Seattle Cell Market, LLC v. M. Segue Corporation

Opinion

} UMBERG ZIPSER LLP WOLF, RIFKIN, SHAPIRO, SCHULMAN > || Mark A. Finkelstein (SBN 173851) & RABKIN, LLP ~ || mfinkelstein@uzllp.com Matthew Oster (SBN 190541) Ellen S. Kim (SBN 329348) moster@wrslawyers.com ekim@uzllp.com Paulo A. de Almeida (SBN 279168) 1920 Main Street, Suite 750 pdealmeida@wrslawyers.com Irvine, California 92614 11400 W Olympic Blvd., 9" FI. Telephone: (949) 679-0052 Los Angeles, CA 90064 Facsimile: (949) 679-0461 Telephone: (310) 478-4100 g || Attorneys for Plaintiff Attorneys for Defendant SEATTLE CELL MARKET, LLC M. SEGUE CORPORATION SEATTLE CELL MARKET, LLC, Case No. 2:25-cv-06165-JFW (Ex) Plaintiff, Assigned to: Hon. Charles F. Eick Vs. DISCOVERY MATTER M. SEGUE CORPORATION, JOINT STIPULATION AND }PROPOSED] PROTECTIVE Defendant. ORDER CASE NO. 2:25-CVv-06165-JFW (EX) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

1. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than pursuing this litigation may be warranted. Accordingly, Plaintiff Seattle Cell Market, LLC (“Plaintiff or “SCM”’), on the one )hand, and Defendant M. Segue Corporation (“Defendant” or “Segue”), on the other hand (collectively, the “Parties”), hereby stipulate to and petition the Court to enter this Stipulated Protective Order (“Protective Order” or the ““Order’”). The Parties acknowledge that this Order does not confer blanket protections on all disclosures or /responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential ! treatment under the applicable legal principles. Further, as set forth in Sections 3 and 14.3 below, this Protective Order does not entitle the Parties to file confidential information under seal. Rather, when the Parties seek permission from the court to file material under seal, the Parties must comply with Civil Local Rule 79-5 and with any pertinent orders of the assigned District Judge and Magistrate Judge. 2 GOOD CAUSE STATEMENT This action 1s likely to involve highly sensitive financial information, customer or supplier identifiers, and pricing lists and other valuable research, development, commercial, financial, technical and/or proprietary information for which special protection from public disclosure and from use for any purpose other than prosecution of this action is warranted. Such confidential and proprietary materials and information consist of, among other things, the parties’ respective customer or supplier identifying information, sales and revenue data, business decisions, internal company communications, pricing lists, confidential business or financial information, information regarding confidential business practices, or other confidential research, development, or commercial information (including information implicating privacy

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rights of third parties), information otherwise generally unavailable to the public, or 2 which may be privileged or otherwise protected from disclosure under state or federal 3 statutes, court rules, case decisions, or common law. Accordingly, to expedite the 4 flow of information, to facilitate the prompt resolution of disputes over confidentiality 5 of discovery materials, to adequately protect highly sensitive information the parties 6 /are entitled to keep confidential (public disclosure of which would risk harming their 7 competitive positions in their industries and could also result in reputational harm), to 8 ensure that the parties are permitted reasonable necessary uses of such material in 9 preparation for and in the conduct of trial, to address their handling at the end of the litigation, and to serve the ends of justice, a protective order for such information is justified in this matter. It is the intent of the Parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case. 3. ACKNOWLEDGMENT OF UNDER SEAL FILING PROCEDURE The Parties acknowledge, as also set forth Section 14.3 below, that this Protective Order does not entitle them to file confidential information under seal. When the Parties seek permission from the court to file material under seal, the Parties )must comply with Civil Local Rule 79-5 and with any pertinent orders of the assigned District Judge and Magistrate Judge. There is a strong presumption that the public has a right of access to judicial proceedings and records in civil cases. See Kamakana v. City and County of Honolulu, 447 F.3d 1172, 1178-79 (9th Cir. 2006). To overcome this presumption, a specific showing of good cause or compelling reasons with proper evidentiary support and legal justification must be made with respect to Protected Material that a party seeks to file under seal. See Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 1097 (9th Cir. 2016). The Parties’ mere designation of Disclosure or Discovery

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| || Material as CONFIDENTIAL does not—without the submission of competent 2 evidence by declaration, establishing that the material sought to be filed under seal 3 qualifies as confidential, privileged, or otherwise protectable—constitute good cause. 4 Further, if a party requests sealing, the relief sought shall be narrowly tailored to serve 5 the specific interest to be protected. 6 Any document that is not confidential, privileged, or otherwise protectable in its 7 entirety will not be filed under seal if the confidential portions can be redacted. If 8 documents can be redacted, then a redacted version for public viewing, omitting only 9 the confidential, privileged, or otherwise protectable portions of the document, shall / be filed. Any application that seeks to file documents under seal in their entirety should include an explanation of why redaction is not feasible. 4. DEFINITIONS 4.1 Action: The instant federal lawsuit, styled as Seattle Cell Market, LLC v. M. Segue Corporation, Case No. 2:25-cv-06165-JFW (Ex). 4.2 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order. 4.3. “CONFIDENTIAL” and “ATTORNEYS’ EYES ONLY” Information or Items: information (regardless of how it is generated, stored or maintained) or tangible ! things that qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified above in the Good Cause Statement. 4.4 Counsel: Outside Counsel of Record and House Counsel (as well as their support staff). 4.5 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” 4.6 Disclosure or Discovery Material: all items or information, regardless of !the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or

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! || generated in disclosures or responses to discovery. 4.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this Action. 4.8 House Counsel: attorneys who are employees of a party to this Action. House Counsel does not include Outside Counsel of Record or any other outside ) counsel. 4.9 Non-Party: any natural person, partnership, corporation, association or other legal entity not named as a Party to this action. 4.10 Qutside Counsel of Record: attorneys who are not employees of a party to this Action but are retained to represent a party to this Action and have appeared in this Action on behalf of that party or are affiliated with a law firm that has appeared on behalf of that party, and includes support staff. 4.11 Producing Party: a Party or Non-Party that produces Disclosure or } Discovery Material in this Action. 4.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors. 4.13 Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL” or ‘ATTORNEYS’ EYES ONLY.”” 4.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party. 5. SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties —_.JTWT———————* "Sissons oy ne WD JOINT STIPULATION AND PROPOSED] PROTECTIVE ORDER

1 or their Counsel that might reveal Protected Material. 2 Any use of Protected Material during a court hearing or at trial shall be 3 governed by the orders of the presiding judge and other applicable authorities. This 4 Order does not govern the use of Protected Material during a court hearing or at trial. 5 6. DURATION 6 Even after final disposition of this litigation, the confidentiality obligations 7 /imposed by this Order shall remain in effect until a Designating Party agrees 8 otherwise in writing or a court order otherwise directs. Final disposition shall be 9 deemed to be the later of (1) dismissal of all claims and defenses in this Action, with or without prejudice; or (2) final judgment herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, including the time limits for filing any motions or applications for extension of time pursuant to applicable law. Once a case proceeds to trial, information that was designated as } CONFIDENTIAL or maintained pursuant to this Protective Order used or introduced as an exhibit at trial becomes public and will be presumptively available to all lmembers of the public, including the press, unless compelling reasons supported by specific factual findings to proceed otherwise are made to the trial judge in advance of the trial. 7. DESIGNATING PROTECTED MATERIAL 7.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. A document should be designated “CONFIDENTIAL.” when it contains confidential information that may be reviewed by a designated manager of the receiving party but must be protected against disclosure to unauthorized third parties. A document may be designated ‘ATTORNEYS’ EYES ONLY” only when it contains

| || supplier/vendor identifiers, customer identifiers, sales and revenue data, pricing, sensitive financial information, sensitive commercial or business information (including information implicating privacy rights of third parties), sensitive internal company communications, or information which would put the producing person or entity at a competitive disadvantage if the information became known to the receiving party. The Designating Party must designate for protection only those parts of material, documents, items or oral or written communications that qualify so that other portions of the material, documents, items or communications for which protection is ) not warranted are not swept unjustifiably within the ambit of this Order. Mass, indiscriminate or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber the case development process or to impose unnecessary expenses and burdens on other parties) may expose the Designating Party to sanctions. If it comes to a Designating Party’s attention that information or items that it designated for protection do not qualify for protection, that Designating Party must ) promptly notify all other Parties that it is withdrawing the inapplicable designation. 7.2 Manner and Timing of Designations. Except as otherwise provided in this Order, or as otherwise stipulated or ordered, Disclosure of Discovery Material that qualifies for protection under this Order must be clearly so designated before the material is disclosed or produced. Designation in conformity with this Order requires: (a) for information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix at a minimum, the legend ““CONFIDENTIAL” or ‘ATTORNEYS’ EYES ONLY” to each page that contains protected material. If only a portion of the material on a page qualifies for protection, = ee JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

| || the Producing Party also must clearly identify the protected portion(s) (e.g., by 2 making appropriate markings in the margins). 3 A Party or Non-Party that makes original documents available for inspection 4 need not designate them for protection until after the inspecting Party has indicated 5 which documents it would like copied and produced. During the inspection and 6 before the designation, all of the material made available for inspection shall be 7 deemed “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY.” After the inspecting 8 Party has identified the documents it wants copied and produced, the Producing Party 9 must determine which documents, or portions thereof, qualify for protection under this Order. Then, before producing the specified documents, the Producing Party must affix the “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” legend to each page that contains Protected Material. If only a portion of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins). (b) for testimony given in depositions that the Designating Party identifies the Disclosure or Discovery Material on the record, before the close of the deposition all protected testimony. (c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which the information is stored the legend “CONFIDENTIAL” or “ATTORNEY’S EYES ONLY.” If only a portion or portions of the information warrants protection, the Producing Party, to the extent practicable, shall identify the protected portion(s). 7.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate qualified information or items does not, standing alone, waive the Designating Party’s right to secure protection under this Order for such material. Upon timely correction of a designation, the Receiving Party must make reasonable CASE NO. 2:25-CV-06165-JFW (Ex) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

| || efforts to assure that the material is treated in accordance with the provisions of this Order. 8 CHALLENGING CONFIDENTIALITY DESIGNATIONS 8.1. Timing of Challenges. Any Party or Non-Party may challenge a designation of confidentiality at any time that is consistent with the Court’s Scheduling Order. 8.2 Meet and Confer. The Challenging Party shall initiate the dispute }/resolution process under Local Rule 37-1 et seq. The burden of persuasion in any such challenge proceeding shall be on the ) Designating Party. Frivolous challenges, and those made for an improper purpose I(e.g., to harass or impose unnecessary expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the Designating Party has waived or withdrawn the confidentiality designation, all parties shall continue to afford the material in question the level of protection to which it is entitled under the Producing Party’s designation until the court rules on the challenge. 9. ACCESS TO AND USE OF PROTECTED MATERIAL 9.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this Action only for prosecuting, defending, or attempting to settle this Action. Such Protected Material may be disclosed only to the categories of persons and under the conditions described in this Order. When the Action has been terminated, a Receiving Party must comply with the provisions of Section 15 below (FINAL DISPOSITION). Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order. 9.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a CASE NO. 2:25-CV-06165-JFW (Ex) JOINT STIPULATION AND PROPOSED] PROTECTIVE ORDER

| || Receiving Party may disclose any information or item designated “CONFIDENTIAL” 2 only to: 3 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 4 well as employees of said Outside Counsel of Record and Professional Vendors 5 working with said Outside Counsel of Record to whom it is reasonably necessary to 6 disclose the information for this Action; (b) Experts of the Receiving Party to whom disclosure is reasonably 8 necessary for this Action and who have signed the “Acknowledgment and Agreement 9 to Be Bound” (Exhibit A); (c) the court and its personnel; (d) court reporters and their staff; (e) professional jury or trial consultants, mock jurors, and Professional Vendors to whom disclosure is reasonably necessary for this Action and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); (f) the author or recipient of a document containing the information or a ] custodian or other person who otherwise possessed or knew the information; (g) during their depositions, witnesses, and attorneys for witnesses, in the } Action to whom disclosure is reasonably necessary provided: (1) the deposing party requests that the witness sign the form attached as Exhibit A hereto; and (2) they will not be permitted to keep any confidential information unless they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal Protected Material may be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Protective Order; and (h) any mediators or settlement officers and their supporting personnel, mutually agreed upon by any of the parties engaged in settlement discussions. (1) the Parties’ officers, directors, employees and consultants to whom it

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1 reasonably necessary to disclose the information for this Action; Materials designated “ATTORNEYS’ EYES ONLY” as well as any copies or excerpts thereof, or analyses or reports, which pertain thereto, may be made available only to persons identified in Sections 9.2(a) through (h), of this Order. 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED If a Party is served with a subpoena or a court order issued in other litigation that compels disclosure of any information or items designated in this Action as ““CONFIDENTIAL” or ‘ATTORNEYS’ EYES ONLY” that Party must: (a) promptly notify in writing the Designating Party. Such notification shall include a copy of the subpoena or court order; (b) promptly notify in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material covered by the subpoena or order is subject to this Protective Order. Such notification shall include a copy of this Protective Order; and (c) cooperate with respect to all reasonable procedures sought to be pursued by the Designating Party whose Protected Material may be affected. If the Designating Party timely seeks a protective order, the Party served with the subpoena ! or court order shall not produce any information designated in this action as “CONFIDENTIAL” or “ATTORNEYS’ EYES ONLY” before a determination by the court from which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. The Designating Party shall bear the burden and expense of seeking protection in that court of its confidential material and nothing in these provisions should be construed as authorizing or encouraging a Receiving Party in this Action to disobey a lawful directive from another court. 11. ANON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE ll CASE NO. 2:25-CVv-06165-JFW (EX) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

I (a) The terms of this Order are applicable to information produced by a Non-Party in this Action and designated as “CONFIDENTIAL” or “ATTORNEYS” EYES ONLY.” Such information produced by Non-Parties in connection with this litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections. (b) In the event that a Party is required, by a valid discovery request, to produce a Non-Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-Party not to produce the Non-Party’s confidential information, then the Party shall: (1) promptly notify in writing the Requesting Party and the Non- Party that some or all of the information requested is subject to a confidentiality agreement with a Non-Party; (2) promptly provide the Non-Party with a copy of the Protective Order in this Action, the relevant discovery request(s), and a reasonably specific description of the information requested; and (3) make the information requested available for inspection by the Non-Party, if requested. (c) If the Non-Party fails to seek a protective order from this court within 14 days of receiving the notice and accompanying information, the Receiving Party may produce the Non-Party’s confidential information responsive to the discovery request. If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any information in its possession or control that is subject to the confidentiality agreement with the Non-Party before a determination by the court, unless otherwise required by the law or court order. Absent a court order to the contrary, the Non-Party shall bear the burden and expense of seeking protection in this court of its Protected Material. 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL

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I If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material to any person or in any circumstance not authorized under this Protective Order, the Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons to }whom unauthorized disclosures were made of all the terms of this Order, and (d) request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” attached hereto as Exhibit A. 13. INADVERTENT PRODUCTION OF PRIVILEGED OR When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege or other protection, the obligations of the Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the Parties reach an agreement on the effect of disclosure of a communication or information covered by the attorney-client privilege or work product protection, the Parties may incorporate their agreement in this Protective Order submitted to the court. 14. MISCELLANEOUS 14.1 Right to Further Relief. Nothing in this Protective Order abridges the right of any person to seek its modification by the Court in the future. 14.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order, no Party waives any right it otherwise would have to object to disclosing or producing any information or item on any ground not addressed in this Protective Order. Similarly, no Party waives any right to object on any ground to use /in evidence of any of the material covered by this Protective Order.

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I 14.3 Filing Protected Material. A Party that seeks to file under seal any Protected Material must comply with Civil Local Rule 79-5 and with any pertinent orders of the assigned District Judge and Magistrate Judge. Protected Material may only be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material. If a Party’s request to file Protected Material under seal is denied by the court, then the Receiving Party may file the information in the public record unless otherwise instructed by the court. 15. FINAL DISPOSITION After the final disposition of this Action, as defined in Section 6, within 60 days of a written request by the Designating Party, each Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in Section 6 (DURATION). 16. VIOLATION 14 CASE NO. 2:25-CV-06165-JFW (EX) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

Any violation of this Protective Order may be punished by appropriate measures including, without limitation, contempt proceedings and/or monetary sanctions. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. IDATED: 3/4/2026 /s/ Mark A. Finkelstein Mark A. Finkelstein Attorneys for Plaintiff Seattle Cell Market, LLC DATED: 3/4/2026 /s/ Paulo A. de Almeida Paulo A. de Almeida Attorneys for Defendant M. Segue Corporation 15 CASE NO. 2:25-CV-06165-JFW (EX) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. DATED: 3/5/2026

United States Magistrate Judge pa CASE NO. 2:25-CV-06165-JFW (EX) JOINT STIPULATION AND [PROPOSED] PROTECTIVE ORDER

EXHIBIT A i, [print or type full name], of [print or type full address], declare under penalty of perjury that I have read in its entirety and understand the Protective Order that was issued by the United States District Court for the Central District of California on in the case of . Lagree to comply with and to be bound by all the terms of this Protective Order and I understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any manner any information } OF item that is subject to this Protective Order to any person or entity except in strict Compliance with the provisions of this Order. I further agree to submit to the jurisdiction of the United States District Court for the Central District of California for the purpose of enforcing the terms of this Protective Order, even if such enforcement proceedings occur after termination of this ig |[action. I hereby appoint [print or type full name] of [print or type full address and 79 telephone number] as my California agent for service of process in connection with this action or any proceedings related to enforcement of this Protective Order. Date: City and State where sworn and signed: Printed Name: Signature: 17

UMBERG ZIPSER LLP WOLF, RIFKIN, SHAPIRO, > || Mark A. Finkelstein (SBN 173851) SCHULMAN & RABKIN, LLP mfinkelstein@uzllp.com Matthew Oster (SBN 190541) Ellen S. Kim (SBN 329348) moster@wrslawyers.com /ekim@uzllp.com Paulo A. de Almeida (SBN 279168) 1920 Main Street, Suite 750 pdealmeida@wrslawyers.com Irvine, California 92614 11400 W Olympic Blvd., 9" FI. Telephone: (949) 679-0052 Los Angeles, CA 90064 Facsimile: (949) 679-0461 Telephone: (310) 478-4100 g || Attorneys for Plaintiff Attorneys for Defendant Seattle Cell Market, LLC M. Segue Corporation UNITED STATES DISTRICT COURT '4 | SEATTLE CELL MARKET, LLC, Case No. 2:25-cv-06165-JFW (Ex) ig Plaintiff, Assigned to: Hon. Charles F. Eick = {PROPOSED} ORDER 1g ||M. SEGUE CORPORATION, REGARDING JOINT STIPULATION Defendant. Complaint Filed: September 10, 2024 Trial Date: December 1, 2026 CASE NO. 2:25-CV-06165-JFW (EX) {PReEPeSED} ORDER REGARDING JOINT STIPULATION

PROPOSED] ORDER 2 The parties are hereby DIRECTED to file a signed copy of a protective order 3 within five (5) days of this Order which [includes] an “Attorneys’ Eyes Only” level of 4 protection. 5 6 IT IS SO ORDERED. BLL g Dated: 3/5/2026 By: SS Hon. Charles F. Eick 9 United States Magistrate Judge 1]

CASE NO. 2:25-CV-06165-JFW (EX) [PROPOSED] ORDER REGARDING JOINT STIPULATION