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Contentions on Defendant (the \u201cMotion\u201d) filed by Plaintiff Semantic Engines LLC\n\n(\u201cPlaintiff\u201d). (Dkt. No. 34.) In the Motion, Plaintiff moves for leave to serve its First Amended\n\nInfringement Contentions on Defendant Microsoft Corporation. (Id. at 1.) The Motion is\n\nunopposed. (Id.)\n\n Having considered the Motion, and noting its unopposed nature, the Court finds that it\n\nshould be and hereby is GRANTED.\n\n\n So ORDERED and SIGNED this 25th day of August, 2026.\n\n\n\n\n ____________________________________\n RODNEY GILSTRAP\n UNITED STATES DISTRICT JUDGE\n\f","ocr_status":2,"date_upload":"2026-09-01T22:57:31.172622-07:00","document_number":"36","attachment_number":null,"pacer_doc_id":"175015644593","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion for Miscellaneous Relief","acms_document_guid":""}],"date_created":"2026-08-25T14:27:00.828121-07:00","date_modified":"2026-08-25T14:27:00.873968-07:00","date_filed":"2026-08-25","time_filed":"16:09:44","entry_number":36,"recap_sequence_number":"2026-08-25.001","pacer_sequence_number":93,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/475553497/","id":475553497,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73237887/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491089639/","id":491089639,"tags":[],"absolute_url":"/docket/73237887/35/semantic-engines-llc-v-microsoft-corporation/","date_created":"2026-08-24T10:12:11.920700-07:00","date_modified":"2026-08-24T10:12:11.931893-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"35","attachment_number":null,"pacer_doc_id":"175015638119","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion to Amend/Correct","acms_document_guid":""}],"date_created":"2026-08-24T10:12:11.888370-07:00","date_modified":"2026-08-24T10:12:11.898656-07:00","date_filed":"2026-08-24","time_filed":"12:04:57","entry_number":35,"recap_sequence_number":"2026-08-24.001","pacer_sequence_number":91,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/475406717/","id":475406717,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73237887/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490937072/","id":490937072,"tags":[],"absolute_url":"/docket/73237887/34/semantic-engines-llc-v-microsoft-corporation/","date_created":"2026-08-21T13:59:02.907238-07:00","date_modified":"2026-08-21T13:59:02.918326-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"34","attachment_number":null,"pacer_doc_id":"175015635523","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Miscellaneous Relief","acms_document_guid":""}],"date_created":"2026-08-21T13:59:02.878832-07:00","date_modified":"2026-08-21T13:59:02.885636-07:00","date_filed":"2026-08-21","time_filed":"15:10:30","entry_number":34,"recap_sequence_number":"2026-08-21.001","pacer_sequence_number":89,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/475221578/","id":475221578,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/73237887/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/490746446/","id":490746446,"tags":[],"absolute_url":"/docket/73237887/33/semantic-engines-llc-v-microsoft-corporation/","date_created":"2026-08-20T11:44:35.611622-07:00","date_modified":"2026-09-28T04:55:36.460610-07:00","sha1":"ba7ac3d8e6bc8588ba30a855a906d89212695ac0","page_count":4,"file_size":160777,"filepath_local":"recap/gov.uscourts.txed.245318/gov.uscourts.txed.245318.33.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.245318/gov.uscourts.txed.245318.33.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 2:26-cv-00339-JRG Document 33 Filed 08/20/26 Page 1 of 4 PageID #: 306\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF TEXAS\n MARSHALL DIVISION\n\n SEMANTIC ENGINES LLC,\n\n Plaintiff,\n v. Civil Action No. 2:26-cv-339-JRG\n\n MICROSOFT CORPORATION,\n\n Defendant.\n\n\n JOINT MOTION FOR LEAVE TO AMEND DOCKET CONTROL ORDER\n\n Plaintiff Semantic Engines LLC and Defendant Microsoft Corporation jointly move to\n\namend the Court\u2019s July 24, 2026 Docket Control Order.\n\n First, the parties agree to amend the Deadline for Defendant to Comply with P.R. 3-3 & 3-\n\n4 (Invalidity Contentions) and to Comply with Standing Order Regarding Subject-Matter\n\nEligibility Contentions from August 31, 2026, to October 16, 2026.\n\n Second, the parties agree to amend the Deadline to Complete Fact Discovery and File\n\nMotions to Compel Discovery from January 18, 2028, to December 15, 2027. This amendment\n\nwill enable the parties to avoid scheduling depositions during the holiday season and provide\n\nadequate time between the close of fact discovery and the deadlines for expert disclosures.\n\n Third, the parties agree to amend the Deadline to Serve Disclosures for Expert Witnesses\n\nby the Party with the Burden of Proof from January 18, 2028, to January 14, 2028, and to amend\n\nthe Deadline to Serve Disclosures for Rebuttal Expert Witnesses from February 7, 2028, to\n\nFebruary 10, 2028.\n\n Fourth and last, the parties agree to amend the chart of deadlines to add the Deadline to\n\nSubmit Joint Notice Indicating Whether the Case Should Be Referred for Mediation, which is two\n\nweeks after Court\u2019s issuance of Claim Construction Order. This deadline already appears in the\n\fCase 2:26-cv-00339-JRG Document 33 Filed 08/20/26 Page 2 of 4 PageID #: 307\n\n\n\n\n\u201cAdditional Requirements\u201d section of the Docket Control Order, and the parties propose adding it\n\nto the chart to aid in tracking deadlines.\n\n Accordingly, the parties jointly move the Court for entry of the attached First Amended\n\nDocket Control Order attached as Exhibit 1.\n\n\n\nDate: August 20, 2026 Respectfully submitted,\n\n/s/ Melissa R. Smith /s/ Andres C. Healy\nMelissa R. Smith Andres C. Healy\nState Bar No. 24001351 Washington State Bar No. 45578\nmelissa@gillamsmithlaw.com ahealy@susmangodfrey.com\nGILLAM & SMITH LLP Matthew R. Berry\n303 South Washington Avenue Washington State Bar No. 37364\nMarshall, Texas 75670 mberry@susmangodfrey.com\nTelephone: (903) 934-8450 John Schiltz\nFacsimile: (903) 934-9257 Washington State Bar No. 48973\n jschiltz@susmangodfrey.com\nFAEGRE DRINKER BIDDLE & REATH SUSMAN GODFREY L.L.P.\nLLP 401 Union Street Suite 3000\nLora A. Brzezynski (admitted in E.D. Tex.) Seattle, WA 98101-2683\nDistrict of Columbia Bar No 444261 Telephone: (206) 505-3880\nlora.brzezynski@faegredrinker.com Facsimile: (206) 516-3883\n1500 K Street NW, Suite 1100\nWashington, D.C. 20005 Kaholi Kiyonami\nTel.: (202) 842-8800 District of Columbia Bar No. 90007351\nFax: (202) 842-8465 kkiyonami@susmangodfrey.com\n SUSMAN GODFREY L.L.P.\nCarrie A. Beyer (admitted in E.D. Tex.) One Manhattan West, 50th Floor\nIllinois State Bar No. 06282524 New York, NY 10001\ncarrie.beyer@faegredrinker.com Telephone: (212) 336-8330\nDevin P. Stein (admitted in E.D. Tex.) Facsimile: (212) 336-8340\nIllinois State Bar No. 6353900\ndevin.stein@faegredrinker.com Claire Abernathy Henry\n320 S. Canal Street, Suite 3300 Texas State Bar No. 24053063\nChicago, IL 60606 claire@millerfairhenry.com\nTel.: (312) 569-1000 Garrett C. Parish\nFax: (312) 569-3000 Texas Bar No. 24125824\n garrett@millerfairhenry.com\nThatcher A. Rahmeier (admitted in E.D. Tex.) MILLER FAIR HENRY, PLLC\nDelaware State Bar No. 5222 1507 Bill Owens Parkway\nthatcher.rahmeier@faegredrinker.com Longview, TX 75604\n\n\n\n -2-\n\fCase 2:26-cv-00339-JRG Document 33 Filed 08/20/26 Page 3 of 4 PageID #: 308\n\n\n\n\n222 Delaware Avenue, Suite 1410 Phone: (903) 757-6400\nWilmington, DE 19801 Facsimile: (903) 757-2323\nTel: (302) 467-4200\nFax: (302) 467-4201 Attorneys for Plaintiff Semantic Engines LLC\n\nElizabeth M.C. Scheibel (admitted in E.D. Tex.)\nMinnesota State Bar No. 0399400\nelizabeth.scheibel@faegredrinker.com\n2200 Wells Fargo Center\n90 South Seventh Street\nMinneapolis, MN 55402\nTel.: (612) 766-7000\nFax: (612) 766-1600\n\nAttorneys for Defendant\nMicrosoft Corporation\n\n\n\n\n -3-\n\fCase 2:26-cv-00339-JRG Document 33 Filed 08/20/26 Page 4 of 4 PageID #: 309\n\n\n\n\n CERTIFICATE OF CONFERENCE\n\n I certify that counsel for Semantic has met and conferred with counsel for Microsoft,\n\nincluding via email on August 20, 2026. Counsel confirmed that Microsoft agrees to join in the\n\nforegoing motion.\n\n\n\n /s/ Andres C. Healy\n Andres C. Healy\n\n\n\n CERTIFICATE OF SERVICE\n\n The undersigned hereby certifies that this document was filed electronically via the Court's\n\nCM/ECF system, which will send notification of such filing to all counsel of record.\n\n\n\n /s/ Andres C. Healy\n Andres C. 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2:26-cv-00339-JRG Document 29 Filed 08/11/26 Page 1 of 3 PageID #: 233\n\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF TEXAS\n MARSHALL DIVISION\n\n SEMANTIC ENGINES LLC,\n\n Plaintiff,\n v. Civil Action No. 2:26-cv-339-JRG\n\n MICROSOFT CORPORATION,\n\n Defendant.\n\n\n JOINT MOTION FOR ENTRY OF PARTIALLY DISPUTED PROTECTIVE ORDER\n\n Plaintiff Semantic Engines LLC (\u201cSemantic\u201d) and Defendant Microsoft Corporation\n\n(\u201cMicrosoft\u201d) file this Joint Motion for Entry of Partially Disputed Protective Order, attached as\n\nExhibit 1. The parties agree on all provisions except those contained in highlighted text in\n\nParagraphs 14 and 30. For each disputed provision, the highlighted text presents each party\u2019s\n\ncompeting proposed language, with supporting arguments in corresponding footnotes.\n\n The parties respectfully request that the Court resolve the disputed provisions and enter the\n\nproposed protective order.\n\n\n\nDate: August 10, 2026 Respectfully submitted,\n\n/s/ Melissa R. Smith /s/ Andres C. Healy\nMelissa R. Smith Andres C. Healy\nTexas State Bar No. 24001351 Washington State Bar No. 45578\nGILLAM & SMITH LLP ahealy@susmangodfrey.com\n303 South Washington Avenue Matthew R. Berry\nMarshall, Texas 75670 Washington State Bar No. 37364\nTelephone: (903) 934-8450 mberry@susmangodfrey.com\nFacsimile: (903) 934-9257 John Schiltz\nEmail: melissa@gillamsmithlaw.com Washington State Bar No. 48973\n jschiltz@susmangodfrey.com\nFAEGRE DRINKER BIDDLE & REATH SUSMAN GODFREY L.L.P.\nLLP 401 Union Street Suite 3000\n Seattle, WA 98101-2683\n\fCase 2:26-cv-00339-JRG Document 29 Filed 08/11/26 Page 2 of 3 PageID #: 234\n\n\n\n\nLora Brzezynski (admitted in E.D. Tex.) Telephone: (206) 505-3880\nDistrict of Columbia Bar No 444261 Facsimile: (206) 516-3883\nlora.brzezynski@faegredrinker.com\n1500 K Street NW, Suite 1100 Kaholi Kiyonami\nWashington, D.C. 20005 District of Columbia Bar No. 90007351\nTel.: (202) 842-8800 kkiyonami@susmangodfrey.com\nFax: (202) 842-8465 SUSMAN GODFREY L.L.P.\n One Manhattan West, 50th Floor\nCarrie A. Beyer (admitted in E.D. Tex.) New York, NY 10001\nIllinois State Bar No. 06282524 Telephone: (212) 336-8330\ncarrie.beyer@faegredrinker.com Facsimile: (212) 336-8340\nDevin P. Stein (admitted in E.D. Tex.)\nIllinois State Bar No. 6353900 Claire Abernathy Henry\ndevin.stein@faegredrinker.com Texas State Bar No. 24053063\n320 S. Canal Street, Suite 3300 claire@millerfairhenry.com\nChicago, IL 60606 Garrett C. Parish\nTel.: (312) 569-1000 Texas Bar No. 24125824\nFax: (312) 569-3000 garrett@millerfairhenry.com\n MILLER FAIR HENRY, PLLC\nThatcher A. Rahmeier (admitted in E.D. Tex.) 1507 Bill Owens Parkway\nDelaware State Bar No. 5222 Longview, TX 75604\nthatcher.rahmeier@faegredrinker.com Phone: (903) 757-6400\n222 Delaware Avenue, Suite 1410 Facsimile: (903) 757-2323\nWilmington, DE 19801\nTel: (302) 467-4200\nFax: (302) 467-4201 Attorneys for Plaintiff\n Semantic Engines LLC\nElizabeth M.C. Scheibel (admitted in E.D. Tex.)\nMinnesota State Bar No. 0399400\nelizabeth.scheibel@faegredrinker.com\n2200 Wells Fargo Center\n90 South Seventh Street\nMinneapolis, MN 55402\nTel.: (612) 766-7000\nFax: (612) 766-1600\n\n\nAttorneys for Defendant\nMicrosoft Corporation\n\n\n\n\n -2-\n\fCase 2:26-cv-00339-JRG Document 29 Filed 08/11/26 Page 3 of 3 PageID #: 235\n\n\n\n\n CERTIFICATE OF CONFERENCE\n\n Pursuant to Local Rule CV-7(h) and (i), the Parties met and conferred about the proposed\n\nprotective order by teleconference on August 7, 2026 and were able to reach agreement on all\n\nprovisions except the highlighted provisions, for which the parties reached an impasse. Andres\n\nHealy and Kaholi Kiyonami attended on behalf of Plaintiff, and Elizabeth M.C. Scheibel attended\n\non behalf of Defendant.\n\n /s/ Andres C. Healy\n Andres C. Healy\n\n\n\n\n CERTIFICATE OF SERVICE\n\n The undersigned hereby certifies that this document was filed electronically via the\n\nCourt's CM/ECF system, which will send notification of such filing to all counsel of record.\n\n /s/ Andres C. Healy\n Andres C. Healy\n\n\n\n\n -3-\n\f","ocr_status":2,"date_upload":"2026-08-31T13:34:34.840871-07:00","document_number":"29","attachment_number":null,"pacer_doc_id":"175015602704","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Protective Order","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/491991221/","id":491991221,"tags":[],"absolute_url":"/docket/73237887/29/1/semantic-engines-llc-v-microsoft-corporation/","date_created":"2026-08-31T13:34:36.507169-07:00","date_modified":"2026-09-08T21:01:10.111959-07:00","sha1":"4e8b46f073e1bed7519bc43296001d400f054ac0","page_count":29,"file_size":247211,"filepath_local":"recap/gov.uscourts.txed.245318/gov.uscourts.txed.245318.29.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.245318/gov.uscourts.txed.245318.29.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 1 of 29 PageID #:\n 236\n\n\n\n\n EXHIBIT 1\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 2 of 29 PageID #:\n 237\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF TEXAS\n MARSHALL DIVISION\n\n SEMANTIC ENGINES LLC,\n\n Plaintiff,\n v. Civil Action No. 2:26-cv-339-JRG\n\n MICROSOFT CORPORATION,\n\n Defendant.\n\n\n [PARTIALLY DISPUTED] PROTECTIVE ORDER\n WHEREAS, Plaintiff Semantic Engines LLC (\u201cSemantic\u201d) and Defendant Microsoft\n\nCorporation (\u201cMicrosoft\u201d), hereafter referred to as \u201cthe Parties,\u201d believe that certain information that\n\nis or will be encompassed by discovery demands by the Parties in the above-captioned action may\n\ninvolve the production or disclosure of trade secrets; confidential business information;\n\ninformation protected under federal, state or foreign Data Protection Laws or other privacy\n\nobligations; or other proprietary information;\n\n WHEREAS, the Parties seek a protective order limiting disclosure thereof in accordance\n\nwith Federal Rule of Civil Procedure 26(c):\n\n THEREFORE, it is hereby stipulated among the Parties and ORDERED that:\n\n 1. Each Party may designate as confidential for protection under this Order, in whole\n\nor in part, any document, information, or material that constitutes or includes, in whole or in part,\n\nconfidential or proprietary information or trade secrets of the Party or a Third Party to whom the\n\nParty reasonably believes it owes an obligation of confidentiality with respect to such document,\n\ninformation, or material (\u201cProtected Material\u201d). Protected Material shall be designated by the Party\n\nproducing it by affixing a legend or stamp on such document, information or material as follows:\n\n\n\n 1\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 3 of 29 PageID #:\n 238\n\n\n\n\u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED\n\nCONFIDENTIAL SOURCE CODE.\u201d The words \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013\n\nATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d shall be\n\nplaced clearly on each page of the Protected Material (except deposition and hearing transcripts)\n\nfor which such protection is sought. For deposition and hearing transcripts, the word\n\n\u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED\n\nCONFIDENTIAL SOURCE CODE\u201d shall be placed on the cover page of the transcript (if not\n\nalready present on the cover page of the transcript when received from the court reporter) by each\n\nattorney receiving a copy of the transcript after that attorney receives notice of the designation of\n\nsome or all of that transcript as \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES\n\nONLY,\u201d or \u201cRESTRICTED CONFIDENTIAL SOURCE CODE.\u201d\n\n 2. Any document produced before issuance of this Order with the designation\n\n\u201cCONFIDENTIAL\u201d or the like shall receive the same treatment as if designated\n\n\u201cCONFIDENTIAL\u201d under this order and any such documents produced with the designation\n\n\u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d or the like shall receive the same\n\ntreatment as if designated \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY\u201d under this Order,\n\nunless and until such document is redesignated to have a different classification under this Order.\n\n 3. With respect to documents, information or material designated\n\n\u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED\n\nCONFIDENTIAL SOURCE CODE\u201d (\u201cDESIGNATED MATERIAL\u201d),1 subject to the provisions\n\n\n\n\n1\n The term DESIGNATED MATERIAL is used throughout this Protective Order to refer to the\nclass of materials designated as \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES\nONLY,\u201d or \u201cRESTRICTED CONFIDENTIAL SOURCE CODE,\u201d both individually and\ncollectively.\n 2\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 4 of 29 PageID #:\n 239\n\n\n\nherein and unless otherwise stated, this Order governs, without limitation: (a) all documents,\n\nelectronically stored information, and/or things as defined by the Federal Rules of Civil Procedure;\n\n(b) all pretrial, hearing or deposition testimony, or documents marked as exhibits or for\n\nidentification in depositions and hearings; (c) pretrial pleadings, exhibits to pleadings and other\n\ncourt filings; (d) affidavits; (e) discovery responses, including answers to interrogatories and to\n\nrequests for admission; and (f) stipulations. All copies, reproductions, extracts, digests, and\n\ncomplete or partial summaries prepared from any DESIGNATED MATERIALS shall also be\n\nconsidered DESIGNATED MATERIAL and treated as such under this Order.\n\n 4. A designation of Protected Material (i.e., \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013\n\nATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d) may be\n\nmade at any time. Inadvertent or unintentional production of documents, information or material\n\nthat has not been designated as DESIGNATED MATERIAL shall not be deemed a waiver in\n\nwhole or in part of a claim for confidential treatment. Unauthorized or illegal distribution or\n\npublication of documents, information, or material without the producing Party\u2019s permission shall\n\nnot be deemed a waiver, in whole or in part, of a claim for confidential treatment of said\n\nunauthorized or illegally distributed or published documents, information, or material. Any Party\n\nthat inadvertently or unintentionally produces Protected Material without designating it as\n\nDESIGNATED MATERIAL may request destruction of that Protected Material by notifying the\n\nrecipient(s), as soon as reasonably possible after the producing Party becomes aware of the\n\ninadvertent or unintentional disclosure, and providing replacement Protected Material that is\n\nproperly designated. The recipient(s) shall then destroy all copies of the inadvertently or\n\nunintentionally produced Protected Materials and any documents, information or material derived\n\nfrom or based thereon irrespective of any other potential remedies provided in Federal Rule of\n\n\n\n 3\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 5 of 29 PageID #:\n 240\n\n\n\nCivil Procedure 26(b)(5)(B). In the event of a disclosure of any Protected Material, by inadvertence\n\nor otherwise, to any person or persons not authorized to receive such disclosure under this Order,\n\nor in any circumstance not authorized under this Order, the Party responsible for having made such\n\ndisclosure, and each Party with knowledge thereof, shall immediately notify counsel for the\n\ndesignating Party whose Protected Material has been disclosed and shall use its best efforts and\n\ncooperate in good faith to retrieve all unauthorized copies of the improperly disclosed Protected\n\nMaterial and to ensure that no further or greater unauthorized disclosure and/or use thereof is made,\n\nincluding informing the person or persons to whom unauthorized disclosure was made of all the\n\nterms of this Order and requesting that such person or persons complete the Undertaking attached\n\nas Appendix A hereto.\n\n 5. \u201cCONFIDENTIAL\u201d documents, information and material may be disclosed only\n\nto the following persons, except upon receipt of the prior written consent of the designating Party,\n\nupon order of the Court, or as set forth in paragraph 12 herein:\n\n a. outside counsel of record in this Action for the Parties;\n b. employees of such outside counsel assigned to and reasonably necessary to assist\n such counsel in the litigation of this Action;\n c. in-house counsel for the Parties who either have responsibility for making decisions\n dealing directly with the litigation of this Action, or who are assisting outside\n counsel in the litigation of this Action, and their employed support staff who are\n reasonably necessary to assist such counsel in the litigation of this Action;\n d. up to and including three (3) designated representatives of each of the Parties to the\n extent reasonably necessary for the litigation of this Action, except that either party\n may in good faith request the other party\u2019s consent to designate one or more\n additional representatives, the other party shall not unreasonably withhold such\n consent, and the requesting party may seek leave of Court to designate such\n additional representative(s) if the requesting party believes the other party has\n unreasonably withheld such consent. Each designated representative shall be\n disclosed five (5) business days prior to receiving access to any Protected Material\n and complete the Undertaking attached as Appendix A hereto;\n e. outside consultants or experts (i.e., not existing employees or affiliates of a Party)\n retained for the purpose of this litigation, provided that: (1) such consultants or\n 4\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 6 of 29 PageID #:\n 241\n\n\n\n experts are not presently employed by the Parties hereto or their affiliates for\n purposes other than this Action; and (2) such consultants or experts are not, and\n have not within the preceding one (1) year been, employed by a competitor of the\n Party from whom disclosure is sought; (3) before access is given, the consultant or\n expert has completed the Undertaking attached as Appendix A hereto and the same\n is served upon the producing Party with a current curriculum vitae of the consultant\n or expert, at least ten (10) days before access to the Protected Material is to be given\n to that consultant or expert. Within the ten (10) day period, the producing Party\n may notify the receiving Party in writing that it objects to disclosure of Protected\n Material to the consultant or expert. The Parties agree to promptly confer and use\n good faith to resolve any such objection. If the Parties are unable to resolve any\n objection, the objecting Party may file a motion with the Court within seven (7)\n business days of the notice, or within such other time as the Parties may agree,\n seeking a protective order with respect to the proposed disclosure. The objecting\n Party shall have the burden of proving the need for a protective order. In the event\n of such a dispute, no disclosure shall occur until all such objections are resolved by\n agreement or Court order;\n f. independent litigation support services, including persons working for or as court\n reporters, graphics or design services, jury or trial consulting services including\n mock jurors and supporting personnel, interpretation services, and photocopy,\n document imaging, file hosting, and database services retained by counsel and\n reasonably necessary to assist counsel with the litigation of this Action;\n g. any mediator who is assigned to hear this matter, including any staff of such\n mediator, subject to their agreement to maintain confidentiality to the same degree\n as required by this Protective Order;\n h. an author, recipient, or custodian of a document or corporate representative of the\n producing Party; and\n i. the Court and its personnel.\n 6. A Party shall designate documents, information, or material as \u201cCONFIDENTIAL\u201d\n\nor \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY\u201d only upon a good faith belief that the\n\ndocuments, information or material contains confidential or proprietary information or trade\n\nsecrets of the Party or a Third Party to whom the Party reasonably believes it owes an obligation\n\nof confidentiality with respect to such documents, information, or material.\n\n 7. Documents, information, or material produced in this Action, including but not\n\nlimited to Protected Material designated as DESIGNATED MATERIAL (i) shall be used by the\n\nParties only in this litigation for prosecuting, defending, or attempting to settle this Action; (ii)\n\n 5\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 7 of 29 PageID #:\n 242\n\n\n\nshall not be used for any business purpose, in connection with any other legal or administrative\n\nproceeding, including but not limited to any proceeding at the U.S. Patent and Trademark Office\n\n(or any similar agency of a foreign government), or directly or indirectly for any other purpose\n\nwhatsoever, unless required to be disclosed in such other legal or administrative proceeding, and\n\n(iii) shall not be disclosed to any person who is not entitled to receive such Protected Material as\n\nherein provided. All produced Protected Material shall be carefully maintained so as to preclude\n\naccess by persons who are not entitled to receive such Protected Material, and any person or entity\n\nwho obtains access to DESIGNATED MATERIAL or the contents thereof pursuant to this Order\n\nshall not make any copies, duplicates, extracts, summaries or descriptions of such DESIGNATED\n\nMATERIAL or any portion thereof except as may be reasonably necessary in the litigation of this\n\nAction. Any such copies, duplicates, extracts, summaries or descriptions shall be classified\n\nDESIGNATED MATERIALS and subject to all of the terms and conditions of this Order.\n\n 8. The restrictions and obligations set forth in this Order relating to DESIGNATED\n\nMATERIAL shall not apply to any information that: (a) the Parties agree, or the Court rules, is or\n\nhas become public knowledge other than as a result of disclosure by the receiving Party in violation\n\nof this Order; (b) has come or shall come into the receiving Party\u2019s legitimate possession\n\nindependently of the producing Party; or (c) has been independently developed by or for the\n\nreceiving Party without use of, or reference to, the producing Party\u2019s Protected Material, which\n\nProtected Material shall remain protected under this Order.\n\n 9. To the extent a producing Party believes in good faith that certain Protected\n\nMaterial qualifying to be designated CONFIDENTIAL is so sensitive that its dissemination\n\ndeserves even further limitation, the producing Party may designate such Protected Material\n\n\u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or to the extent such Protected Material\n\n\n\n 6\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 8 of 29 PageID #:\n 243\n\n\n\nincludes computer source code (e.g., computer code, machine readable code, programming\n\nlanguage, scripts, assembly code, binaries and object code, and/or hardware description language)\n\n(\u201cSource Code Material\u201d), the producing Party may designate such Protected Material as\n\n\u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d. A document that merely quotes or cites\n\nfilenames, line numbers, directory names, module names, class names, parameter names, variable\n\nnames, function names, method names, and/or procedure names (e.g., for notetaking or\n\nidentification purposes) without reproducing any lines of source code need not be designated\n\n\u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d but should be designated \u201cRESTRICTED\n\n\u2013 ATTORNEYS\u2019 EYES ONLY.\u201d\n\n 10. For Protected Material designated RESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\n\naccess to, and disclosure of, such Protected Material shall be limited to individuals listed in\n\nparagraphs 5(a-c) and (e-h); provided, however, that access by in-house counsel pursuant to\n\nparagraph 5(c) be limited to in-house counsel who exercise no competitive decision-making\n\nauthority on behalf of the client. Nothing in this paragraph 10 precludes outside counsel for a\n\nParty from informing their client(s) designated under paragraph 5(d) and who agree to be bound\n\nby this Protective Order of high-level damages estimates, solely to aid in settlement discussions or\n\nmediation and advise on damages models, so long as no information designated RESTRICTED \u2013\n\nATTORNEYS\u2019 EYES ONLY is revealed.\n\n 11. For Protected Material designated RESTRICTED CONFIDENTIAL SOURCE\n\nCODE, access to, and disclosure of, such Protected Material shall be limited to individuals listed\n\nin paragraphs 5(a-b) and (e-h). The following additional restrictions apply for Protected Material\n\ndesignated RESTRICTED CONFIDENTIAL SOURCE CODE:\n\n a. Access to a Party\u2019s (including a Third Party\u2019s) Source Code Material shall be\n provided only on \u201cstand-alone\u201d computer(s) (that is, the computer(s) may not be\n\n\n 7\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 9 of 29 PageID #:\n 244\n\n\n\n linked to any network, including a local area network (\u201cLAN\u201d), an intranet or the\n Internet) (\u201cSource Code Computers\u201d). The Source Code Computers shall be\n password protected. Without the permission of the Producing Party, neither the\n receiving Party\u2019s outside counsel nor its outside consultants or experts may connect\n any device to the Source Code Computers. The Source Code Computers may be\n connected to a printer, however, all printing shall be performed by the producing\n Party or the producing Party\u2019s outside counsel, upon request by the receiving Party\n or the receiving Party\u2019s reviewer(s). Except as otherwise permitted in this Order,\n no person shall copy, e-mail, transmit, upload, download, print, photograph or\n otherwise duplicate any portion of the Source Code Material, except that the\n receiving Party shall be permitted to have made a reasonable number of printouts of\n Source Code Material, all of which shall be designated and clearly labeled\n \u201cRESTRICTED CONFIDENTIAL SOURCE CODE.\u201d The receiving party should\n identify the Source Code Material the receiving party wants to request for printing\n by saving (as PDFs) the requested pages on the Source Code Computers and\n making a written request to the producing Party. The receiving Party is entitled to\n print up to fifty (50) consecutive pages of Source Code Material and up to three\n hundred and fifty (350) total pages of Source Code Material during the duration of\n the case. The producing Party and the producing Party\u2019s expert(s) will be subject\n to the same printing restrictions for purposes of this action as that of the receiving\n Party. To the extent a receiving Party requests to print additional Source Code\n Material, the parties agree to meet and confer regarding any such request. The\n Source Code Computers shall be located at one of the offices of the producing\n Party\u2019s outside counsel, or other location(s) mutually agreed upon by the producing\n Party and the receiving Party, in a room where the receiving Party\u2019s outside\n counsel, consultants, and experts can review the Source Code Material in private.\n A mouse, keyboard, and a display screen or monitor of a size of at least twenty-\n three inches shall be provided by the producing Party for each stand-alone computer\n on which Source Code Material is produced. The hardware and software\n specifications of the Source Code Computers (e.g., processor speed, RAM,\n operating system, and monitor) shall be commensurate with that of computers used\n by the producing Party to work with source code in the ordinary course of business.\n No recordable media or recordable devices, including cell phones, shall be\n permitted into the room with the Source Code Computers. The receiving Party is\n permitted to use a note-taking laptop to be provided by the producing Party, not\n connected to any network and with the camera disabled. The receiving Party\u2019s\n outside counsel and/or expert shall be entitled to take notes relating to the Source\n Code by hand or on the note-taking laptop, but may not copy any line of Source\n Code Material into the notes. For the avoidance of doubt, no reviewer may at any\n time copy any portions or sections of source code material into either electronic or\n paper notes, and counsel for the reviewing Party shall instruct its reviewer(s) not to\n copy or include any portion or section of source code material in either electronic\n or paper notes. However, the notes may contain descriptions of source code\n functionality, including filenames, directory names, module names, class names,\n method names, procedure names, function names, variable names, parameter\n names, and other individual identifiers derived from Source Code, which do not,\n\n\n 8\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 10 of 29 PageID #:\n 245\n\n\n\n by themselves, constitute a line of Source Code Material. Any notes, whether\n electronic or paper, relating to the Source Code will be treated as \u201cRESTRICTED\n \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d The receiving Party shall be able to copy the\n notes from the note taking laptop onto a recordable device at the end of each day of\n inspection under the supervision of the producing Party.\n b. Any review of source code on the Source Code Computer(s) by the receiving Party\n must occur prior to the close of expert discovery unless otherwise agreed among\n the parties or ordered by the Court.\n c. The receiving Party shall make reasonable efforts to restrict its requests for such\n access to the Source Code Computers to normal business hours, which for purposes\n of this paragraph shall be 9:00 a.m. through 5:00 p.m. local time where the Source\n Code Computers are located. However, upon reasonable notice from the receiving\n Party, the producing Party shall make reasonable efforts to accommodate the\n receiving Party\u2019s request for access to the Source Code Computers outside of\n normal business hours. The Parties agree to cooperate in good faith such that\n maintaining the producing Party\u2019s Source Code Material at the offices of its outside\n counsel shall not unreasonably hinder the receiving Party\u2019s ability to efficiently and\n effectively conduct the prosecution or defense of this Action;\n d. The Party requesting to inspect source code shall provide notice to the producing\n Party of its request ten (10) business days in advance of the first requested\n inspection, absent circumstances warranting good cause for a shorter notice, and\n three (3) business days in advance of each subsequent requested inspection, absent\n circumstances warranting good cause for shorter notice. In advance of the\n inspection, the receiving Party will identify the individual(s) who will be reviewing\n the source code, as well as the anticipated hours of the review. Proper identification\n of all authorized persons shall be provided prior to any access to the secure room\n or the Source Code Computers. Proper identification includes any official\n government-issued identification. Access to the secure room or the Source Code\n Computers may be denied to any individual who fails to provide proper\n identification.\n e. The producing Party shall provide the receiving Party with information explaining\n how to start, log on to, and operate the Source Code Computers in order to access\n the produced Source Code Material on the Source Code Computers;\n f. The reviewing Party or its expert(s) shall not attempt to circumvent the security of\n the Source Code Computers or confidentiality of the Source Code Material\n displayed. A telephone and internet access will be provided in a breakout room\n convenient to and near the source code review room\u2014i.e., a room in close\n proximity to the source code review room; a reviewer shall be permitted to access\n the internet and use a personal cell phone in that room. The receiving Party shall\n not be permitted to bring the Source Code Computer from the review room into the\n breakout room;\n g. The producing Party may maintain a daily log of the names of persons who enter\n\n 9\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 11 of 29 PageID #:\n 246\n\n\n\n the designated facility to view the materials and when they enter and depart and\n may require reviewers for the receiving Party to sign the log indicating when they\n enter and depart the review room. The producing Party shall be entitled to have a\n person observe all entrances and exits from the reviewing room, but entrances and\n exits only, not the review itself. All access to the source code may be maintained\n on a source code Access Log identifying, for each and every time any source code\n is viewed, accessed, or analyzed: (1) the name of each person who accessed the\n code; (2) the date and time of access; and (3) the date and time at which such access\n ended;\n h. The producing Party will produce Source Code Material in computer searchable\n format on the Source Code Computers as described above. The receiving Party may\n request that the producing Party install certain licensed software to assist with\n review of the producing Party\u2019s Source Code Material. Any costs associated with\n acquiring licenses to requested software tools shall be borne by the receiving Party.\n Such request shall be subject to the approval of the producing Party, which shall\n not be unreasonably withheld. To allow the producing Party reasonable time to\n prepare the Source Code Computers, the receiving Party must provide the\n producing Party the computer medium (e.g., CD, DVD, USB drive, or FTP)\n containing the requested software tools at least ten (10) business days in advance\n of the inspection. The producing Party will install and confirm installation of said\n software on the Source Code Computers prior to the date the receiving Party seeks\n access. The receiving Party shall not erase, load, install, or otherwise modify any\n program on the Source Code Computer without first submitting a written request\n and obtaining the producing Party\u2019s agreement to the request.\n i. Access to Protected Material designated RESTRICTED CONFIDENTIAL\n SOURCE CODE shall be limited to outside counsel and up to three (3) outside\n consultants or experts (i.e., not existing employees or affiliates of a Party or\n competitor of the producing Party) retained for the purpose of this litigation and\n approved to access such Protected Materials pursuant to the Protective Order\n applicable to this Action2;\n j. A receiving Party may include excerpts of Source Code Material in a pleading,\n exhibit, expert report, discovery document, deposition transcript, or other Court\n document (\u201cSource Code Documents\u201d), provided that the Source Code Documents\n are appropriately marked under this Order, restricted to those who are entitled to\n have access to them as specified herein, and, if filed with the Court, filed under seal\n in accordance with the Court\u2019s rules, procedures and orders. Such material may not\n leave the United States of America, nor shall it be accessed from outside the United\n States of America without prior written agreement from the producing Party.\n\n\n2\n For the purposes of this paragraph, an outside consultant or expert is defined to include the outside\nconsultant\u2019s or expert\u2019s direct reports and other support personnel, such that the disclosure to a\nconsultant or expert who employs others within his or her firm to help in his or analysis shall count\nas a disclosure to a single consultant or expert.\n\n 10\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 12 of 29 PageID #:\n 247\n\n\n\n Compliance with all export controls is the sole responsibility of the receiving Party.\n k. To the extent portions of Source Code Material are quoted in a Source Code\n Document, either (1) the entire Source Code Document will be stamped and treated\n as RESTRICTED CONFIDENTIAL SOURCE CODE or (2) those pages\n containing quoted Source Code Material will be separately stamped and treated as\n RESTRICTED CONFIDENTIAL SOURCE CODE;\n l. Except as set forth herein or unless otherwise agreed to by the Parties, no electronic\n copies of Source Code Material shall be made without the prior written consent of\n the producing Party, except as necessary to create documents which, pursuant to\n the Court\u2019s rules, procedures, and orders, must be filed, served, or shown\n electronically;\n m. The receiving Party shall be permitted up to four printouts of Source Code Material,\n as set out above in paragraph 11(a), and further all of which shall be requested from\n and printed by the producing Party on paper bearing Bates numbers and the legend\n \u201cRESTRICTED CONFIDENTIAL SOURCE CODE.\u201d Any printouts of Source\n Code Material must be made on colored (i.e., non-white) paper. Within five (5)\n business days of the request for printouts, the producing Party shall provide the\n printouts to the receiving Party;\n n. Should such printouts be transferred back to electronic media, such media shall be\n labeled \u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d and shall continue\n to be treated as such;\n o. The receiving Party\u2019s outside counsel shall maintain a log of all copies of the\n Source Code Printouts (received from a producing Party) that are delivered by the\n receiving Party to any person and a log of any electronic images of Source Code\n Material. The log shall include the names of the recipients and reviewers of copies\n and address(es) where the copies are stored. Upon request by the producing Party,\n the receiving Party shall provide reasonable assurances and/or descriptions of the\n security measures employed by the receiving Party and/or person that receives a\n copy of any portion of Source Code Material;\n\n p. If the receiving Party\u2019s outside counsel, consultants, or experts obtain printouts of\n Source Code Material, the receiving Party shall ensure that such outside counsel,\n consultants, or experts keep the printouts in a secured locked area in the offices of\n such outside counsel, consultants, or expert. The receiving Party may also\n temporarily keep the printouts at: (i) the Court for any proceeding(s) relating to the\n Source Code Material, for the dates associated with the proceeding(s); (ii) the sites\n where any deposition(s) relating to the Source Code Material are taken, for the dates\n associated with the deposition(s); and (iii) any intermediate location reasonably\n necessary to transport the printouts (e.g., a hotel prior to a Court proceeding or\n deposition). Copies of source code that are marked as deposition exhibits shall not\n be provided to the Court Reporter or attached to deposition transcripts; rather, the\n deposition record will identify the exhibit by its production numbers, unless\n otherwise agreed by the producing Party. All paper copies of source code brought\n\n 11\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 13 of 29 PageID #:\n 248\n\n\n\n to the deposition must be returned to the receiving Counsel following the deposition\n for secure transport back to the secured locked area in the offices of the receiving\n Counsel;\n q. A producing Party\u2019s Source Code Material may only be transported by the\n receiving Party at the direction of a person authorized under paragraph 11(j) above\n to another person authorized under paragraph 11(j) above, on paper or removable\n electronic media (e.g., a DVD, CD-ROM, or flash memory \u201cstick\u201d) via hand carry,\n Federal Express, or other similarly reliable courier. Any such removable electronic\n media must be encrypted using commercially reasonable encryption software\n including password protection. Except for purposes of serving, filing, or\n transmitting a pleading, exhibit, expert report, discovery document, deposition\n transcript, or other Court document, Source Code Material may not be transported\n or transmitted electronically over a network of any kind, including a LAN, an\n intranet, or the Internet. Source Code Material may only be transported\n electronically for the purpose of Court proceeding(s) or deposition(s) as set forth in\n paragraph 11(q) above and is at all times subject to the transport restrictions set\n forth herein. But, for those purposes only, the Source Code Materials may be loaded\n onto a stand-alone computer without prior consent from the producing Party or as\n necessary to file with the Court or serve documents which, pursuant to the Court\u2019s\n rules, procedures and order, must be filed or served electronically under seal;\n r. No other copying or transcribing of Source Code Material is allowed beyond that\n described in this Protective Order. No person shall copy, e-mail, transmit, upload,\n download, print, photograph or otherwise duplicate any portion of the Source Code\n Material, unless explicitly permitted by this Protective Order; and\n\n s. Designated Source Code Material of a producing Party may not be used or\n discussed in any way in a mock trial or any other form of jury testing exercise. This\n does not preclude a Party from discussing source code generally, or using some\n form of pseudo code.\n 12. Any attorney representing a Party, whether in-house or outside counsel, and any\n\nperson who is both associated with a Party and permitted to receive the other Party\u2019s Protected\n\nMaterial that is designated RESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY and/or RESTRICTED\n\nCONFIDENTIAL SOURCE CODE (collectively, \u201cHIGHLY SENSITIVE MATERIAL\u201d), who\n\nobtains, receives, has access to, or otherwise learns, in whole or in part, the other Party\u2019s HIGHLY\n\nSENSITIVE MATERIAL under this Order shall not prepare, prosecute, supervise, or assist in the\n\npreparation or prosecution of any patent application pertaining to the field of the invention of the\n\npatents-in-suit on behalf of the receiving Party or its acquirer, successor, predecessor, or other\n\n 12\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 14 of 29 PageID #:\n 249\n\n\n\naffiliate during the pendency of this Action and for one year after its conclusion, including any\n\nappeals. To ensure compliance with the purpose of this provision, each Party shall create an\n\n\u201cEthical Wall\u201d between those persons with access to HIGHLY SENSITIVE MATERIAL and any\n\nindividuals who prepare, prosecute, supervise or assist in the preparation or prosecution of any\n\npatent application pertaining to the field of the invention of the patents-in-suit. Nothing in this\n\nOrder shall prevent a person with access to HIGHLY SENSITIVE MATERIAL from participating\n\nin a PTO proceeding, e.g., IPR or PGR, except for that person shall not participate\u2014directly or\n\nindirectly\u2014in the amendment of any claim(s).\n\n 13. Should a Party elect to utilize artificial intelligence (\u201cAI\u201d) to assist in reviewing,\n\nanalyzing, translating or summarizing discovery material produced or exchanged in this litigation,\n\nthe Party shall take all necessary steps to ensure that the application, service, or analytical software\n\nis fully containerized. \u201cFully containerized,\u201d as used in this Order, means an AI tool that does not\n\nretain the substance of a prompt or documents reviewed, share the substance of a prompt or\n\ndocuments reviewed for training or improvement of large language models, or use the substance\n\nof a prompt or documents reviewed in any other matter or inquiry other than these Actions. For\n\nthe avoidance of doubt, this restriction expressly applies to the use of non-containerized advanced\n\nlarge language models, generative AI tools, and other advanced AI systems, including, but not\n\nlimited to, OpenAI, Anthropic, Gemini, LLAMA, MidJourney, and Stable Diffusion, but this\n\nprovision does not limit the use of services leveraging the technology underlying these generative\n\nAI tools in a fully containerized environment, including, but not limited to, Copilot Enterprise,\n\nHarvey, Relativity aiR, Solve, Patlytics, DISCO Cecelia, Everlaw AI, Syllo, Alchemy, Lexis+ AI,\n\nEpiq AIDA, and Lighthouse AI. Before submitting any DESIGNATED MATERIAL to a fully\n\ncontainerized AI tool, a Receiving Party shall ensure that it (or its vendor) can delete all such\n\n\n\n 13\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 15 of 29 PageID #:\n 250\n\n\n\nDESIGNATED MATERIAL from the AI tool at the conclusion of this matter, including any\n\nderivative information stored within the tool. To be clear, any person or entity in possession of\n\nDESIGNATED MATERIAL produced or exchanged in this litigation shall not submit such\n\nDESIGNATED MATERIAL or summary thereof to any open generative AI tool that is available\n\nto the public, so that the DESIGNATED MATERIAL is not further disclosed or used in any\n\nmanner inconsistent with this Order. The obligations and restrictions of this paragraph apply even\n\nwhere the DESIGNATED MATERIAL has been anonymized.\n\n 14. Disclosure of Protected Material shall be subject to all applicable laws and\n\nregulations relating to the export of technical data contained in such Protected Material, including\n\nthe release of such technical data to foreign persons or nationals in the United States or elsewhere.\n\nSee, e.g., 15 CFR Part 734. [Semantic: Any material subject to governmental export control\n\nrestrictions that precludes it from being taken beyond the territorial boundaries of the United States\n\nof America or being made available to any foreign national who is not (i) lawfully admitted for\n\npermanent residence in the United States or (ii) identified as a protected individual under the\n\nImmigration and Naturalization Act (8 U.S.C. \u00a7 1324b(a)(3)) shall be designated by the Party\n\nproducing it by placing the words \u201cEXPORT CONTROLLED\u201d clearly on each page of such\n\n\n\n\n 14\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 16 of 29 PageID #:\n 251\n\n\n\nmaterial.]3 4 [Microsoft: The viewing of Protected Material] [Semantic: EXPORT CONTROLLED\n\nmaterial] in physical form and/or through electronic means outside the territorial limits of the\n\nUnited States of America is prohibited. The restrictions contained within this paragraph may be\n\namended through the consent of the producing Party to the extent that such agreed to procedures\n\nconform with applicable export control laws and regulations.]\n\n 15. Nothing in this Order shall require production of documents, information or other\n\nmaterial that a Party contends is protected from disclosure by the attorney-client privilege, the\n\n\n3\n Semantic Position: As proposed by Microsoft, Paragraph 14 categorically precludes the viewing\nof Protected Material outside the United States. There is no justification for such a provision\u2014one\nat odds with Microsoft\u2019s own publicly reported history of disclosing technical material to non-U.S.\ncitizens as part of its day-to-day operations.\nhttps://www.grassley.senate.gov/imo/media/doc/grassley_durbin_to_microsoft_-_h-1b.pdf. In\nparticular, as reported by the Judiciary Committee of the United States Senate, Microsoft was \u201cthe\nthird-largest employer of newly approved H1-B visa beneficiaries in the nation\u201d in 2025. Id.\nInstead, to the extent Paragraph 14 is adopted at all, it should be limited as Semantic proposes such\nthat (1) it applies only to limit the disclosure of material actually subject to United States export\ncontrol laws and (2) the party producing such materials must explicitly designate them as EXPORT\nCONTROLLED so that the receiving Party is aware of such limitations. Such conditions are driven\nby common sense and practicality. First, not all DESIGNATED MATERIAL is subject to United\nStates export control laws. As such, the disclosure limitations specified in this paragraph should\nbe limited to those materials that actually are subject to United States export control restrictions.\nSecond, the producing Party is the party in the best position to know which of its produced\nmaterials are subject to export control restrictions. Accordingly, the producing Party should be\nrequired to explicitly designate any such material as EXPORT CONTROLLED to put the\nreceiving Party on notice of its obligations with respect to them. After all, Semantic otherwise will\nhave no way to know what materials Microsoft believes are subject to export control restrictions.\n4\n Microsoft Position: Microsoft has included the export control provision given its role as a\ntechnology company and the potential for discovery to include information that cannot be exported\npursuant to United States law. Microsoft\u2019s proposal does not categorically preclude disclosure of\nProtected Material to non-U.S. citizens; it merely states that export control laws may apply and\nprohibits viewing of protected material outside of the United States, regardless of who is viewing.\nAlthough Semantic has not disclosed whether it intends to disclose any Protected Information to\npersons who would be prohibited from accessing materials due to export control laws and/or\nMicrosoft\u2019s proposal, to the extent it does, the parties should meet and confer regarding any\nproposed exceptions to those prohibitions and/or whether and how to further designate information\nprovided in discovery. Moreover, all parties are subject to applicable export control laws regardless\nof the provisions here, rendering Semantic\u2019s more detailed and burdensome proposal ineffective\nand impractical.\n 15\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 17 of 29 PageID #:\n 252\n\n\n\nwork product doctrine, or other privilege, doctrine, or immunity. If documents, information or\n\nother material subject to a claim of attorney-client privilege, work product doctrine, or other\n\nprivilege, doctrine, or immunity is inadvertently or unintentionally produced, pursuant to Federal\n\nRule of Evidence 502(d), such production shall in no way prejudice or otherwise constitute a\n\nwaiver of, or estoppel as to, any such privilege, doctrine, or immunity in this or any other federal,\n\nstate, local, or administrative proceeding. Any Party that inadvertently or unintentionally produces\n\ndocuments, information, or other material it reasonably believes are protected under the attorney-\n\nclient privilege, work product doctrine, or other privilege, doctrine, or immunity may obtain the\n\nreturn or destruction of such documents, information, or other material by promptly notifying the\n\nrecipient(s) and providing a privilege log for the inadvertently or unintentionally produced\n\ndocuments, information, or other material. The recipient(s) shall, within three (3) business days of\n\nbeing notified, gather and return or destroy all copies of such documents, information, or other\n\nmaterial to the producing Party, except for any pages containing privileged or otherwise protected\n\nmarkings by the recipient(s), which pages shall instead be destroyed and certified as such to the\n\nproducing Party. If the recipient(s) contest the privilege or work product designation by the\n\nproducing Party, the recipient(s) shall provide written notice of the reasons for disputing the claim\n\nof privilege, and the Parties shall confer in good faith to resolve the dispute. The receiving Party\n\nmay move the Court for an Order compelling production of such information, but the motion shall\n\nnot assert as a ground for production the fact or circumstances of the inadvertent or unintentional\n\nproduction. If a claim is disputed, the receiving Party shall not use or disclose a document or\n\ninformation for which a claim of privilege or immunity is made pursuant to this Paragraph for any\n\npurpose until the matter is resolved by agreement of the parties or by a decision of this Court.\n\n 16. There shall be no disclosure of any DESIGNATED MATERIAL by any person\n\n\n\n 16\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 18 of 29 PageID #:\n 253\n\n\n\nauthorized to have access thereto to any person who is not authorized for such access under this\n\nOrder. The Parties are hereby ORDERED to safeguard all such documents, information and\n\nmaterial to protect against disclosure to any unauthorized persons or entities.\n\n 17. Any person in possession of another Party\u2019s DESIGNATED MATERIAL shall\n\nexercise the same degree of care with respect to its storage, custody, and use that such person\n\napplies to its own information of comparable sensitivity, but in no event less than reasonable\n\nprecautions to protect against loss, misuse, or unauthorized access, disclosure, alteration, or\n\ndestruction of such DESIGNATED MATERIAL. If a receiving Party discovers a breach of\n\nsecurity involving another Party\u2019s DESIGNATED MATERIAL, it shall, no later than twenty-four\n\n(24) hours after discovery of the breach: (a) provide written notice of the breach to the designating\n\nParty; (b) investigate and remediate the effects of the breach; and (c) provide the designating Party\n\nwith sufficient information to reasonably ascertain the size and scope of the breach, and shall\n\nthereafter cooperate reasonably with the designating Party in investigating the breach.\n\n 18. Nothing contained herein shall be construed to prejudice any Party\u2019s right to use\n\nany DESIGNATED MATERIAL in taking testimony at any deposition or hearing provided that\n\nthe DESIGNATED MATERIAL is only disclosed to a person(s) who is: (i) eligible to have access\n\nto the DESIGNATED MATERIAL by virtue of his or her employment with the designating Party,\n\n(ii) identified in the DESIGNATED MATERIAL as an author, addressee, or copy recipient of such\n\ninformation, (iii) although not identified as an author, addressee, or copy recipient of such\n\nDESIGNATED MATERIAL, has, in the ordinary course of business, seen such DESIGNATED\n\nMATERIAL, (iv) a current or former officer, director or employee of the producing Party or a\n\ncurrent or former officer, director or employee of a company affiliated with the producing Party;\n\n(v) counsel for a Party, including outside counsel and in-house counsel (subject to paragraph 10\n\n\n\n 17\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 19 of 29 PageID #:\n 254\n\n\n\nof this Order); (vi) an independent contractor, consultant, and/or expert retained for the purpose of\n\nthis litigation; (vii) court reporters and videographers; (viii) the Court; or (ix) other persons entitled\n\nhereunder to access to DESIGNATED MATERIAL. DESIGNATED MATERIAL shall not be\n\ndisclosed to any other persons unless prior authorization is obtained from counsel representing the\n\nproducing Party or from the Court.5\n\n 19. Parties may, at the deposition or hearing or within thirty (30) days after receipt of\n\na deposition or hearing transcript, designate the deposition or hearing transcript or any portion\n\nthereof as \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or\n\n\u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d pursuant to this Order. Access to the\n\ndeposition or hearing transcript so designated shall be limited in accordance with the terms of this\n\nOrder. Until expiration of the 30-day period, the entire deposition or hearing transcript shall be\n\ntreated as RESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY.\n\n 20. The existence of this Protective Order must be disclosed to any person producing\n\ndocuments, tangible things, or testimony in this action who may reasonably be expected to desire\n\nconfidential treatment for such documents, tangible things, or testimony. Any such person or any\n\nParty may designate documents, tangible things, or testimony confidential pursuant to this\n\nProtective Order.\n\n 21. Any DESIGNATED MATERIAL that is filed with the Court shall be filed under\n\nseal pursuant to the applicable Court orders or procedures regarding motions to seal, including\n\n\n\n5\n In the event a non-Party witness is authorized to receive Protected Material that is to be used\nduring his/her deposition but is represented by an attorney not authorized under this Order to\nreceive such Protected Material, such attorney shall be subject to the limitations of this Order and\nshall be requested prior to commencement of the deposition to execute the Undertaking attached\nas Appendix A. In the event such attorney declines to sign the Undertaking prior to the\nexamination, any party may seek a protective order from the Court prohibiting the attorney from\ndisclosing Protected Material to any person not authorized under this Order.\n 18\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 20 of 29 PageID #:\n 255\n\n\n\nL.R. CV-5(7), and shall remain under seal until further order of the Court. The filing Party shall\n\nbe responsible for informing the Clerk of the Court that the filing should be sealed and for placing\n\nthe legend \u201cFILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER\u201d above the caption\n\nand conspicuously on each page of the filing. Exhibits to a filing shall conform to the labeling\n\nrequirements set forth in this Order. The filing Party thereafter shall file a redacted copy of such\n\nfiling within fourteen (14) days. To effectuate such filing, within three (3) business days of filing\n\nDESIGNATED MATERIAL under seal, the filing Party shall provide any Party whose\n\nDESIGNATED MATERIAL is involved with a proposed redacted version of the submission\n\nintended for the public file, unless the entire document is confidential information. Any Party\n\nobjecting to the proposed redactions must notify the filing Party within two (2) business days of\n\nreceipt of any requested modifications, and the filing Party must accept, reject, or negotiate the\n\nrequested modifications within two (2) business days thereafter. If no agreement is reached, the\n\nParty seeking broader redactions must file a motion with the Court explaining why the broader\n\nredactions are warranted and requesting an extension of the fourteen (14) day period in which the\n\nfiling party is to submit the redacted version. If a pretrial pleading filed with the Court, or an exhibit\n\nthereto, discloses or relies on DESIGNATED MATERIAL, such confidential portions shall be\n\nredacted to the extent necessary and the pleading or exhibit filed publicly with the Court.\n\n 22. The Order applies to pretrial discovery. Nothing in this Order shall be deemed to\n\nprevent the Parties from introducing any DESIGNATED MATERIAL into evidence at the trial of\n\nthis Action, or from using any information contained in DESIGNATED MATERIAL at the trial\n\nof this Action, subject to any pretrial order issued by this Court.\n\n 23. A Party may request in writing to the other Party that the designation given to any\n\nDESIGNATED MATERIAL be modified or withdrawn. The written request shall describe the\n\n\n\n 19\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 21 of 29 PageID #:\n 256\n\n\n\nbasis for the challenge. The designating Party must respond within five (5) business days of\n\nreceiving the request by either agreeing to modify the designation or explaining why it believes\n\nthe designation is proper. If the designating Party does not agree to redesignation within ten (10)\n\nbusiness days of receipt of the written request, the requesting Party may apply to the Court for\n\nrelief. Upon any such application to the Court, the burden shall be on the designating Party to show\n\nwhy its classification is proper. Such application shall be treated procedurally as a motion to\n\ncompel pursuant to Federal Rules of Civil Procedure 37, subject to the Rule\u2019s provisions relating\n\nto sanctions. In making such application, the requirements of the Federal Rules of Civil Procedure\n\nand the Local Rules of the Court shall be met. Pending the Court\u2019s determination of the application,\n\nthe designation of the designating Party shall be maintained.\n\n 24. Each outside consultant or expert, each designated representative identified\n\npursuant to paragraph 5(d), each independent litigation support service provider identified\n\npursuant to paragraph 5(f), and any deposition witness shown HIGHLY SENSITIVE MATERIAL,\n\nto whom DESIGNATED MATERIAL is disclosed in accordance with the terms of this Order shall\n\nbe advised by counsel of the terms of this Order and shall be informed that he or she is subject to\n\nthe terms and conditions of this Order.\n\n 25. To the extent that any discovery is taken of persons who are not Parties to this\n\nAction (\u201cThird Parties\u201d) and in the event that such Third Parties contend the discovery sought\n\ninvolves trade secrets, confidential business information, or other proprietary information, then\n\nsuch Third Parties may agree to be bound by this Order.\n\n 26. To the extent that discovery or testimony is taken of Third Parties, the Third Parties\n\nmay designate as \u201cCONFIDENTIAL\u201d, \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY\u201d, or\n\n\u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d any documents, information or other\n\n\n\n 20\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 22 of 29 PageID #:\n 257\n\n\n\nmaterial, in whole or in part, produced, given, or made available for inspection by such Third\n\nParties. The Third Parties shall have ten (10) days after production of such documents, information,\n\nor other materials to make such a designation. Until that time period lapses or until such a\n\ndesignation has been made, whichever occurs sooner, all documents, information, or other material\n\nso produced or given shall be treated as \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY\u201d in\n\naccordance with this Order.\n\n 27. If a Party is served with a subpoena or court order in other litigation that compels\n\ndisclosure of any DESIGNATED MATERIAL produced in this Action, that Party shall: (a)\n\npromptly notify the designating Party in writing, enclosing a copy of the subpoena or order; and\n\n(b) promptly notify in writing the party who caused the subpoena or order to issue that some or all\n\nof the material sought is subject to this Order, enclosing a copy of this Order. The Party served\n\nwith the subpoena or order shall not produce any DESIGNATED MATERIAL before a\n\ndetermination by the court from which the subpoena or order issued, unless it has obtained the\n\ndesignating Party\u2019s permission, and the designating Party shall bear the burden and expense of\n\nseeking protection of its DESIGNATED MATERIAL in that other proceeding.\n\n 28. If a Party is required by a valid discovery request in this Action to produce a Third\n\nParty\u2019s confidential material that is in its possession, and the Party is subject to an agreement with\n\nthe Third Party not to produce such material, the Party shall: (a) promptly notify the requesting\n\nParty and the Third Party in writing that some or all of the material requested is subject to a\n\nconfidentiality agreement with the Third Party; (b) promptly provide the Third Party with a copy\n\nof this Order, the relevant discovery request(s), and a reasonably specific description of the\n\ninformation requested; and (c) make the requested information available for inspection by the\n\nThird Party. If the Third Party fails to object or seek a protective order within fourteen (14) days\n\n\n\n 21\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 23 of 29 PageID #:\n 258\n\n\n\nof receiving such notice, the Party may produce the Third Party\u2019s material in response to the\n\ndiscovery request. If the Third Party timely seeks a protective order, the Party shall not produce\n\nthe material before a determination by the Court, and the Third Party shall bear the burden and\n\nexpense of seeking protection of its material.\n\n 29. \u201cProtected Data\u201d refers to any information that a Party or Non-Party reasonably\n\nbelieves to be subject to federal, state, or foreign Data Protection Laws or other privacy obligations.\n\nExamples of such Data Protection Laws include, without limitation, The Gramm-Leach-Biley Act,\n\n15 U.S.C. \u00a7 6801 et seq. (financial information); The Health Insurance Portability and\n\nAccountability Act (\u201cHIPAA\u201d) and the regulations thereunder, 45 CFR Part 160 and Subparts A\n\nand E of Part 164 (medical information); Regulation (EU) 2016/679 Of the European Parliament\n\nand of the Council of 27 April 2016 on the Protection of Natural Persons with Regard to the\n\nProcessing of Personal Data and on the Free Movement of Such Data, also known as the General\n\nData Protection Regulation (\u201cGDPR\u201d). To the extent a party contends that DESIGNATED\n\nMATERIAL constitutes Protected Data that requires additional safeguards pursuant to Federal,\n\nState, or foreign statutes, regulations, or privacy obligations, the parties shall meet and confer\n\nregarding such issues. To the extent that the parties are unable to reach agreement, the burden shall\n\nbe on the producing Party to promptly seek a protective order regarding the production of such\n\nmaterials.\n\n 30. Except as necessary to comply with P.R. 3-7, the parties agree that any documents\n\nor information not shared with a third party (other than a retained litigation expert or consultant)\n\nand withheld from discovery solely on grounds of attorney-client privilege or work product that\n\narose or came into existence after April 23, 2026, are exempt from privilege log disclosure\n\nrequirements. [Semantic\u2019s Proposal: In addition, (i) attorney work-product materials created by or\n\n\n\n 22\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 24 of 29 PageID #:\n 259\n\n\n\non behalf of a party\u2019s outside litigation counsel of record regarding the above-captioned action in\n\nwhich such counsel represent the party; and (ii) privileged communications between a party and\n\nits outside litigation counsel of record regarding the above-captioned action in which such counsel\n\nrepresent the party, do not need to be included on any privilege log.]6 7 However, this provision\n\nshall not constitute a waiver of a party\u2019s right to specifically request privilege logs covering\n\nspecific categories of documents created before or after the filing of the Complaint, upon a showing\n\nof good cause.\n\n 31. The provisions of this Order shall continue to be binding after final termination of\n\n\n\n6\n Semantic Position: To the extent relevant at all, attorney-client communications between a party\nand its outside litigation counsel of record and work product created by or on behalf of a party\u2019s\noutside litigation counsel of record are privileged. Accordingly, requiring the parties\n(predominately Plaintiff) to log such materials imposes a significant burden and costs with no\ncountervailing discovery benefit. Indeed, the commonsense benefit of the provision is\ndemonstrated by the fact that Microsoft agreed to it in the Discovery Order entered in ParTec AG\nv. Microsoft Corp., No. 2:24-cv-00433-RWS, ECF No. 22 (E.D. Tex. Oct. 2, 2024). Moreover,\nthere is no countervailing benefit. Contrary to Microsoft\u2019s point below, not only is it irrelevant\nwhen Semantic first became aware of the alleged infringement and/or conducted a pre-suit\ninvestigation, but the provision of a log would not disclose any such information in any case.\nFurther, to the extent Microsoft believes otherwise, the provision includes a good cause exception\nin the following sentence, which preserves each party\u2019s right to request targeted privilege logs for\ngood cause. As for the remainder of Microsoft\u2019s arguments, the reality is that\u2014despite having\nSemantics position for weeks\u2014Microsoft made its request for evidence of the burden its position\nwould impose for the first time at 11:11 pm CT on the day the parties\u2019 submission was due. Had\nMicrosoft made its request in a timely manner, Semantic could have addressed it during the parties\u2019\nmeet and confers.\n7\n Microsoft Position: This paragraph addresses exceptions to the usual rules regarding logging\ndocuments withheld on the basis of a privilege or protection. In cases of all kinds, the standard is\nthat documents predating the complaint must be logged, including in cases to which Microsoft is\nor has been a party in this District. Microsoft is entitled via discovery to the types of nonprivileged\nrelevant facts that appear on a privilege log, and it should not have to spend additional resources\nestablishing good cause to test when, for example, Semantic first became aware of the alleged\ninfringement or conducted a pre-suit investigation, if any, which are relevant to Microsoft\u2019s\ndefenses. Microsoft notified Semantic by email on August 6 that Microsoft wished to discuss the\n\u201csignificant burden and costs\u201d of logging this information, and during the parties\u2019 meet and confer\non August 7, Microsoft asked Semantic for this information, but Semantic did not respond and so\nhas not substantiated its purported burden.\n 23\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 25 of 29 PageID #:\n 260\n\n\n\nthis case until a producing Party agrees otherwise in writing or a court order otherwise directs.\n\nWithin sixty (60) days of final termination of this Action, including any appeals, all\n\nDESIGNATED MATERIAL, including all copies, duplicates, abstracts, indexes, summaries,\n\ndescriptions, and excerpts or extracts thereof (excluding excerpts or extracts incorporated into any\n\nprivileged memoranda of the Parties and materials which have been admitted into evidence in this\n\nAction), shall at the producing Party\u2019s election either be returned to the producing Party or be\n\ndestroyed. The receiving Party shall verify the return or destruction by affidavit furnished to the\n\nproducing Party, upon the producing Party\u2019s request. However, notwithstanding this requirement,\n\ncounsel may retain for archival purposes copies of any court filings, pleadings, motions and trial\n\nbriefs (including all supporting and opposing papers and exhibits thereto), written discovery\n\nrequests and responses (and exhibits thereto), deposition transcripts (and exhibits thereto), trial\n\ntranscripts, attorney work product, communications, consultant and expert work product, and\n\nexhibits offered or introduced into evidence at any hearing or trial that contain or constitute\n\nProtected Material or DESIGNATED MATERIAL , provided such counsel was entitled to receive\n\nsuch material prior to the final termination of this matter. Any such archived copies that contain\n\nor constitute Protected Material remain subject to this Order and shall be maintained in confidence\n\nby such counsel. Any destruction obligations under this Protective Order shall not apply to\n\nelectronically-stored information in archival form stored on backup tapes or computer servers that\n\nare created only for disaster recovery purposes, provided that such electronic archives are not used\n\nas reference materials for a receiving Party\u2019s business operations, and further counsel shall not be\n\nrequired to delete DESIGNATED MATERIAL that may reside on their respective firms\u2019 or\n\nvendors\u2019 electronic disaster recovery systems that are overwritten in the ordinary course of\n\nbusiness, or that may reside in electronic files that are not reasonably accessible, provided that no\n\n\n\n 24\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 26 of 29 PageID #:\n 261\n\n\n\nParty or its counsel shall retrieve, access, or use any such DESIGNATED MATERIAL from such\n\nsystems or sources after conclusion of this Action.\n\n 32. The failure to designate documents, information, or material in accordance with\n\nthis Order and the failure to object to a designation at a given time shall not preclude the later\n\ndesignation of such documents, information, or material, or the filing of a motion at a later date\n\nseeking to impose such designation or challenging the propriety thereof. The entry of this Order\n\nand/or the production of documents, information and material hereunder shall in no way constitute\n\na waiver of any objection to the furnishing thereof, all such objections being hereby preserved.\n\n 33. Any Party knowing or believing that any other Party is in violation of or intends to\n\nviolate this Order and has raised the question of violation or potential violation with the opposing\n\nParty and has been unable to resolve the matter by agreement may move the Court for such relief\n\nas may be appropriate in the circumstances. Pending disposition of the motion by the Court, the\n\nParty alleged to be in violation of or intending to violate this Order shall discontinue the\n\nperformance of and/or shall not undertake the further performance of any action alleged to\n\nconstitute a violation of this Order.\n\n 34. Production of DESIGNATED MATERIAL by each of the Parties shall not be\n\ndeemed a publication of the documents, information and material (or the contents thereof)\n\nproduced so as to void or make voidable whatever claim the Parties may have as to the proprietary\n\nand confidential nature of the documents, information or other material or its contents.\n\n 35. Nothing in this Order shall be construed to effect an abrogation, waiver or limitation\n\nof any kind on the rights of each of the Parties to assert any applicable discovery or trial privilege.\n\n 36. Each of the Parties shall also retain the right to file a motion with the Court (a) to\n\nmodify this Order to allow disclosure of DESIGNATED MATERIAL to additional persons or\n\n\n\n 25\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 27 of 29 PageID #:\n 262\n\n\n\nentities if reasonably necessary to prepare and present this Action and (b) to apply for additional\n\nprotection of DESIGNATED MATERIAL.\n\n\n\n\n 26\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 28 of 29 PageID #:\n 263\n\n\n\n IN THE UNITED STATES DISTRICT COURT\n FOR THE EASTERN DISTRICT OF TEXAS\n MARSHALL DIVISION\n\n SEMANTIC ENGINES LLC,\n\n Plaintiff,\n v. Civil Action No. 2:26-cv-339-JRG\n\n MICROSOFT CORPORATION,\n\n Defendant.\n\n\n\n APPENDIX A\n UNDERTAKING OF EXPERTS OR CONSULTANTS REGARDING\n PROTECTIVE ORDER\n I, ___________________________________________, declare that:\n\n1. My address is _________________________________________________________.\n\n My current employer is _________________________________________________.\n\n My current occupation is ________________________________________________.\n\n2. I have received a copy of the Protective Order in this action. I have carefully read and\n\n understand the provisions of the Protective Order.\n\n3. I will comply with all of the provisions of the Protective Order. I will hold in confidence,\n\n will not disclose to anyone not qualified under the Protective Order, and will use only for\n\n purposes of this action any information designated as \u201cCONFIDENTIAL,\u201d\n\n \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or \u201cRESTRICTED CONFIDENTIAL\n\n SOURCE CODE\u201d that is disclosed to me.\n\n4. Promptly upon termination of these actions, I will return all documents and things\n\n designated as \u201cCONFIDENTIAL,\u201d \u201cRESTRICTED \u2013 ATTORNEYS\u2019 EYES ONLY,\u201d or\n\n \u201cRESTRICTED CONFIDENTIAL SOURCE CODE\u201d that came into my possession, and\n\n\n\n\n 1\n\fCase 2:26-cv-00339-JRG Document 29-1 Filed 08/11/26 Page 29 of 29 PageID #:\n 264\n\n\n\n all documents and things that I have prepared relating thereto, to the outside counsel for\n\n the Party by whom I am employed.\n\n5. I hereby submit to the jurisdiction of this Court for the purpose of enforcement of the\n\n Protective Order in this action.\n\n I declare under penalty of perjury that the foregoing is true and correct.\n\nSignature ________________________________________\n\nDate ____________________________________________\n\n\n\n\n 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