Disney Enterprises, Inc. v. Minimax — Entry #63: Joint STIPULATION for Protective Order filed by Plaintiffs and Counterclaim Defendants DC Comics, Disney Enterprises, Inc., Dreamworks Animation L.L.C.…

Case 2:25-cv-08768-SB-E   Document 63 Filed 08/07/26   Page 1 of 19 Page ID
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 1 JENNER & BLOCK LLP
   David R. Singer (SBN 204699)
 2
   dsinger@jenner.com
 3 Julie A. Shepard (SBN 175538)
   jshepard@jenner.com
 4
   Lauren M. Greene (SBN 271397)
 5 lgreene@jenner.com
   515 South Flower Street, Suite 3300
 6
   Los Angeles, CA 90071-2246
 7 Telephone: (213) 239-5100
 8 Facsimile: (213) 239-5199
 9 Attorneys for Plaintiffs and
   Counterclaim-Defendants
10
11                        UNITED STATES DISTRICT COURT

12                     CENTRAL DISTRICT OF CALIFORNIA

13 DISNEY ENTERPRISES, INC.;                  Case No. 2:25-cv-08768-SB-E
   UNIVERSAL CITY STUDIOS
14
   PRODUCTIONS LLLP; WARNER
15 BROS. ENTERTAINMENT INC., et al.,          [PROPOSED] STIPULATED
                                              PROTECTIVE ORDER
16                         Plaintiffs,        Complaint filed: September 16, 2025
17     v.                                     Trial Date: July 12, 2027
18 MINIMAX, et al.,
19                         Defendants.
20
21 NANONOBLE PTE. LTD.,
22                         Counterclaimant,
23       v.
24
   DISNEY ENTERPRISES, INC.,
25 UNIVERSAL CITY STUDIOS
   PRODUCTIONS LLLP; WARNER
26
   BROS. ENTERTAINMENT INC., et al.,
27
               Counterclaim-Defendants.
28

                                              [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 1.      GENERAL
 2         1.1   Purposes and Limitations. Discovery in this action is likely to involve
 3 production of confidential, proprietary, or private information for which special
 4 protection from public disclosure and from use for any purpose other than prosecuting
 5 this litigation may be warranted. Accordingly, the parties hereby stipulate to and
 6 petition the Court to enter the following Stipulated Protective Order (the “Order”).
 7 The parties acknowledge that this Order does not confer blanket protections on all
 8 disclosures or responses to discovery and that the protection it affords from public
 9 disclosure and use extends only to the limited information or items that are entitled to
10 confidential treatment under the applicable legal principles. However, the parties
11 agree that all Discovery Material shall be used by the parties only for the purpose of
12 conducting this litigation, including any appellate proceedings, and not by anyone else
13 or for any other purpose. The parties further acknowledge, as set forth in Section 13.3,
14 below, that this Order does not entitle them to file confidential information under seal;
15 Civil Local Rule 79-5 sets forth the procedures that must be followed and the
16 standards that will be applied when a party seeks permission from the court to file
17 material under seal.
18         1.2   Good Cause Statement.
19         This action involves Defendants’ alleged infringement of Plaintiffs’
20 copyrighted works in connection with Defendants’ generative artificial intelligence
21 (AI) image and video service (“Defendants’ Service”). Discovery in this litigation
22 may include the development, training, operation, outputs, policies, business plans,
23 contractual arrangements and revenues of Defendants and their AI Service, some of
24 which Defendants consider and treat as confidential and/or proprietary. Likewise,
25 discovery may include information about Plaintiffs’ business plans and contractual
26 arrangements, as well as harms Plaintiffs allege are caused by Defendants’ Service,
27 some of which Plaintiffs consider and treat as confidential and/or proprietary.
28 Discovery into the foregoing types of information warrants protection from public
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                                                     [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 disclosure and from use for any purpose other than prosecution of this action. Such
 2 confidential and proprietary materials and information consist of, among other things,
 3 confidential business or financial information, information regarding confidential
 4 business practices, or other confidential research, development, or commercial
 5 information (including information implicating privacy rights of third parties),
 6 information otherwise generally unavailable to the public, or which may be privileged
 7 or otherwise protected from disclosure under state or federal statutes, court rules, case
 8 decisions, or common law.
 9         Accordingly, to expedite the flow of information, to facilitate the prompt
10 resolution of disputes over confidentiality of discovery materials, to adequately
11 protect information the parties are entitled to keep confidential, to ensure that the
12 parties are permitted reasonably necessary uses of such material in preparation for
13 and in the conduct of trial, to address their handling at the end of the litigation, and
14 serve the ends of justice, a protective order for such information is justified in this
15 matter. It is the intent of the parties that information will not be designated as
16 Confidential or Highly Confidential – Attorneys’ Eyes Only for tactical reasons and
17 that nothing be so designated without a good faith belief that it has been maintained
18 in a confidential, non-public manner, and there is good cause why it should not be
19 part of the public record of this case.
20 2.      DEFINITIONS
21         2.1   Action: this pending federal lawsuit.
22         2.2   Challenging Party: a Party or Non-Party that challenges the designation
23 of information or items under this Order.
24         2.3   “CONFIDENTIAL” Information or Items: information (regardless of
25 how it is generated, stored or maintained) or tangible things that qualify for protection
26 under Federal Rule of Civil Procedure 26(c).
27         2.4   Counsel: Outside Counsel of Record and House Counsel (as well as their
28 support staff).
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                                                     [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1         2.5   Designating Party: a Party or Non-Party that designates information or
 2 items that it produces in disclosures or in responses to discovery as
 3 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
 4 ONLY.”
 5         2.6   Disclosure or Discovery Material: all items or information, regardless
 6 of the medium or manner in which it is generated, stored, or maintained (including,
 7 among other things, testimony, transcripts, and tangible things), that are produced or
 8 generated in disclosures or responses to discovery in this matter.
 9         2.7   Expert: a person with specialized knowledge or experience in a matter
10 pertinent to the litigation who has been retained by a Party or its counsel to serve as
11 an expert witness or as a consultant in this Action.
12         2.8   “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
13 Information or Items: extremely sensitive “Confidential Information or Items,”
14 disclosure of which to another Party or Non-Party would create a substantial risk of
15 serious harm that could not be avoided by less restrictive means.
16         2.9   House Counsel: attorneys who are employees of a party to this Action.
17 House Counsel does not include Outside Counsel of Record or any other outside
18 counsel.
19         2.10 Non-Party: any natural person, partnership, corporation, association, or
20 other legal entity not named as a Party to this action.
21         2.11 Outside Counsel of Record: attorneys who are not employees of a party
22 to this Action but are retained to represent or advise a party to this Action and have
23 appeared in this Action on behalf of that party or are affiliated with a law firm that
24 has appeared on behalf of that party, including support staff. For the avoidance of
25 doubt, separate firms or solo practitioners cannot be Counsel of Record unless they
26 formally appear in the case.
27
28
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                                                    [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1        2.12 Party: any party to this Action, including all of its officers, directors,
 2 employees, consultants, retained experts, and Outside Counsel of Record (and their
 3 support staffs).
 4        2.13 Producing Party: a Party or Non-Party that produces Disclosure or
 5 Discovery Material in this Action.
 6        2.14 Professional Vendors: persons or entities that provide litigation support
 7 services (e.g., photocopying, videotaping, translating, preparing exhibits or
 8 demonstrations, and organizing, storing, or retrieving data in any form or medium)
 9 and their employees and subcontractors.
10        2.15 Protected Material:      any Disclosure or Discovery Material that is
11 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’
12 EYES ONLY.”
13        2.16 Receiving Party: a Party that receives Disclosure or Discovery Material
14 from a Producing Party.
15 3.     SCOPE
16        The protections conferred by this Order cover not only Protected Material (as
17 defined above), but also (1) any information copied or extracted from Protected
18 Material; (2) all copies, excerpts, summaries, or compilations of Protected Material;
19 and (3) any testimony, conversations, or presentations by Parties or their Counsel that
20 might reveal Protected Material.
21        Any use of Protected Material at trial shall be governed by the orders of the
22 trial judge. This Order does not govern the use of Protected Material at trial.
23 4.     DURATION
24        Once a case proceeds to trial, all of the court-filed information to be introduced
25 that was previously designated as confidential or maintained pursuant to this
26 protective order becomes public and will be presumptively available to all members
27 of the public, including the press, unless compelling reasons supported by specific
28 factual findings to proceed otherwise are made to the trial judge in advance of the
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                                                    [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 trial. See Kamakana v. City and Cty. of Honolulu, 447 F.3d 1172, 1180-81 (9th Cir.
 2 2006) (distinguishing “good cause” showing for sealing documents produced in
 3 discovery from “compelling reasons” standard when merits-related documents are
 4 part of court record). Accordingly, the terms of this protective order do not extend
 5 beyond the commencement of the trial.             Notwithstanding the foregoing, the
 6 obligations set forth in Sections 7.1, 10, and 13 of this Order shall survive the final
 7 disposition of this Action.
 8 5.      DESIGNATING PROTECTED MATERIAL
 9         5.1     Exercise of Restraint and Care in Designating Material for Protection.
10 Each Party or Non-Party that designates information or items for protection under this
11 Order must take care to limit any such designation to specific material that qualifies
12 under the appropriate standards. To the extent it is practical to do so, the Designating
13 Party must designate for protection only those parts of material, documents, items, or
14 oral or written communications that qualify so that other portions of the material,
15 documents, items, or communications for which protection is not warranted are not
16 swept unjustifiably within the ambit of this Order.
17         Mass, indiscriminate, or routinized designations are prohibited. Designations
18 that are shown to be clearly unjustified or that have been made for an improper
19 purpose (e.g., to unnecessarily encumber the case development process or to impose
20 unnecessary expenses and burdens on other parties) may expose the Designating Party
21 to sanctions.
22         If it comes to a Designating Party’s attention that information or items that it
23 designated for protection do not qualify for protection, that Designating Party must
24 promptly notify all other Parties that it is withdrawing the inapplicable designation.
25         5.2     Manner and Timing of Designations. Except as otherwise provided in
26 this Order (see, e.g., second paragraph of Section 5.2(a) below), or as otherwise
27 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
28
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                                                     [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 under this Order must be clearly so designated before the material is disclosed or
 2 produced.
 3         Designation in conformity with this Order requires:
 4             (a)   for information in documentary form (e.g., paper or electronic
 5 documents, but excluding transcripts of depositions or other pretrial or trial
 6 proceedings), that the Producing Party affix, at a minimum, the legend
 7 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
 8 ONLY” (hereinafter “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL
 9 legend,” to each page of each document that contains protected material, or, in the
10 case of an electronic document that is produced in native form or is impracticable to
11 produce in a form with the affixed legend, by placing the legend on a placeholder
12 document bearing the document’s production number or by placing the designation
13 in the file name of the native file. If only a portion or portions of the material on a
14 page qualifies for protection, to the extent practical the Producing Party also must
15 clearly identify the protected portion(s) (e.g., by making appropriate markings in the
16 margins).
17         A Party or Non-Party that makes original documents available for inspection
18 need not designate them for protection until after the inspecting Party has indicated
19 which documents it would like copied and produced. During the inspection and
20 before the designation, all of the material made available for inspection shall be
21 deemed       either   “CONFIDENTIAL”         or    “HIGHLY      CONFIDENTIAL          –
22 ATTORNEYS’ EYES ONLY.” After the inspecting Party has identified the
23 documents it wants copied and produced, the Producing Party must determine which
24 documents, or portions thereof, qualify for protection under this Order. Then, before
25 producing the specified documents, the Producing Party must affix the
26 “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
27 ONLY legend” to each page that contains Protected Material. If only a portion or
28 portions of the material on a page qualifies for protection, to the extent practical the
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                                                     [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 Producing Party also must clearly identify the protected portion(s) (e.g., by making
 2 appropriate markings in the margins).
 3               (b) for testimony given in depositions that the Designating Party identify
 4 the Disclosure or Discovery Material on the record, before the close of the deposition,
 5 or in writing within 14 days following receipt of the final transcript. During the 14
 6 day period for designation, the Parties shall treat any transcript that was not designated
 7 on the record as if it had been designated “HIGHLY CONFIDENTIAL –
 8 ATTORNEYS’ EYES ONLY” in its entirety. After the expiration of that period or
 9 such earlier time that such transcript is designated, the transcript will be treated only
10 as actually designated.
11               (c) for information produced in some form other than documentary and for
12 any other tangible items, that the Producing Party affix in a prominent place on the
13 exterior of the container or containers in which the information is stored the legend
14 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
15 ONLY.” If only a portion or portions of the information warrants protection, to the
16 extent practical the Producing Party, to the extent practicable, shall identify the
17 protected portion(s).
18         5.3      Inadvertent Failures to Designate. If timely corrected, an inadvertent
19 failure to designate qualified information or items does not, standing alone, waive the
20 Designating Party's right to secure protection under this Order for such material. To
21 correct such an inadvertent failure, the Producing Party shall give written notice of
22 the correction (a “Re-Designation Notice”) and shall reproduce copies of the affected
23 material labeled with the appropriate confidentiality designation. Upon receipt of a
24 Re-Designation Notice and properly labeled material, the Receiving Party shall
25 promptly either (a) destroy the originally produced, unlabeled copies and all
26 duplicates thereof and notify the Producing Party in writing of such destruction within
27 thirty (30) calendar days of receipt of the Re-Designation Notice, or (b) return the
28 originally produced, unlabeled copies and all duplicates thereof to counsel for the
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                                                      [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 Producing Party within thirty (30) calendar days of receipt of the Re-Designation
 2 Notice. From the date of receipt of a Re-Designation Notice, the Receiving Party
 3 must treat the affected material in accordance with the provisions of this Order.
 4 6.      CHALLENGING CONFIDENTIALITY DESIGNATIONS
 5         6.1    Timing of Challenges.       Any Party or Non-Party may challenge a
 6 designation of confidentiality at any time that is consistent with the Court’s
 7 Scheduling Order. Unless a prompt challenge to a Designating Party’s confidentiality
 8 designation is necessary to avoid foreseeable, substantial unfairness, unnecessary
 9 economic burdens, or a significant disruption or delay of the litigation, a Party does
10 not waive its right to challenge a confidentiality designation by electing not to mount
11 a challenge promptly after the original designation is disclosed.
12         6.2    Meet and Confer. The Challenging Party shall initiate the dispute
13 resolution process under Local Rule 37-1, et seq. Any discovery motion must strictly
14 comply with the procedures set forth in Local Rules 37-1, 37-2, and 37-3.
15         6.3    Burden. The burden of persuasion in any such challenge proceeding
16 shall be on the Designating Party. Frivolous challenges, and those made for an
17 improper purpose (e.g., to harass or impose unnecessary expenses and burdens on
18 other parties) may expose the Challenging Party to sanctions. Unless the Designating
19 Party has waived or withdrawn the confidentiality designation, all parties shall
20 continue to afford the material in question the level of protection to which it is entitled
21 under the Producing Party’s designation until the Court rules on the challenge.
22 7.      ACCESS TO AND USE OF PROTECTED MATERIAL
23         7.1    Basic Principles. A Receiving Party may use Protected Material that is
24 disclosed or produced by another Party or by a Non-Party in connection with this
25 Action only for prosecuting, defending, or attempting to settle this Action. Such
26 Protected Material may be disclosed only to the categories of persons and under the
27 conditions described in this Order. When the Action has been terminated, a Receiving
28 Party must comply with the provisions of Section 14 below (FINAL DISPOSITION).
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                                                      [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1        Protected Material must be stored and maintained by a Receiving Party at a
 2 location and in a secure manner that ensures that access is limited to the persons
 3 authorized under this Order.
 4        7.2      Disclosure of “CONFIDENTIAL” Information or Items.                 Unless
 5 otherwise ordered by the Court or permitted in writing by the Designating Party, a
 6 Receiving       Party    may     disclose    any     information   or   item   designated
 7 “CONFIDENTIAL” only to:
 8              (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
 9 as employees of said Outside Counsel of Record, and Professional Vendors engaged
10 via said Outside Counsel of Record or via the Receiving Party, to whom it is
11 reasonably necessary to disclose the information for this Action;
12              (b) the officers, directors, and employees (including House Counsel) of the
13 Receiving Party to whom disclosure is reasonably necessary for this Action;
14              (c) Experts (as defined in this Order) of the Receiving Party to whom
15 disclosure is reasonably necessary for this Action and who have signed the
16 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17              (d) the Court and its personnel;
18              (e) court reporters and their staff;
19              (f) professional jury or trial consultants, mock jurors, and Professional
20 Vendors to whom disclosure is reasonably necessary for this Action and who have
21 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
22              (g) the author or recipient of a document containing the information or a
23 custodian or other person who otherwise possessed or knew the information;
24              (h) during their depositions, witnesses, and, as to Non-Parties, attorneys for
25 witnesses, in the Action to whom disclosure is reasonably necessary provided: (1) the
26 deposing party requests that the witness sign the form attached as Exhibit A hereto;
27 and (2) they will not be permitted to keep any confidential information unless they
28 sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
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                                                        [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1 otherwise agreed by the Designating Party or ordered by the Court. Pages of
 2 transcribed deposition testimony or exhibits to depositions that reveal Protected
 3 Material may be separately bound by the court reporter and may not be disclosed to
 4 anyone except as permitted under this Stipulated Protective Order; and
 5              (i) any mediator or settlement officer, and their supporting personnel,
 6 mutually agreed upon by all parties to the settlement discussions.
 7        7.3      Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
 8 ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in
 9 writing by the Designating Party, a Receiving Party may disclose any information or
10 item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only
11 to:
12              (a) the Receiving Party’s Outside Counsel of Record in this Action, as well
13 as employees of said Outside Counsel of Record, and Professional Vendors engaged
14 via said Outside Counsel of Record or via the Receiving Party, to whom it is
15 reasonably necessary to disclose the information for this Action;
16              (b) Experts (as defined in this Order) of the Receiving Party (i) to whom
17 disclosure is reasonably necessary for this Action, (ii) who have signed the
18 “Acknowledgment and Agreement to Be Bound” (Exhibit A), and (iii) as to whom
19 the procedures set forth in Section 7.4, below, have been followed;
20              (c) the Court and its personnel;
21              (d) court reporters and their staff;
22              (e) professional jury or trial consultants, mock jurors, to whom disclosure is
23 reasonably necessary for this Action and who have signed the “Acknowledgment and
24 Agreement to Be Bound” (Exhibit A);
25              (f) the author or recipient of a document containing the information or a
26 custodian or other person who otherwise possessed or knew the information; and
27              (g) any mediator or settlement officer, and their supporting personnel,
28 mutually agreed upon by all parties to the settlement discussions.
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                                                        [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1         7.4      Procedures for Approving or Objecting to Disclosure of “HIGHLY
 2 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or Items to Experts.
 3               (a) Unless otherwise ordered by the court or agreed to in writing by the
 4 Designating Party, a Party that seeks to disclose to an Expert (as defined in this Order)
 5 any information or item that has been designated “HIGHLY CONFIDENTIAL –
 6 ATTORNEYS’ EYES ONLY” pursuant to paragraph 7.3(b) first must make a written
 7 request to the Designating Party that (1) identifies the general categories of “HIGHLY
 8 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information that the Receiving
 9 Party seeks permission to disclose to the Expert, (2) sets forth the full name of the
10 Expert and the city and state of his or her primary residence, (3) attaches a copy of
11 the Expert’s current resume, (4) identifies the Expert’s current employer(s), (5)
12 identifies each person or entity from whom the Expert has received compensation or
13 funding for work in his or her areas of expertise or to whom the expert has provided
14 professional services, including in connection with a litigation, at any time during the
15 preceding four years, and (6) identifies (by name and number of the case, filing date,
16 and location of court) any litigation in connection with which the Expert has offered
17 expert testimony, including through a declaration, report, or testimony at a deposition
18 or trial, during the preceding five years.1
19               (b) A Party that makes a request and provides the information specified in
20 the preceding respective paragraphs may disclose the subject Protected Material to
21 the identified Expert unless, within ten (10) calendar days of delivering the request,
22 the Party receives a written objection from the Designating Party. Any such objection
23 must set forth in detail the grounds on which it is based.
24
25   1
       If the Expert believes any of this information is subject to a confidentiality
26 obligation to a third-party, then the Expert should provide whatever information the
   Expert believes can be disclosed without violating any confidentiality agreements,
27 and the Party seeking to disclose to the Expert shall be available to meet and confer
28 with the Designating Party regarding any such engagement.
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                                                        [PROPOSED] STIPULATED PROTECTIVE ORDER


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 1            (c) A Party that receives a timely written objection must meet and confer
 2 with the Designating Party (through direct voice to voice dialogue) to try to resolve
 3 the matter by agreement within seven (7) calendar days of the written objection. If no
 4 agreement is reached, the Party seeking to make the disclosure to the Expert may seek
 5 the Court’s relief.
 6            (d) In any such proceeding, the Party opposing disclosure to the Expert shall
 7 bear the burden of proving that the risk of harm that the disclosure would entail (under
 8 the safeguards proposed) outweighs the Receiving Party’s need to disclose the
 9 Protected Material to its Expert.
10 8.      PROTECTED           MATERIAL          SUBPOENAED            OR      ORDERED
11         PRODUCED IN OTHER LITIGATION
12         If a Party is served with a subpoena or a court order issued in other litigation
13 that compels disclosure of any information or items designated in this Action as
14 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
15 ONLY,” that Party must:
16            (a) promptly notify in writing the Designating Party. Such notification shall
17 include a copy of the subpoena or court order;
18            (b) promptly notify in writing the party who caused the subpoena or order
19 to issue in the other litigation that some or all of the material covered by the subpoena
20 or order is subject to this Order. Such notification shall include a copy of this Order;
21 and
22            (c) cooperate with respect to all reasonable procedures sought to be pursued
23 by the Designating Party whose Protected Material may be affected.
24         If the Designating Party timely seeks a protective order, the Party served with
25 the subpoena or court order shall not produce any information designated in this action
26 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
27 ONLY,” before a determination by the court from which the subpoena or order issued,
28 unless the Party has obtained the Designating Party’s permission. The Designating
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 1 Party shall bear the burden and expense of seeking protection in that court of its
 2 confidential material and nothing in these provisions should be construed as
 3 authorizing or encouraging a Receiving Party in this Action to disobey a lawful
 4 directive from another court.
 5 9.     A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
 6        PRODUCED IN THIS LITIGATION
 7            (a) The terms of this Order are applicable to information produced by a
 8 Non-Party in this Action and designated as “CONFIDENTIAL” or “HIGHLY
 9 CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” Such information produced by
10 Non-Parties in connection with this litigation is protected by the remedies and relief
11 provided by this Order.       Nothing in these provisions should be construed as
12 prohibiting a Non-Party from seeking additional protections.
13            (b) In the event that a Party is required, by a valid discovery request, to
14 produce a Non-Party’s confidential information in its possession, and the Party is
15 subject to an agreement with the Non-Party not to produce the Non-Party’s
16 confidential information, then the Party shall:
17               (1) promptly notify in writing the Requesting Party and the Non-Party
18 that some or all of the information requested is subject to a confidentiality agreement
19 with a Non-Party;
20               (2) promptly provide the Non-Party with a copy of this Order, the
21 relevant discovery request(s), and a reasonably specific description of the information
22 requested; and
23               (3) make the information requested available for inspection by the Non-
24 Party, if requested.
25            (c) If the Non-Party fails to seek a protective order from this Court within
26 14 days of receiving the notice and accompanying information, the Receiving Party
27 may produce the Non-Party’s confidential information responsive to the discovery
28 request. If the Non-Party timely seeks a protective order, the Receiving Party shall
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 1 not produce any information in its possession or control that is subject to the
 2 confidentiality agreement with the Non-Party before a determination by the Court.
 3 Absent a court order to the contrary, the Non-Party shall bear the burden and expense
 4 of seeking protection in this Court of its Protected Material.
 5 10.     UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
 6            (a) If a Receiving Party learns that, by inadvertence or otherwise, it has
 7 disclosed Protected Material to any person or in any circumstance not authorized
 8 under this Order, the Receiving Party must immediately (i) notify in writing the
 9 Designating Party of the unauthorized disclosures, (ii) use its best efforts to retrieve
10 all unauthorized copies of the Protected Material, (iii) inform the person or persons to
11 whom unauthorized disclosures were made of all the terms of this Order, and (iv)
12 request such person or persons to execute the “Acknowledgment and Agreement to
13 Be Bound” that is attached hereto as Exhibit A.
14            (b) To the extent that Protected Material is lost or is the subject of an actual
15 or suspected security breach, the Receiving Party shall (i) provide written notice to
16 the Designating Party of such loss or breach; (ii) investigate and make reasonable
17 efforts to remediate the effects of the loss or breach, and provide the Designating Party
18 with assurances reasonably satisfactory to Designating Party that such loss or breach
19 will not reoccur; and (iii) provide sufficient information about the loss or breach that
20 the Designating Party can reasonably ascertain the size and scope of the loss or breach.
21 The Receiving Party agrees to cooperate, to the extent reasonably practicable, with
22 the Designating Party in investigating any such security incident. In any event, the
23 Receiving Party shall promptly take all necessary and appropriate corrective action to
24 resolve the security breach.
25 11.     INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
26         PROTECTED MATERIAL
27         When a Producing Party gives notice to Receiving Parties that certain
28 inadvertently produced material is subject to a claim of privilege or other protection,
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 1 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
 2 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
 3 may be established in an e-discovery order that provides for production without prior
 4 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
 5 parties reach an agreement on the effect of disclosure of a communication or
 6 information covered by the attorney-client privilege or work product protection, the
 7 parties may incorporate their agreement in the stipulated protective order submitted
 8 to the Court.
 9 12.     MISCELLANEOUS
10         13.1 Right to Further Relief. Nothing in this Order abridges the right of any
11 person to seek its modification by the Court in the future.
12         13.2 Right to Assert Other Objections. By stipulating to the entry of this
13 Protective Order, no Party waives any right it otherwise would have to object to
14 disclosing or producing any information or item on any ground not addressed in this
15 Stipulated Protective Order. Similarly, no Party waives any right to object on any
16 ground to use in evidence of any of the material covered by this Protective Order.
17         13.3 Filing Protected Material. A Party that seeks to file under seal any
18 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
19 only be filed under seal pursuant to a court order authorizing the sealing of the specific
20 Protected Material at issue; good cause must be shown in the request to file under
21 seal. If a Party’s request to file Protected Material under seal is denied by the Court,
22 then the Receiving Party may file the information in the public record unless
23 otherwise instructed by the Court.
24 13.     FINAL DISPOSITION
25         After the final disposition of this Action, as defined within Section 4, within 60
26 days of a written request by the Designating Party, each Receiving Party must, at the
27 Receiving Party’s election, return all Protected Material to the Producing Party or
28 destroy such material. As used in this subdivision, “all Protected Material” includes
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 1 all copies, abstracts, compilations, summaries, and any other format reproducing or
 2 capturing any of the Protected Material. Whether the Protected Material is returned
 3 or destroyed, the Receiving Party must submit a written certification to the Producing
 4 Party (and, if not the same person or entity, to the Designating Party) by the 60 day
 5 deadline that (1) identifies (by category, where appropriate) all the Protected Material
 6 that was returned or destroyed, and (2) affirms that the Receiving Party has not
 7 retained any copies, abstracts, compilations, summaries or any other format
 8 reproducing or capturing any of the Protected Material.          Notwithstanding this
 9 provision, counsel are entitled to retain an archival copy of all pleadings, motion
10 papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence,
11 deposition and trial exhibits, expert reports, attorney work product, and consultant
12 and expert work product, even if such materials contain Protected Material. Counsel
13 are not required to search their email and disaster recovery systems to comply with
14 this paragraph. Any retained archival or remaining copies that contain or constitute
15 Protected Material remain subject to this Protective Order as set forth in Section 4
16 (DURATION).
17 14.    VIOLATION OF ORDER
18        Any violation of this Order may be punished by any and all appropriate
19 measures including, without limitation, contempt proceedings and/or monetary
20 sanctions.
21
22
23
24
25
26
27
28
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 1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
 2
 3 Dated: August 7, 2026               Respectfully submitted,
 4                                     JENNER & BLOCK LLP
 5                                       David R. Singer
                                         Julie A. Shepard
 6                                       Lauren M. Greene
 7
 8                                     By:
 9                                           David R. Singer
                                       Attorney for Plaintiffs and Counterclaim-
10                                     Defendants
11
12 Dated: August 7, 2026               Respectfully submitted,
13                                     QUINN EMANUEL URQUHART
14                                          & SULLIVAN, LLP
                                        Robert M. Schwartz
15                                      Daniel C. Posner
16                                      Haiyan Tang
                                        Aaron Perahia
17                                      Bradley Kahn
18
19                                     By:
20                                           Robert M. Schwartz
                                       Attorneys for Defendants and
21                                     Counterclaimant
22
23 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
24 DATED: __________________
25
26                                     By
27                                           HON. CHARLES F. EICK
                                            United States Magistrate Judge
28
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 1                                      EXHIBIT A
 2            ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
 3        I, ______________________ [full name], of __________________________
 4 [full address], declare under penalty of perjury that I have read in its entirety and
 5 understand the Stipulated Protective Order that was issued by the United States
 6 District Court for the Central District of California on ____________ [date] in the
 7 case of Disney Enterprises, Inc. et Al. v. MiniMax, et al., C.D. Cal. Case No. 2:25-cv-
 8 08768-SB-E. I agree to comply with and to be bound by all the terms of this Stipulated
 9 Protective Order and I understand and acknowledge that failure to so comply could
10 expose me to sanctions and punishment in the nature of contempt. I solemnly promise
11 that I will not disclose in any manner any information or item that is subject to this
12 Stipulated Protective Order to any person or entity except in strict compliance with
13 the provisions of this Order.
14        I further agree to submit to the jurisdiction of the United States District Court
15 for the Central District of California for the purpose of enforcing the terms of this
16 Stipulated Protective Order, even if such enforcement proceedings occur after
17 termination of this action. I hereby appoint _______________________ [full name]
18 of __________________________________ [full address and telephone number]
19 as my California agent for service of process in connection with this action or any
20 proceedings related to enforcement of this Stipulated Protective Order.
21
22 Date: ______________________________________
23
24 City and State where signed: _________________________________
25
26 Printed name: _______________________________
27
28 Signature:    __________________________________
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                                                    [PROPOSED] STIPULATED PROTECTIVE ORDER