected. See Pintos v. Pac. Creditors Ass’n, 6 605 F.3d 665, 677–79 (9th Cir. 2010). For each item or type of 7 information, document, or thing sought to be filed or introduced under 8 seal in connection with a dispositive motion or trial, the party seeking 9 protection must articulate compelling reasons, supported by specific 10 facts and legal justification, for the requested sealing order. Again, 11 competent evidence supporting the application to file documents under 12 seal must be provided by declaration. 13 Any document that is not confidential, privileged, or otherwise 14 protectable in its entirety will not be filed under seal if the confidential 15 portions can be redacted. If documents can be redacted, then a redacted 16 version for public viewing, omitting only the confidential, privileged, or 17 otherwise protectable portions of the document, shall be filed. Any 18 application that seeks to file documents under seal in their entirety 19 should include an explanation of why redaction is not feasible. 20

21 22 2. DEFINITIONS 23 2.1 Action: This pending federal lawsuit. 24 2.2 Challenging Party: a Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 2.3 “CONFIDENTIAL” Information or Items: information 27 (regardless of how it is generated, stored or maintained) or tangible 1 things that qualify for protection under Rule 26(c) of the Federal Rules of 2 Civil Procedure, and as specified above in the Good Cause Statement. 3 2.4 Counsel: Outside Counsel of Record (as well as their support 4 staff). 5 2.5 Designating Party: a Party or Non-Party that designates 6 information or items that it produces in disclosures or in responses to 7 discovery as “CONFIDENTIAL.” 8 2.6 Disclosure or Discovery Material: all items or information, 9 regardless of the medium or manner in which it is generated, stored, or 10 maintained (including, among other things, testimony, transcripts, and 11 tangible things), that are produced or generated in disclosures or 12 responses to discovery in this matter. 13 2.7 Expert: a person with specialized knowledge or experience in 14 a matter pertinent to the litigation who has been retained by a Party or 15 its counsel to serve as an expert witness or as a consultant in this Action. 16 2.8 Final Disposition: the later of (1) dismissal of all claims and 17 defenses in this Action, with or without prejudice; and (2) final judgment 18 herein after the completion and exhaustion of all appeals, rehearings, 19 remands, trials, or reviews of this Action, including the time limits for 20 filing any motions or applications for extension of time pursuant to 21 22 applicable law. 23 2.9 Non-Party: any natural person, partnership, corporation, 24 association, or other legal entity not named as a Party to this action. 25 2.10 Outside Counsel of Record: attorneys who are not employees 26 of a party to this Action but are retained to represent or advise a party to 27 this Action and have appeared in this Action on behalf of that party or 1 appeared on behalf of that party, and includes support staff.

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Related

Pintos v. PACIFIC CREDITORS ASS'N
605 F.3d 665 (Ninth Circuit, 2010)
Knight v. Spencer
447 F.3d 6 (First Circuit, 2006)
Makar-Wellbon v. Sony Electronics, Inc.
187 F.R.D. 576 (E.D. Wisconsin, 1999)

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INI, LLC v. MMAD Games, LLC and Imagination Gaming Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ini-llc-v-mmad-games-llc-and-imagination-gaming-inc-cacd-2025.