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(This is a text-only entry generated by the court. There is no document associated with this entry.) (klh, COURT STAFF) (Filed on 11/27/2023) Modified on 11/27/2023 (klh, COURT STAFF). (Entered: 11/27/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/371574576/","id":371574576,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/379061961/","id":379061961,"tags":[],"absolute_url":"/docket/66862637/42/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-11-27T09:13:01.636694-08:00","date_modified":"2025-09-18T09:06:07.397010-07:00","sha1":"365d2d35aabcc473f85fc8c6a4f59d1ebdae20a4","page_count":2,"file_size":135593,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.42.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.42.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 42 Filed 11/27/23 Page 1 of 2\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 8\n\n 9 Case No.: 3:23-cv-00844-JCS\n NANOLABS, INC.,\n 10\n\n 11 Plaintiff, VOLUNTARY DISMISSAL\n 12 v. [FRCP 41]\nNorthern District of California\n United States District Court\n\n\n\n\n 13 COINBASE GLOBAL, INC.,\n 14\n Defendant.\n 15\n\n 16\n Through undersigned counsel, pursuant to Rule 41(a)(1)(A)(ii), the above-captioned action\n 17 be and hereby is settled and dismissed with prejudice, and without costs.\n 18\n\n 19 Dated: November 23, 2023 Respectfully submitted,\n\n 20\n\n 21\n Mike L. Rodenbaugh (SBN 179059)\n 22\n RODENBAUGH LAW\n 23\n Attorneys for Plaintiff,\n 24 NANOLABS, INC.\n 25\n\n 26\n\n 27\n\n 28\n Voluntary Dismissal with Prejudice 1\n\f Case 3:23-cv-00844-JCS Document 42 Filed 11/27/23 Page 2 of 2\n\n\n\n\n Dated: November 23, 2023 Respectfully submitted,\n 1\n\n 2 /s/ Gina Durham\n ____________________________\n 3 Gina Durham (SBN 295910)\n 4 DLA PIPER LLP (US)\n 555 Mission Street\n 5 San Francisco, CA 94105\n Tel: (415) 836-2506\n 6 Fax: (415) 659-7333\n Gina.durham@dlapiper.com\n 7\n\n 8 Attorneys for Defendant\n COINBASE GLOBAL, INC.\n 9\n\n 10\n\n 11 PURSUANT TO STIPULATION, IT IS SO ORDERED,\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n ___________________________ November 27, 2023\n _________________\n 13\n Magistrate Judge Joseph C. Spero Date\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28\n Voluntary Dismissal with Prejudice 2\n\f","ocr_status":2,"date_upload":"2024-02-29T09:51:24.822244-08:00","document_number":"42","attachment_number":null,"pacer_doc_id":"035023784981","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Stipulation","acms_document_guid":""}],"date_created":"2023-11-27T09:13:01.623451-08:00","date_modified":"2025-09-18T09:06:07.368994-07:00","date_filed":"2023-11-27","time_filed":"08:41:06","entry_number":42,"recap_sequence_number":"2023-11-27.001","pacer_sequence_number":121,"description":"Order. Signed 11/27/2023 by Magistrate Judge Joseph C. Spero granting 41 Stipulation for Dismissal.(klh, COURT STAFF) (Filed on 11/27/2023) (Entered: 11/27/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/371574573/","id":371574573,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/379061958/","id":379061958,"tags":[],"absolute_url":"","date_created":"2023-11-27T09:13:01.396881-08:00","date_modified":"2023-11-27T09:13:01.400051-08:00","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":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Clerk's Notice","acms_document_guid":""}],"date_created":"2023-11-27T09:13:01.389148-08:00","date_modified":"2023-11-27T09:13:01.389159-08:00","date_filed":"2023-11-27","time_filed":"08:42:40","entry_number":null,"recap_sequence_number":"2023-11-27.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/371463191/","id":371463191,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/378941130/","id":378941130,"tags":[],"absolute_url":"/docket/66862637/41/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-11-22T17:10:25.762538-08:00","date_modified":"2025-09-18T09:06:07.346112-07:00","sha1":"10cb3914ccc37a1578d3a285a3f918429768c86b","page_count":2,"file_size":50100,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.41.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.41.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 41 Filed 11/22/23 Page 1 of 2\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 8\n\n 9 Case No.: 3:23-cv-00844-JCS\n NANOLABS, INC.,\n 10\n\n 11 Plaintiff, VOLUNTARY DISMISSAL\n 12 v. [FRCP 41]\nNorthern District of California\n United States District Court\n\n\n\n\n 13 COINBASE GLOBAL, INC.,\n 14\n Defendant.\n 15\n\n 16\n Through undersigned counsel, pursuant to Rule 41(a)(1)(A)(ii), the above-captioned action\n 17 be and hereby is settled and dismissed with prejudice, and without costs.\n 18\n\n 19 Dated: November 23, 2023 Respectfully submitted,\n\n 20\n\n 21\n Mike L. Rodenbaugh (SBN 179059)\n 22\n RODENBAUGH LAW\n 23\n Attorneys for Plaintiff,\n 24 NANOLABS, INC.\n 25\n\n 26\n\n 27\n\n 28\n Voluntary Dismissal with Prejudice 1\n\f Case 3:23-cv-00844-JCS Document 41 Filed 11/22/23 Page 2 of 2\n\n\n\n\n Dated: November 23, 2023 Respectfully submitted,\n 1\n\n 2 /s/ Gina Durham\n ____________________________\n 3 Gina Durham (SBN 295910)\n 4 DLA PIPER LLP (US)\n 555 Mission Street\n 5 San Francisco, CA 94105\n Tel: (415) 836-2506\n 6 Fax: (415) 659-7333\n Gina.durham@dlapiper.com\n 7\n\n 8 Attorneys for Defendant\n COINBASE GLOBAL, INC.\n 9\n\n 10\n\n 11 PURSUANT TO STIPULATION, IT IS SO ORDERED,\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n ___________________________ _________________\n 13\n Magistrate Judge Joseph C. Spero Date\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28\n Voluntary Dismissal with Prejudice 2\n\f","ocr_status":2,"date_upload":"2023-11-24T06:02:09.924543-08:00","document_number":"41","attachment_number":null,"pacer_doc_id":"035023781544","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation","acms_document_guid":""}],"date_created":"2023-11-22T17:10:25.748882-08:00","date_modified":"2025-09-18T09:06:07.317182-07:00","date_filed":"2023-11-22","time_filed":"16:28:46","entry_number":41,"recap_sequence_number":"2023-11-22.001","pacer_sequence_number":119,"description":"STIPULATION WITH PROPOSED ORDER Voluntary Dismissal filed by Nanolabs, Inc.. (Rodenbaugh, Michael) (Filed on 11/22/2023) (Entered: 11/22/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/369456048/","id":369456048,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/376819108/","id":376819108,"tags":[],"absolute_url":"/docket/66862637/40/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-10-31T12:19:20.946799-07:00","date_modified":"2025-09-18T09:06:07.293173-07:00","sha1":"131e7903871eafee46e86e0d17ab5338b4ced0c9","page_count":4,"file_size":136015,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.40.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.40.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 40 Filed 10/31/23 Page 1 of 4\n\n\n\n 1 GINA DURHAM (SBN 295910)\n gina.durham@us.dlapiper.com\n 2 AISLINN SMALLING (SBN 335911)\n aislinn.smalling@us.dlapiper.com\n 3 DLA PIPER LLP (US)\n 555 Mission Street\n 4 Suite 2400\n San Francisco, California 94105-2933\n 5 Telephone: 415.836.2500\n Facsimile: 415.836.2501\n 6\n KRISTINA MARIE FERNANDEZ MABRIE (SBN 318315)\n 7 kristina.fernandezmabrie@us.dlapiper.com\n DLA PIPER LLP (US)\n 8 2000 Avenue of the Stars\n Suite 400 North Tower\n 9 Los Angeles, California 90067-4735\n Tel: 310.595.3136\n10 Fax: 310.595.3366\n11 Attorneys for Defendant\n Coinbase Global, Inc.\n12\n13 UNITED STATES DISTRICT COURT\n14 NORTHERN DISTRICT OF CALIFORNIA\n15 NANOLABS, INC., a Delaware Case No. 3:23-cv-844\n corporation,\n16 JOINT STIPULATION TO\n Plaintiff, CONTINUE CASE\n17 MANAGEMENT CONFERENCE\n v.\n18\n COINBASE GLOBAL, INC., a Delaware Date: November 3, 2023\n19 corporation, Time: 2:00 pm\n Judge: Hon. Joseph C. Spero\n20 Defendant.\n Action Filed: February 24, 2023\n21 COINBASE GLOBAL, INC., a Delaware\n corporation,\n22\n Counterclaimant,\n23\n v.\n24\n NANOLABS, INC., a Delaware\n25 corporation,\n26 Counterdefendant.\n27\n28\n ACTIVE\\1605005535.1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 40 Filed 10/31/23 Page 2 of 4\n\n\n\n 1 Pursuant to Local Rule 6-2, due to the parties working on a resolution, the\n 2 parties stipulate to continue the Case Management Conference, currently set for\n 3 November 3, 2023, four weeks to December 1, 2023.\n 4 1. On October 18, 2023, the Parties attended mediation in front of the\n 5 Honorable Judge Laporte.\n 6 2. As a result of this mediation, the Parties require additional time as\n 7 they work towards resolution.\n 8 3. The Parties therefore stipulate to a continuance to December 1, 2023\n 9 to accommodate the Parties\u2019 desire to resolve the matter.\n10 4. This request supports judicial efficiency by allowing the parties\n11 additional time to resolve the case.\n12 5. The Parties have requested a continuance previously to account for\n13 Plaintiff counsel\u2019s travel.\n14 6. The dates would be amended as follows; no other dates would change.\n15 Date Event\n16 November 11, 2023 Last Day to Amend Pleadings\n17 November 24, 2023 Deadline to file Amended Joint Case Management\n18 Statement\n19 December 1, 2023 Case Management Conference\n20 December 22, 2023 Discovery Cut-off\n21 January 19, 2024 Expert Disclosure\n22 February 16, 2024 Expert Rebuttal\n23 March 29, 2024 Expert Discovery Cut-off\n24 April 26, 2024 Deadline to File Dispositive Motions\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 40 Filed 10/31/23 Page 3 of 4\n\n\n\n 1 Dated: October 30, 2023\n 2 DLA PIPER LLP (US)\n 3\n By: /s/ Gina Durham\n 4 GINA DURHAM\n AISLINN N. SMALLING\n 5 KRISTINA M. FERNANDEZ MABRIE\n 6\n Attorneys for Defendant/Counterclaimant\n 7 Coinbase Global, Inc.\n Dated: October 30, 2023\n 8\n RODENBAUGH LAW\n 9\n10 By: /s/ Mike L. Rodenbaugh\n MIKE L. RODENBAUGH\n11\n12 Attorneys for Plaintiff/Counterdefendant\n NanoLabs, Inc.\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 2\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 40 Filed 10/31/23 Page 4 of 4\n\n\n\n 1 ATTORNEY ATTESTATION\n 2 Pursuant to N.D. Cal. Civil L.R. 5-1(h)(3), I attest that the concurrence in\n 3 the filing of this document has been obtained from each of the other signatories\n 4 shown above and that all signatories have authorized placement of their electronic\n 5 signature on this document.\n 6\n 7 Dated: October 30, 2023\n 8 /s/ Gina Durham\n Gina Durham\n 9\n10\n S DISTRICT\n11 ATE C\n T\n\n\n O\n S\n\n\n\n\n U\n ED\n\n\n\n\n12 Dated: October 31, 2023\n\n RT\n ERED\n UNIT\n\n\n\n\n O ORD\n IT IS S\n13\n Spero R NIA\n14 seph C.\n NO\n\n\n\n\n Judge Jo\n FO\n RT\n\n\n\n\n15\n LI\n\n\n\n ER\n H\n\n\n\n\n A\n\n\n\n\n N C\n F\n D IS T IC T O\n16 R\n\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f","ocr_status":2,"date_upload":"2024-02-29T09:51:22.264691-08:00","document_number":"40","attachment_number":null,"pacer_doc_id":"035023699666","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2023-10-31T12:19:20.934880-07:00","date_modified":"2025-09-18T09:06:07.264041-07:00","date_filed":"2023-10-31","time_filed":"11:25:34","entry_number":40,"recap_sequence_number":"2023-10-31.001","pacer_sequence_number":114,"description":"ORDER. Signed 10/31/2023 by Magistrate Judge Joseph C. Spero GRANTING re 39 Stipulation to Continue Case Management Conference filed by Coinbase Global, Inc. Further Case Management Conference set for 11/3/2023 is continued to 12/1/2023 02:00 PM in San Francisco, - Videoconference Only. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/jcs General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. Case Management Statement due by 11/24/2023. (klh, COURT STAFF) (Filed on 10/31/2023) (Entered: 10/31/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/369344953/","id":369344953,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/376704657/","id":376704657,"tags":[],"absolute_url":"/docket/66862637/39/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-10-30T12:49:03.346454-07:00","date_modified":"2025-09-18T09:06:07.235840-07:00","sha1":"82a2d5786c87b183c7ab871d4861990b4266f7fd","page_count":4,"file_size":96393,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.39.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.39.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 39 Filed 10/30/23 Page 1 of 4\n\n\n\n 1 GINA DURHAM (SBN 295910)\n gina.durham@us.dlapiper.com\n 2 AISLINN SMALLING (SBN 335911)\n aislinn.smalling@us.dlapiper.com\n 3 DLA PIPER LLP (US)\n 555 Mission Street\n 4 Suite 2400\n San Francisco, California 94105-2933\n 5 Telephone: 415.836.2500\n Facsimile: 415.836.2501\n 6\n KRISTINA MARIE FERNANDEZ MABRIE (SBN 318315)\n 7 kristina.fernandezmabrie@us.dlapiper.com\n DLA PIPER LLP (US)\n 8 2000 Avenue of the Stars\n Suite 400 North Tower\n 9 Los Angeles, California 90067-4735\n Tel: 310.595.3136\n10 Fax: 310.595.3366\n11 Attorneys for Defendant\n Coinbase Global, Inc.\n12\n13 UNITED STATES DISTRICT COURT\n14 NORTHERN DISTRICT OF CALIFORNIA\n15 NANOLABS, INC., a Delaware Case No. 3:23-cv-844\n corporation,\n16 JOINT STIPULATION TO\n Plaintiff, CONTINUE CASE\n17 MANAGEMENT CONFERENCE\n v.\n18\n COINBASE GLOBAL, INC., a Delaware Date: November 3, 2023\n19 corporation, Time: 2:00 pm\n Judge: Hon. Joseph C. Spero\n20 Defendant.\n Action Filed: February 24, 2023\n21 COINBASE GLOBAL, INC., a Delaware\n corporation,\n22\n Counterclaimant,\n23\n v.\n24\n NANOLABS, INC., a Delaware\n25 corporation,\n26 Counterdefendant.\n27\n28\n ACTIVE\\1605005535.1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 39 Filed 10/30/23 Page 2 of 4\n\n\n\n 1 Pursuant to Local Rule 6-2, due to the parties working on a resolution, the\n 2 parties stipulate to continue the Case Management Conference, currently set for\n 3 November 3, 2023, four weeks to December 1, 2023.\n 4 1. On October 18, 2023, the Parties attended mediation in front of the\n 5 Honorable Judge Laporte.\n 6 2. As a result of this mediation, the Parties require additional time as\n 7 they work towards resolution.\n 8 3. The Parties therefore stipulate to a continuance to December 1, 2023\n 9 to accommodate the Parties\u2019 desire to resolve the matter.\n10 4. This request supports judicial efficiency by allowing the parties\n11 additional time to resolve the case.\n12 5. The Parties have requested a continuance previously to account for\n13 Plaintiff counsel\u2019s travel.\n14 6. The dates would be amended as follows; no other dates would change.\n15 Date Event\n16 November 11, 2023 Last Day to Amend Pleadings\n17 November 24, 2023 Deadline to file Amended Joint Case Management\n18 Statement\n19 December 1, 2023 Case Management Conference\n20 December 22, 2023 Discovery Cut-off\n21 January 19, 2024 Expert Disclosure\n22 February 16, 2024 Expert Rebuttal\n23 March 29, 2024 Expert Discovery Cut-off\n24 April 26, 2024 Deadline to File Dispositive Motions\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 39 Filed 10/30/23 Page 3 of 4\n\n\n\n 1 Dated: October 30, 2023\n 2 DLA PIPER LLP (US)\n 3\n By: /s/ Gina Durham\n 4 GINA DURHAM\n AISLINN N. SMALLING\n 5 KRISTINA M. FERNANDEZ MABRIE\n 6\n Attorneys for Defendant/Counterclaimant\n 7 Coinbase Global, Inc.\n Dated: October 30, 2023\n 8\n RODENBAUGH LAW\n 9\n10 By: /s/ Mike L. Rodenbaugh\n MIKE L. RODENBAUGH\n11\n12 Attorneys for Plaintiff/Counterdefendant\n NanoLabs, Inc.\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 2\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f Case 3:23-cv-00844-JCS Document 39 Filed 10/30/23 Page 4 of 4\n\n\n\n 1 ATTORNEY ATTESTATION\n 2 Pursuant to N.D. Cal. Civil L.R. 5-1(h)(3), I attest that the concurrence in\n 3 the filing of this document has been obtained from each of the other signatories\n 4 shown above and that all signatories have authorized placement of their electronic\n 5 signature on this document.\n 6\n 7 Dated: October 30, 2023\n 8 /s/ Gina Durham\n Gina Durham\n 9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n\n ACTIVE\\1605005535.1 1\n JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE\n\f","ocr_status":2,"date_upload":"2024-02-29T09:50:58.704203-08:00","document_number":"39","attachment_number":null,"pacer_doc_id":"035023695262","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation","acms_document_guid":""}],"date_created":"2023-10-30T12:49:03.335350-07:00","date_modified":"2025-09-18T09:06:07.204957-07:00","date_filed":"2023-10-30","time_filed":"12:11:17","entry_number":39,"recap_sequence_number":"2023-10-30.001","pacer_sequence_number":112,"description":"STIPULATION JOINT STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE filed by Coinbase Global, Inc.. (Durham, Gina) (Filed on 10/30/2023) (Entered: 10/30/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/365191763/","id":365191763,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/372089873/","id":372089873,"tags":[],"absolute_url":"/docket/66862637/38/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-09-18T15:13:00.239310-07:00","date_modified":"2025-09-18T09:06:07.182197-07:00","sha1":"b850138d627f3cee84cca375895679f888badc8d","page_count":1,"file_size":90850,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.38.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.38.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 38 Filed 09/18/23 Page 1 of 1\n\n\n\n\nAnafrancesca Comunale SBN 323257\nPO Box 22296\nSan Diego, CA 92192\n\n\n\n\n UNITED STATES DISTRICT COURT\n NORTHERN DISTRICT OF CALIFORNIA\n\n\n\n NANOLABS, INC., a Delaware corporation Case No.: 3:23-cv-844\n\n Plaintiff,\n NOTICE OF WITHDRAWAL OF\n v. COUNSEL\n\n COINBASE GLOBAL, INC., a Delaware\n Date of filing: September 18, 2023\n corporation\n\n\n\n Defendant.\n\n\n\n\nPLEASE TAKE NOTICE that Anafrancesca Comunale, formerly an associate attorney of\nRodenbaugh Law Firm, hereby withdraws as attorney for Plaintiff: Nanolabs, Inc.\n\n\nDated: September 18, 2023 Respectfully Submitted,\n /s/ Anafrancesca Comunale\n Anafrancesca Comunale\n Attorney for Plaintiff\n\n\nNotice of Withdrawal Case No.: 3:23-cv-844\n\f","ocr_status":2,"date_upload":"2024-02-29T09:50:41.721071-08:00","document_number":"38","attachment_number":null,"pacer_doc_id":"035023554406","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice of Change In Counsel","acms_document_guid":""}],"date_created":"2023-09-18T15:13:00.230329-07:00","date_modified":"2025-09-18T09:06:07.151528-07:00","date_filed":"2023-09-18","time_filed":"15:08:03","entry_number":38,"recap_sequence_number":"2023-09-18.001","pacer_sequence_number":108,"description":"NOTICE of Change In Counsel by Anafrancesca Comunale (Comunale, Anafrancesca) (Filed on 9/18/2023) (Entered: 09/18/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/362701522/","id":362701522,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/369397496/","id":369397496,"tags":[],"absolute_url":"/docket/66862637/37/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-22T16:47:11.773295-07:00","date_modified":"2025-09-18T09:06:07.129003-07:00","sha1":"fa744f4a0b13b5b970a6c0bf859e962a1148177d","page_count":1,"file_size":2853846,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.37.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.37.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 3:23-cv-00844-JCS Document 37 Filed 08/22/23 Page 1 of 1\n\nAO 458 (Rev. 06/09) Appearance of Counsel\n\nUNITED STATES DISTRICT COURT\n\nfor the\nNorthern District of California [\u00a5]\n\nNanolabs, Inc., a Delaware corporation _ )\nPlaintiff )\nVv. ) Case No. 3:23-cv-00844-JCS\nCoinbase Global, Inc., a Delaware corporation )\nDefendant )\nAPPEARANCE OF COUNSEL\n\nTo: The clerk of court and all parties of record\n1 am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:\n\nNanolabs, Inc., a Delaware corporation\n\nDate: 08/22/2023\n\nAttorney's signature\n\nAnafrancesca Comunale, SBN 323257\n\nPrinted name and bar number\n\nPO Box 22296\nSan Diego, CA 92192\n\nAddress \u2014\n\nacomunale@rodenbaugh.com\nE-mail address\n\n(619) 840-1053\n\nTelephone number\n\nNia\n\nFAX number\n\n","ocr_status":1,"date_upload":"2024-02-29T09:51:17.987014-08:00","document_number":"37","attachment_number":null,"pacer_doc_id":"035023468863","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice of Appearance","acms_document_guid":""}],"date_created":"2023-08-22T16:47:11.764817-07:00","date_modified":"2025-09-18T09:06:07.094338-07:00","date_filed":"2023-08-22","time_filed":"16:24:28","entry_number":37,"recap_sequence_number":"2023-08-22.002","pacer_sequence_number":106,"description":"NOTICE of Appearance by Anafrancesca Comunale (Comunale, Anafrancesca) (Filed on 8/22/2023) (Entered: 08/22/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/362634374/","id":362634374,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/369329588/","id":369329588,"tags":[],"absolute_url":"/docket/66862637/36/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-22T09:26:32.432724-07:00","date_modified":"2025-09-18T09:06:07.066103-07:00","sha1":"9c5a55a45b7b325f6851746df5abcfe7ea9c1f15","page_count":17,"file_size":146581,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.36.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.36.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 1 of 17\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 9\n\n 10\n NANOLABS, INC., Case No.: 3:23-cv-00844-JCS\n 11\n\n 12 Plaintiff,\n STIPULATED PROTECTIVE ORDER FOR\nNorthern District of California\n\n\n\n\n v. LITIGATION INVOLVING HIGHLY\n United States District Court\n\n\n\n\n 13 SENSITIVE CONFIDENTIAL INFORMATION\n COINBASE GLOBAL, INC., AND/OR TRADE SECRETS\n 14\n\n 15 Defendant.\n\n 16 And related counterclaims.\n 17\n\n 18\n\n 19 1. PURPOSES AND LIMITATIONS\n\n 20 Disclosure and discovery activity in this action are likely to involve production of\n\n 21 confidential, proprietary, or private information for which special protection from public\n\n 22 disclosure and from use for any purpose other than prosecuting this litigation may be warranted.\n\n 23 Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated\n\n 24 Protective Order. The parties acknowledge that this Order does not confer blanket protections on\n\n 25 all disclosures or responses to discovery and that the protection it affords from public disclosure\n\n 26 and use extends only to the limited information or items that are entitled to confidential treatment\n\n 27 under the applicable legal principles. The parties further acknowledge, as set forth in Section 14.4,\n\n 28 1\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 2 of 17\n\n\n\n\n 1 below, that this Stipulated Protective Order does not entitle them to file confidential information\n\n 2 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards\n\n 3 that will be applied when a party seeks permission from the court to file material under seal.\n\n 4 2. DEFINITIONS\n 5 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or\n\n 6 items under this Order.\n\n 7 2.2 \u201cCONFIDENTIAL\u201d Information or Items: information (regardless of how it is generated,\n\n 8 stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure\n\n 9 26(c).\n\n 10 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as\n\n 11 their support staff).\n\n 12 2.4 Designated House Counsel: House Counsel who seek access to \u201cHIGHLY\nNorthern District of California\n United States District Court\n\n\n\n\n 13 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d information in this matter.\n\n 14 2.5 Designating Party: a Party or Non-Party that designates information or items that it\n\n 15 produces in disclosures or in responses to discovery as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY\n\n 16 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d.\n\n 17 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium or\n\n 18 manner in which it is generated, stored, or maintained (including, among other things, testimony,\n\n 19 transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in\n\n 20 this matter.\n\n 21 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the\n\n 22 litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consultant\n\n 23 in this action, (2) is not a past or current employee of a Party or of a Party\u2019s competitor, and (3) at the time\n\n 24 of retention, is not anticipated to become an employee of a Party or of a Party\u2019s competitor.\n\n 25 2.8 \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d Information or Items:\n\n 26 extremely sensitive \u201cConfidential Information or Items,\u201d disclosure of which to another Party or Non-Party\n\n 27 would create a substantial risk of serious harm that could not be avoided by less restrictive means.\n\n 28 2\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 3 of 17\n\n\n\n\n 1 2.10 House Counsel: attorneys who are employees of a party to this action. House Counsel does\n\n 2 not include Outside Counsel of Record or any other outside counsel.\n\n 3 2.11 Non-Party: any natural person, partnership, corporation, association, or other legal entity\n\n 4 not named as a Party to this action.\n\n 5 2.12 Outside Counsel of Record: attorneys who are not employees of a party to this action but\n\n 6 are retained to represent or advise a party to this action and have appeared in this action on behalf of that\n\n 7 party or are affiliated with a law firm which has appeared on behalf of that party.\n\n 8 2.13 Party: any party to this action, including all of its officers, directors, employees,\n\n 9 consultants, retained experts, and Outside Counsel of Record (and their support staffs).\n\n 10 2.14 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in\n\n 11 this action.\n\n 12 2.15 Professional Vendors: persons or entities that provide litigation support services (e.g.,\nNorthern District of California\n United States District Court\n\n\n\n\n 13 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or\n\n 14 retrieving data in any form or medium) and their employees and subcontractors.\n\n 15 2.16 Protected Material: any Disclosure or Discovery Material that is designated as\n\n 16 \u201cCONFIDENTIAL,\u201d or as \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d\n\n 17 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing\n\n 18 Party.\n\n 19 3. SCOPE\n 20 The protections conferred by this Stipulation and Order cover not only Protected Material (as\n\n 21 defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies,\n\n 22 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or\n\n 23 presentations by Parties or their Counsel that might reveal Protected Material. However, the protections\n\n 24 conferred by this Stipulation and Order do not cover the following information: (a) any information that is\n\n 25 in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain\n\n 26 after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order,\n\n 27 including becoming part of the public record through trial or otherwise; and (b) any information known to\n\n 28 3\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 4 of 17\n\n\n\n\n 1 the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a\n\n 2 source who obtained the information lawfully and under no obligation of confidentiality to the Designating\n\n 3 Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.\n\n 4 4. DURATION\n 5 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order\n\n 6 shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise\n\n 7 directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this\n\n 8 action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all\n\n 9 appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any\n\n 10 motions or applications for extension of time pursuant to applicable law.\n\n 11 5. DESIGNATING PROTECTED MATERIAL\n 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-\nNorthern District of California\n United States District Court\n\n\n\n\n 13 Party that designates information or items for protection under this Order must take care to limit any such\n\n 14 designation to specific material that qualifies under the appropriate standards. To the extent it is practical to\n\n 15 do so, the Designating Party must designate for protection only those parts of material, documents, items,\n\n 16 or oral or written communications that qualify \u2013 so that other portions of the material, documents, items, or\n\n 17 communications for which protection is not warranted are not swept unjustifiably within the ambit of this\n\n 18 Order.\n\n 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be\n\n 20 clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or\n\n 21 retard the case development process or to impose unnecessary expenses and burdens on other parties)\n\n 22 expose the Designating Party to sanctions.\n\n 23 If it comes to a Designating Party\u2019s attention that information or items that it designated for\n\n 24 protection do not qualify for protection at all or do not qualify for the level of protection initially asserted,\n\n 25 that Designating Party must promptly notify all other parties that it is withdrawing the mistaken\n\n 26 designation.\n\n 27 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g.,\n\n 28 4\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 5 of 17\n\n\n\n\n 1 second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery\n\n 2 Material that qualifies for protection under this Order must be clearly so designated before the\n\n 3 material is disclosed or produced.\n\n 4 Designation in conformity with this Order requires:\n\n 5 (a) for information in documentary form (e.g., paper or electronic documents, but excluding\n\n 6 transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the legend\n\n 7 \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d to each page that\n\n 8 contains protected material. If only a portion or portions of the material on a page qualifies for protection,\n\n 9 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate\n\n 10 markings in the margins) and must specify, for each portion, the level of protection being asserted.\n\n 11 A Party or Non-Party that makes original documents or materials available for inspection need not\n\n 12 designate them for protection until after the inspecting Party has indicated which material it would like\nNorthern District of California\n United States District Court\n\n\n\n\n 13 copied and produced. During the inspection and before the designation, all of the material made available\n\n 14 for inspection shall be deemed \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d After the\n\n 15 inspecting Party has identified the documents it wants copied and produced, the Producing Party must\n\n 16 determine which documents, or portions thereof, qualify for protection under this Order. Then, before\n\n 17 producing the specified documents, the Producing Party must affix the appropriate legend\n\n 18 (\u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d to each page that\n\n 19 contains Protected Material. If only a portion or portions of the material on a page qualifies for protection,\n\n 20 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate\n\n 21 markings in the margins) and must specify, for each portion, the level of protection being asserted.\n\n 22 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the Designating\n\n 23 Party identify on the record, before the close of the deposition, hearing, or other proceeding, all protected\n\n 24 testimony and specify the level of protection being asserted. When it is impractical to identify separately\n\n 25 each portion of testimony that is entitled to protection and it appears that substantial portions of the\n\n 26 testimony may qualify for protection, the Designating Party may invoke on the record (before the\n\n 27 deposition, hearing, or other proceeding is concluded) a right to have up to 21 days to identify the specific\n\n 28 5\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 6 of 17\n\n\n\n\n 1 portions of the testimony as to which protection is sought and to specify the level of protection being\n\n 2 asserted. Only those portions of the testimony that are appropriately designated for protection within the 21\n\n 3 days shall be covered by the provisions of this Stipulated Protective Order. Alternatively, a Designating\n\n 4 Party may specify, at the deposition or up to 21 days afterwards if that period is properly invoked, that the\n\n 5 entire transcript shall be treated as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 6 EYES ONLY.\u201d\n\n 7 Parties shall give the other parties notice if they reasonably expect a deposition, hearing or other\n\n 8 proceeding to include Protected Material so that the other parties can ensure that only authorized\n\n 9 individuals who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A) are present at\n\n 10 those proceedings. The use of a document as an exhibit at a deposition shall not in any way affect its\n\n 11 designation as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d\n\n 12 Transcripts containing Protected Material shall have an obvious legend on the title page that the\nNorthern District of California\n United States District Court\n\n\n\n\n 13 transcript contains Protected Material, and the title page shall be followed by a list of all pages (including\n\n 14 line numbers as appropriate) that have been designated as Protected Material and the level of protection\n\n 15 being asserted by the Designating Party. The Designating Party shall inform the court reporter of these\n\n 16 requirements. Any transcript that is prepared before the expiration of a 21-day period for designation shall\n\n 17 be treated during that period as if it had been designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 18 EYES ONLY\u201d in its entirety unless otherwise agreed. After the expiration of that period, the transcript shall\n\n 19 be treated only as actually designated.\n\n 20 (c) for information produced in some form other than documentary and for any other tangible\n\n 21 items, that the Producing Party affix in a prominent place on the exterior of the container or containers in\n\n 22 which the information or item is stored the legend \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013\n\n 23 ATTORNEYS\u2019 EYES ONLY\u201d. If only a portion or portions of the information or item warrant protection,\n\n 24 the Producing Party, to the extent practicable, shall identify the protected portion(s) and specify the level of\n\n 25 protection being asserted.\n\n 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate\n\n 27 qualified information or items does not, standing alone, waive the Designating Party\u2019s right to secure\n\n 28 6\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 7 of 17\n\n\n\n\n 1 protection under this Order for such material. Upon timely correction of a designation, the Receiving Party\n\n 2 must make reasonable efforts to assure that the material is treated in accordance with the provisions of this\n\n 3 Order.\n\n 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS\n 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of\n\n 6 confidentiality at any time. Unless a prompt challenge to a Designating Party\u2019s confidentiality designation\n\n 7 is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant\n\n 8 disruption or delay of the litigation, a Party does not waive its right to challenge a confidentiality\n\n 9 designation by electing not to mount a challenge promptly after the original designation is disclosed.\n\n 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by\n\n 11 providing written notice of each designation it is challenging and describing the basis for each challenge.\n\n 12 To avoid ambiguity as to whether a challenge has been made, the written notice must recite that the\nNorthern District of California\n United States District Court\n\n\n\n\n 13 challenge to confidentiality is being made in accordance with this specific paragraph of the Protective\n\n 14 Order. The parties shall attempt to resolve each challenge in good faith and must begin the process by\n\n 15 conferring directly (in voice to voice dialogue; other forms of communication are not sufficient) within 14\n\n 16 days of the date of service of notice. In conferring, the Challenging Party must explain the basis for its\n\n 17 belief that the confidentiality designation was not proper and must give the Designating Party an\n\n 18 opportunity to review the designated material, to reconsider the circumstances, and, if no change in\n\n 19 designation is offered, to explain the basis for the chosen designation. A Challenging Party may proceed to\n\n 20 the next stage of the challenge process only if it has engaged in this meet and confer process first or\n\n 21 establishes that the Designating Party is unwilling to participate in the meet and confer process in a timely\n\n 22 manner.\n\n 23 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court intervention,\n\n 24 the Designating Party shall file and serve a motion to retain confidentiality under Civil Local Rule 7 (and in\n\n 25 compliance with Civil Local Rule 79-5, if applicable) within 21 days of the initial notice of challenge or\n\n 26 within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute,\n\n 27 whichever is earlier. Each such motion must be accompanied by a competent declaration affirming that the\n\n 28 7\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 8 of 17\n\n\n\n\n 1 movant has complied with the meet and confer requirements imposed in the preceding paragraph. Failure\n\n 2 by the Designating Party to make such a motion including the required declaration within 21 days (or 14\n\n 3 days, if applicable) shall automatically waive the confidentiality designation for each challenged\n\n 4 designation. In addition, the Challenging Party may file a motion challenging a confidentiality designation\n\n 5 at any time if there is good cause for doing so, including a challenge to the designation of a deposition\n\n 6 transcript or any portions thereof. Any motion brought pursuant to this provision must be accompanied by a\n\n 7 competent declaration affirming that the movant has complied with the meet and confer requirements\n\n 8 imposed by the preceding paragraph.\n\n 9 The burden of persuasion in any such challenge proceeding shall be on the Designating Party.\n\n 10 Frivolous challenges and those made for an improper purpose (e.g., to harass or impose unnecessary\n\n 11 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the\n\n 12 Designating Party has waived the confidentiality designation by failing to file a motion to retain\nNorthern District of California\n United States District Court\n\n\n\n\n 13 confidentiality as described above, all parties shall continue to afford the material in question the level of\n\n 14 protection to which it is entitled under the Producing Party\u2019s designation until the court rules on the\n\n 15 challenge.\n\n 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL\n 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or\n\n 18 produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending,\n\n 19 or attempting to settle this litigation. Such Protected Material may be disclosed only to the categories of\n\n 20 persons and under the conditions described in this Order. When the litigation has been terminated, a\n\n 21 Receiving Party must comply with the provisions of section 15 below (FINAL DISPOSITION).\n\n 22 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure\n\n 23 manner that ensures that access is limited to the persons authorized under this Order.\n\n 24 7.2 Disclosure of \u201cCONFIDENTIAL\u201d Information or Items. Unless otherwise ordered by the\n\n 25 court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or\n\n 26 item designated \u201cCONFIDENTIAL\u201d only to:\n\n 27 (a) the Receiving Party\u2019s Outside Counsel of Record in this action, as well as employees of said\n\n 28 8\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 9 of 17\n\n\n\n\n 1 Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation\n\n 2 and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit\n\n 3 A;\n\n 4 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to\n\n 5 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\n\n 6 Agreement to Be Bound\u201d (Exhibit A);\n\n 7 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably\n\n 8 necessary for this litigation and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d\n\n 9 (Exhibit A);\n\n 10 (d) the court and its personnel;\n\n 11 (e) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to\n\n 12 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\nNorthern District of California\n United States District Court\n\n\n\n\n 13 Agreement to Be Bound\u201d (Exhibit A);\n\n 14 (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and\n\n 15 who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), unless otherwise\n\n 16 agreed by the Designating Party or ordered by the court. Pages of transcribed deposition testimony or\n\n 17 exhibits to depositions that reveal Protected Material must be separately bound by the court reporter and\n\n 18 may not be disclosed to anyone except as permitted under this Stipulated Protective Order.\n\n 19 (g) the author or recipient of a document containing the information or a custodian or other person\n\n 20 who otherwise possessed or knew the information.\n\n 21 7.3 Disclosure of \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d Information or\n\n 22 Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving\n\n 23 Party may disclose any information or item designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 24 EYES ONLY\u201d only to:\n\n 25 (a) the Receiving Party\u2019s Outside Counsel of Record in this action,1 as well as employees of said\n\n 26 Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation\n\n 27 1\n Maulin Shah of EnvisionIP is also authorized Outside Counsel for Plaintiff.\n 28 9\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 10 of 17\n\n\n\n\n 1 and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit\n\n 2 A;\n\n 3 (b) One Designated House Counsel of the Receiving Party (1) who has no involvement in\n\n 4 competitive decision-making, (2) to whom disclosure is reasonably necessary for this litigation, (3) who\n\n 5 has signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), and (4) as to whom the\n\n 6 procedures set forth in paragraph 7.4(a)(1), below, have been followed;\n\n 7 (c) Experts of the Receiving Party (1) to whom disclosure is reasonably necessary for this\n\n 8 litigation, (2) who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), and (3) as\n\n 9 to whom the procedures set forth in paragraph 7.4(a)(2), below, have been followed];\n\n 10 (d) the court and its personnel;\n\n 11 (e) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to\n\n 12 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\nNorthern District of California\n United States District Court\n\n\n\n\n 13 Agreement to Be Bound\u201d (Exhibit A); and\n\n 14 (f) the author or recipient of a document containing the information or a custodian or other person\n\n 15 who otherwise possessed or knew the information.\n\n 16 7.4 Procedures for Approving or Objecting to Disclosure of \u201cHIGHLY CONFIDENTIAL \u2013\n\n 17 ATTORNEYS\u2019 EYES ONLY\u201d Information or Items to Designated House Counsel or Experts.\n\n 18 (a)(1) Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a\n\n 19 Party that seeks to disclose to Designated House Counsel any information or item that has been designated\n\n 20 \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d pursuant to paragraph 7.3(b) first must make\n\n 21 a written request to the Designating Party that (1) sets forth the full name of the Designated House Counsel\n\n 22 and the city and state of his or her residence, and (2) describes the Designated House Counsel\u2019s current and\n\n 23 reasonably foreseeable future primary job duties and responsibilities in sufficient detail to determine if\n\n 24 House Counsel is involved, or may become involved, in any competitive decision-making.\n\n 25 (a)(2) Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a\n\n 26 Party that seeks to disclose to an Expert (as defined in this Order) any information or item that has been\n\n 27 designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d pursuant to paragraph 7.3(c) first\n\n 28 10\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 11 of 17\n\n\n\n\n 1 must make a written request to the Designating Party that (1) identifies the general categories of \u201cHIGHLY\n\n 2 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d information that the Receiving Party seeks permission\n\n 3 to disclose to the Expert, (2) sets forth the full name of the Expert and the city and state of his or her\n\n 4 primary residence, (3) attaches a copy of the Expert\u2019s current resume, (4) identifies the Expert\u2019s current\n\n 5 employer(s), (5) identifies each person or entity from whom the Expert has received compensation or\n\n 6 funding for work in his or her areas of expertise or to whom the expert has provided professional services,\n\n 7 including in connection with a litigation, at any time during the preceding five years,2 and (6) identifies (by\n\n 8 name and number of the case, filing date, and location of court) any litigation in connection with which the\n\n 9 Expert has offered expert testimony, including through a declaration, report, or testimony at a deposition or\n\n 10 trial, during the preceding five years.\n\n 11 (b) A Party that makes a request and provides the information specified in the preceding respective\n\n 12 paragraphs may disclose the subject Protected Material to the identified Designated House Counsel or\nNorthern District of California\n United States District Court\n\n\n\n\n 13 Expert unless, within 14 days of delivering the request, the Party receives a written objection from the\n\n 14 Designating Party. Any such objection must set forth in detail the grounds on which it is based.\n\n 15 (c) A Party that receives a timely written objection must meet and confer with the Designating\n\n 16 Party (through direct voice to voice dialogue) to try to resolve the matter by agreement within seven days\n\n 17 of the written objection. If no agreement is reached, the Party seeking to make the disclosure to Designated\n\n 18 House Counsel or the Expert may file a motion as provided in Civil Local Rule 7 (and in compliance with\n\n 19 Civil Local Rule 79-5, if applicable) seeking permission from the court to do so. Any such motion must\n\n 20 describe the circumstances with specificity, set forth in detail the reasons why the disclosure to Designated\n\n 21 House Counsel or the Expert is reasonably necessary, assess the risk of harm that the disclosure would\n\n 22 entail, and suggest any additional means that could be used to reduce that risk. In addition, any such motion\n\n 23 must be accompanied by a competent declaration describing the parties\u2019 efforts to resolve the matter by\n\n 24 agreement (i.e., the extent and the content of the meet and confer discussions) and setting forth the reasons\n\n 25 advanced by the Designating Party for its refusal to approve the disclosure.\n 2 If the Expert believes any of this information is subject to a confidentiality obligation to a third-party, then the Expert\n 26\n should provide whatever information the Expert believes can be disclosed without violating any confidentiality\n 27 agreements, and the Party seeking to disclose to the Expert shall be available to meet and confer with the Designating\n Party regarding any such engagement.\n 28 11\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 12 of 17\n\n\n\n\n 1 In any such proceeding, the Party opposing disclosure to Designated House Counsel or the Expert\n\n 2 shall bear the burden of proving that the risk of harm that the disclosure would entail (under the safeguards\n\n 3 proposed) outweighs the Receiving Party\u2019s need to disclose the Protected Material to its Designated House\n\n 4 Counsel or Expert.\n\n 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER\n LITIGATION\n 6\n If a Party is served with a subpoena or a court order issued in other litigation that compels\n 7\n disclosure of any information or items designated in this action as \u201cCONFIDENTIAL\u201d or\n 8\n \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d that Party must:\n 9\n (a) promptly notify in writing the Designating Party. Such notification shall include a copy\n 10\n of the subpoena or court order;\n 11\n (b) promptly notify in writing the party who caused the subpoena or order to issue in the\n 12\nNorthern District of California\n\n\n\n\n other litigation that some or all of the material covered by the subpoena or order is subject to this\n United States District Court\n\n\n\n\n 13\n Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and\n 14\n (c) cooperate with respect to all reasonable procedures sought to be pursued by the\n 15\n Designating Party whose Protected Material may be affected.3\n 16\n If the Designating Party timely seeks a protective order, the Party served with the subpoena\n 17\n or court order shall not produce any information designated in this action as \u201cCONFIDENTIAL\u201d\n 18\n or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d before a determination by the\n 19\n court from which the subpoena or order issued, unless the Party has obtained the Designating\n 20\n Party\u2019s permission. The Designating Party shall bear the burden and expense of seeking protection\n 21\n in that court of its confidential material \u2013 and nothing in these provisions should be construed as\n 22\n authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from\n 23\n another court.\n 24\n\n 25\n\n 26\n 3 The purpose of imposing these duties is to alert the interested parties to the existence of this Protective Order and to\n\n 27 afford the Designating Party in this case an opportunity to try to protect its confidentiality interests in the court from\n which the subpoena or order issued.\n 28 12\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 13 of 17\n\n\n\n 9. A NON-PARTY\u0001S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS\n 1 LITIGATION\n 2 (a) The terms of this Order are applicable to information produced by a Non-Party in\n\n 3 this action and designated as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013\n\n 4 ATTORNEYS\u2019 EYES ONLY\u201d. Such information produced by Non-Parties in connection with this\n\n 5 litigation is protected by the remedies and relief provided by this Order. Nothing in these\n\n 6 provisions should be construed as prohibiting a Non-Party from seeking additional protections.\n\n 7 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-\n\n 8 Party\u2019s confidential information in its possession, and the Party is subject to an agreement with the\n\n 9 Non-Party not to produce the Non-Party\u2019s confidential information, then the Party shall:\n\n 10 1. promptly notify in writing the Requesting Party and the Non-Party that some or all\n\n 11 of the information requested is subject to a confidentiality agreement with a Non-Party;\n\n 12 2. promptly provide the Non-Party with a copy of the Stipulated Protective Order in\nNorthern District of California\n United States District Court\n\n\n\n\n 13 this litigation, the relevant discovery request(s), and a reasonably specific description of the information\n\n 14 requested; and\n\n 15 3. make the information requested available for inspection by the Non-Party.\n\n 16 (c) If the Non-Party fails to object or seek a protective order from this court within 14\n\n 17 days of receiving the notice and accompanying information, the Receiving Party may produce the\n\n 18 Non-Party\u2019s confidential information responsive to the discovery request. If the Non-Party timely\n\n 19 seeks a protective order, the Receiving Party shall not produce any information in its possession or\n\n 20 control that is subject to the confidentiality agreement with the Non-Party before a determination\n\n 21 by the court.4 Absent a court order to the contrary, the Non-Party shall bear the burden and\n\n 22 expense of seeking protection in this court of its Protected Material.\n\n 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL\n 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material to\n\n 25 any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving\n\n 26 Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use\n 4 The purpose of this provision is to alert the interested parties to the existence of confidentiality rights of a Non-Party\n 27\n and to afford the Non-Party an opportunity to protect its confidentiality interests in this court.\n 28 13\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 14 of 17\n\n\n\n\n 1 its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons\n\n 2 to whom unauthorized disclosures were made of all the terms of this Order, and (d) request such person or\n\n 3 persons to execute the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit A.\n\n 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED\n MATERIAL\n 5\n When a Producing Party gives notice to Receiving Parties that certain inadvertently\n 6\n produced material is subject to a claim of privilege or other protection, the obligations of the\n 7\n Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This\n 8\n provision is not intended to modify whatever procedure may be established in an e-discovery order\n 9\n that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence\n 10\n 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a\n 11\n communication or information covered by the attorney-client privilege or work product protection,\n 12\nNorthern District of California\n\n\n\n\n the parties may incorporate their agreement in the stipulated protective order submitted to the\n United States District Court\n\n\n\n\n 13\n court.\n 14\n 12. MISCELLANEOUS\n 15\n 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its\n 16\n modification by the court in the future.\n 17\n 14.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no\n 18\n Party waives any right it otherwise would have to object to disclosing or producing any information or item\n 19\n on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to\n 20\n object on any ground to use in evidence of any of the material covered by this Protective Order.\n 21\n 14.3 Export Control. Disclosure of Protected Material shall be subject to all applicable laws and\n 22\n regulations relating to the export of technical data contained in such Protected Material, including the\n 23\n release of such technical data to foreign persons or nationals in the United States or elsewhere. The\n 24\n Producing Party shall be responsible for identifying any such controlled technical data, and the Receiving\n 25\n Party shall take measures necessary to ensure compliance.\n 26\n 14.4 Filing Protected Material. Without written permission from the Designating Party or a\n 27\n\n 28 14\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 15 of 17\n\n\n\n\n 1 court order secured after appropriate notice to all interested persons, a Party may not file in the public\n\n 2 record in this action any Protected Material. A Party that seeks to file under seal any Protected Material\n\n 3 must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a\n\n 4 court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Civil Local Rule\n\n 5 79-5, a sealing order will issue only upon a request establishing that the Protected Material at issue is\n\n 6 privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If a Receiving\n\n 7 Party's request to file Protected Material under seal pursuant to Civil Local Rule 79-5 is denied by the\n\n 8 court, then the Receiving Party may file the Protected Material in the public record pursuant to Civil Local\n\n 9 Rule 79-5 unless otherwise instructed by the court.\n\n 10 13. FINAL DISPOSITION\n 11 Within 60 days after the final disposition of this action, as defined in paragraph 4, each Receiving\n\n 12 Party must return all Protected Material to the Producing Party or destroy such material. As used in this\nNorthern District of California\n United States District Court\n\n\n\n\n 13 subdivision, \u201call Protected Material\u201d includes all copies, abstracts, compilations, summaries, and any other\n\n 14 format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned\n\n 15 or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the\n\n 16 same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category,\n\n 17 where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the\n\n 18 Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format\n\n 19 reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are\n\n 20 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,\n\n 21 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and\n\n 22 consultant and expert work product, even if such materials contain Protected Material. Any such archival\n\n 23 copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in\n\n 24 Section 4 (DURATION).\n\n 25 //\n\n 26 //\n\n 27 //\n\n 28 15\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 16 of 17\n\n\n\n\n 1 //\n\n 2 //\n\n 3\n\n 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.\n\n 5\n DATED: /s/ Michael Rodenbaugh\n 6 Attorneys for Plaintiff\n\n 7 DATED: /s/ Gina Durham\n Attorneys for Defendant\n 8\n\n 9 PURSUANT TO STIPULATION, IT IS SO ORDERED.\n\n 10\n August 22, 2023\n DATED: ________________________ _____________________________________\n 11 [Name of Judge] Joseph C. Spero\n United States District/Magistrate Judge\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n 13\n\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28 16\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f Case 3:23-cv-00844-JCS Document 36 Filed 08/22/23 Page 17 of 17\n\n\n\n\n 1 EXHIBIT A\n\n 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND\n\n 3 I, _____________________________ [print or type full name], of _________________\n\n 4 [print or type full address], declare under penalty of perjury that I have read in its entirety and understand\n\n 5 the Stipulated Protective Order that was issued by the United States District Court for the Northern District\n\n 6 of California on [date] in the case of Nanolabs, Inc. v. Coinbase Global Inc., Case No.: 4:22-cv-01289-\n\n 7 DMR. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I\n\n 8 understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the\n\n 9 nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that\n\n 10 is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the\n\n 11 provisions of this Order.\n\n 12 I further agree to submit to the jurisdiction of the United States District Court for the\nNorthern District of California\n United States District Court\n\n\n\n\n 13 Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order,\n\n 14 even if such enforcement proceedings occur after termination of this action.\n\n 15\n\n 16\n\n 17 Date: _________________________________\n\n 18 City and State where sworn and signed: _________________________________\n\n 19 Printed name: ______________________________\n [printed name]\n 20\n Signature: __________________________________\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28 17\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\f","ocr_status":2,"date_upload":"2024-02-29T09:50:15.077779-08:00","document_number":"36","attachment_number":null,"pacer_doc_id":"035023465477","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Stipulation","acms_document_guid":""}],"date_created":"2023-08-22T09:26:32.425958-07:00","date_modified":"2025-09-18T09:06:07.035053-07:00","date_filed":"2023-08-22","time_filed":"08:25:42","entry_number":36,"recap_sequence_number":"2023-08-22.001","pacer_sequence_number":104,"description":"Order. Signed 8/22/2023 by Magistrate Judge Joseph C. Spero granting 35 Stipulated Protective Order.(klh, COURT STAFF) (Filed on 8/22/2023) (Entered: 08/22/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/362581423/","id":362581423,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/369276035/","id":369276035,"tags":[],"absolute_url":"/docket/66862637/35/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-21T18:05:41.404743-07:00","date_modified":"2025-09-18T09:06:07.006287-07:00","sha1":"21e19fa3d7204775e42ef412b6baef298e1f4aab","page_count":17,"file_size":178948,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.35.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.35.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 1 of 17\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 9\n\n 10\n NANOLABS, INC., Case No.: 3:23-cv-00844-JCS\n 11\n\n 12 Plaintiff, STIPULATED PROTECTIVE ORDER FOR\n Northern District of California\n\n\n\n\n v. LITIGATION INVOLVING HIGHLY\n United States District Court\n\n\n\n\n 13 SENSITIVE CONFIDENTIAL INFORMATION\n COINBASE GLOBAL, INC., AND/OR TRADE SECRETS\n 14\n\n 15 Defendant.\n\n 16 And related counterclaims.\n 17\n\n 18\n\n 19 1. PURPOSES AND LIMITATIONS\n\n 20 Disclosure and discovery activity in this action are likely to involve production of\n\n 21 confidential, proprietary, or private information for which special protection from public\n\n 22 disclosure and from use for any purpose other than prosecuting this litigation may be warranted.\n\n 23 Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated\n\n 24 Protective Order. The parties acknowledge that this Order does not confer blanket protections on\n\n 25 all disclosures or responses to discovery and that the protection it affords from public disclosure\n\n 26 and use extends only to the limited information or items that are entitled to confidential treatment\n\n 27 under the applicable legal principles. The parties further acknowledge, as set forth in Section 14.4,\n\n 28 1\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 2 of 17\n\n\n\n\n 1 below, that this Stipulated Protective Order does not entitle them to file confidential information\n\n 2 under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards\n\n 3 that will be applied when a party seeks permission from the court to file material under seal.\n\n 4 2. DEFINITIONS\n 5 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or\n\n 6 items under this Order.\n\n 7 2.2 \u201cCONFIDENTIAL\u201d Information or Items: information (regardless of how it is generated,\n\n 8 stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure\n\n 9 26(c).\n\n 10 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as\n\n 11 their support staff).\n\n 12 2.4 Designated House Counsel: House Counsel who seek access to \u201cHIGHLY\n Northern District of California\n United States District Court\n\n\n\n\n 13 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d information in this matter.\n\n 14 2.5 Designating Party: a Party or Non-Party that designates information or items that it\n\n 15 produces in disclosures or in responses to discovery as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY\n\n 16 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d.\n\n 17 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium or\n\n 18 manner in which it is generated, stored, or maintained (including, among other things, testimony,\n\n 19 transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in\n\n 20 this matter.\n\n 21 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the\n\n 22 litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consultant\n\n 23 in this action, (2) is not a past or current employee of a Party or of a Party\u2019s competitor, and (3) at the time\n\n 24 of retention, is not anticipated to become an employee of a Party or of a Party\u2019s competitor.\n\n 25 2.8 \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d Information or Items:\n\n 26 extremely sensitive \u201cConfidential Information or Items,\u201d disclosure of which to another Party or Non-Party\n\n 27 would create a substantial risk of serious harm that could not be avoided by less restrictive means.\n\n 28 2\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 3 of 17\n\n\n\n\n 1 2.10 House Counsel: attorneys who are employees of a party to this action. House Counsel does\n\n 2 not include Outside Counsel of Record or any other outside counsel.\n\n 3 2.11 Non-Party: any natural person, partnership, corporation, association, or other legal entity\n\n 4 not named as a Party to this action.\n\n 5 2.12 Outside Counsel of Record: attorneys who are not employees of a party to this action but\n\n 6 are retained to represent or advise a party to this action and have appeared in this action on behalf of that\n\n 7 party or are affiliated with a law firm which has appeared on behalf of that party.\n\n 8 2.13 Party: any party to this action, including all of its officers, directors, employees,\n\n 9 consultants, retained experts, and Outside Counsel of Record (and their support staffs).\n\n 10 2.14 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in\n\n 11 this action.\n\n 12 2.15 Professional Vendors: persons or entities that provide litigation support services (e.g.,\n Northern District of California\n United States District Court\n\n\n\n\n 13 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or\n\n 14 retrieving data in any form or medium) and their employees and subcontractors.\n\n 15 2.16 Protected Material: any Disclosure or Discovery Material that is designated as\n\n 16 \u201cCONFIDENTIAL,\u201d or as \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d\n\n 17 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing\n\n 18 Party.\n\n 19 3. SCOPE\n 20 The protections conferred by this Stipulation and Order cover not only Protected Material (as\n\n 21 defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies,\n\n 22 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or\n\n 23 presentations by Parties or their Counsel that might reveal Protected Material. However, the protections\n\n 24 conferred by this Stipulation and Order do not cover the following information: (a) any information that is\n\n 25 in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain\n\n 26 after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order,\n\n 27 including becoming part of the public record through trial or otherwise; and (b) any information known to\n\n 28 3\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 4 of 17\n\n\n\n\n 1 the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a\n\n 2 source who obtained the information lawfully and under no obligation of confidentiality to the Designating\n\n 3 Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.\n\n 4 4. DURATION\n 5 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order\n\n 6 shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise\n\n 7 directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this\n\n 8 action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all\n\n 9 appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any\n\n 10 motions or applications for extension of time pursuant to applicable law.\n\n 11 5. DESIGNATING PROTECTED MATERIAL\n 12 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-\n Northern District of California\n United States District Court\n\n\n\n\n 13 Party that designates information or items for protection under this Order must take care to limit any such\n\n 14 designation to specific material that qualifies under the appropriate standards. To the extent it is practical to\n\n 15 do so, the Designating Party must designate for protection only those parts of material, documents, items,\n\n 16 or oral or written communications that qualify \u2013 so that other portions of the material, documents, items, or\n\n 17 communications for which protection is not warranted are not swept unjustifiably within the ambit of this\n\n 18 Order.\n\n 19 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be\n\n 20 clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or\n\n 21 retard the case development process or to impose unnecessary expenses and burdens on other parties)\n\n 22 expose the Designating Party to sanctions.\n\n 23 If it comes to a Designating Party\u2019s attention that information or items that it designated for\n\n 24 protection do not qualify for protection at all or do not qualify for the level of protection initially asserted,\n\n 25 that Designating Party must promptly notify all other parties that it is withdrawing the mistaken\n\n 26 designation.\n\n 27 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g.,\n\n 28 4\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 5 of 17\n\n\n\n\n 1 second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery\n\n 2 Material that qualifies for protection under this Order must be clearly so designated before the\n\n 3 material is disclosed or produced.\n\n 4 Designation in conformity with this Order requires:\n\n 5 (a) for information in documentary form (e.g., paper or electronic documents, but excluding\n\n 6 transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the legend\n\n 7 \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d to each page that\n\n 8 contains protected material. If only a portion or portions of the material on a page qualifies for protection,\n\n 9 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate\n\n 10 markings in the margins) and must specify, for each portion, the level of protection being asserted.\n\n 11 A Party or Non-Party that makes original documents or materials available for inspection need not\n\n 12 designate them for protection until after the inspecting Party has indicated which material it would like\n Northern District of California\n United States District Court\n\n\n\n\n 13 copied and produced. During the inspection and before the designation, all of the material made available\n\n 14 for inspection shall be deemed \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d After the\n\n 15 inspecting Party has identified the documents it wants copied and produced, the Producing Party must\n\n 16 determine which documents, or portions thereof, qualify for protection under this Order. Then, before\n\n 17 producing the specified documents, the Producing Party must affix the appropriate legend\n\n 18 (\u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d to each page that\n\n 19 contains Protected Material. If only a portion or portions of the material on a page qualifies for protection,\n\n 20 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate\n\n 21 markings in the margins) and must specify, for each portion, the level of protection being asserted.\n\n 22 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the Designating\n\n 23 Party identify on the record, before the close of the deposition, hearing, or other proceeding, all protected\n\n 24 testimony and specify the level of protection being asserted. When it is impractical to identify separately\n\n 25 each portion of testimony that is entitled to protection and it appears that substantial portions of the\n\n 26 testimony may qualify for protection, the Designating Party may invoke on the record (before the\n\n 27 deposition, hearing, or other proceeding is concluded) a right to have up to 21 days to identify the specific\n\n 28 5\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 6 of 17\n\n\n\n\n 1 portions of the testimony as to which protection is sought and to specify the level of protection being\n\n 2 asserted. Only those portions of the testimony that are appropriately designated for protection within the 21\n\n 3 days shall be covered by the provisions of this Stipulated Protective Order. Alternatively, a Designating\n\n 4 Party may specify, at the deposition or up to 21 days afterwards if that period is properly invoked, that the\n\n 5 entire transcript shall be treated as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 6 EYES ONLY.\u201d\n\n 7 Parties shall give the other parties notice if they reasonably expect a deposition, hearing or other\n\n 8 proceeding to include Protected Material so that the other parties can ensure that only authorized\n\n 9 individuals who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A) are present at\n\n 10 those proceedings. The use of a document as an exhibit at a deposition shall not in any way affect its\n\n 11 designation as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY.\u201d\n\n 12 Transcripts containing Protected Material shall have an obvious legend on the title page that the\n Northern District of California\n United States District Court\n\n\n\n\n 13 transcript contains Protected Material, and the title page shall be followed by a list of all pages (including\n\n 14 line numbers as appropriate) that have been designated as Protected Material and the level of protection\n\n 15 being asserted by the Designating Party. The Designating Party shall inform the court reporter of these\n\n 16 requirements. Any transcript that is prepared before the expiration of a 21-day period for designation shall\n\n 17 be treated during that period as if it had been designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 18 EYES ONLY\u201d in its entirety unless otherwise agreed. After the expiration of that period, the transcript shall\n\n 19 be treated only as actually designated.\n\n 20 (c) for information produced in some form other than documentary and for any other tangible\n\n 21 items, that the Producing Party affix in a prominent place on the exterior of the container or containers in\n\n 22 which the information or item is stored the legend \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013\n\n 23 ATTORNEYS\u2019 EYES ONLY\u201d. If only a portion or portions of the information or item warrant protection,\n\n 24 the Producing Party, to the extent practicable, shall identify the protected portion(s) and specify the level of\n\n 25 protection being asserted.\n\n 26 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate\n\n 27 qualified information or items does not, standing alone, waive the Designating Party\u2019s right to secure\n\n 28 6\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 7 of 17\n\n\n\n\n 1 protection under this Order for such material. Upon timely correction of a designation, the Receiving Party\n\n 2 must make reasonable efforts to assure that the material is treated in accordance with the provisions of this\n\n 3 Order.\n\n 4 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS\n 5 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of\n\n 6 confidentiality at any time. Unless a prompt challenge to a Designating Party\u2019s confidentiality designation\n\n 7 is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant\n\n 8 disruption or delay of the litigation, a Party does not waive its right to challenge a confidentiality\n\n 9 designation by electing not to mount a challenge promptly after the original designation is disclosed.\n\n 10 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by\n\n 11 providing written notice of each designation it is challenging and describing the basis for each challenge.\n\n 12 To avoid ambiguity as to whether a challenge has been made, the written notice must recite that the\n Northern District of California\n United States District Court\n\n\n\n\n 13 challenge to confidentiality is being made in accordance with this specific paragraph of the Protective\n\n 14 Order. The parties shall attempt to resolve each challenge in good faith and must begin the process by\n\n 15 conferring directly (in voice to voice dialogue; other forms of communication are not sufficient) within 14\n\n 16 days of the date of service of notice. In conferring, the Challenging Party must explain the basis for its\n\n 17 belief that the confidentiality designation was not proper and must give the Designating Party an\n\n 18 opportunity to review the designated material, to reconsider the circumstances, and, if no change in\n\n 19 designation is offered, to explain the basis for the chosen designation. A Challenging Party may proceed to\n\n 20 the next stage of the challenge process only if it has engaged in this meet and confer process first or\n\n 21 establishes that the Designating Party is unwilling to participate in the meet and confer process in a timely\n\n 22 manner.\n\n 23 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court intervention,\n\n 24 the Designating Party shall file and serve a motion to retain confidentiality under Civil Local Rule 7 (and in\n\n 25 compliance with Civil Local Rule 79-5, if applicable) within 21 days of the initial notice of challenge or\n\n 26 within 14 days of the parties agreeing that the meet and confer process will not resolve their dispute,\n\n 27 whichever is earlier. Each such motion must be accompanied by a competent declaration affirming that the\n\n 28 7\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 8 of 17\n\n\n\n\n 1 movant has complied with the meet and confer requirements imposed in the preceding paragraph. Failure\n\n 2 by the Designating Party to make such a motion including the required declaration within 21 days (or 14\n\n 3 days, if applicable) shall automatically waive the confidentiality designation for each challenged\n\n 4 designation. In addition, the Challenging Party may file a motion challenging a confidentiality designation\n\n 5 at any time if there is good cause for doing so, including a challenge to the designation of a deposition\n\n 6 transcript or any portions thereof. Any motion brought pursuant to this provision must be accompanied by a\n\n 7 competent declaration affirming that the movant has complied with the meet and confer requirements\n\n 8 imposed by the preceding paragraph.\n\n 9 The burden of persuasion in any such challenge proceeding shall be on the Designating Party.\n\n 10 Frivolous challenges and those made for an improper purpose (e.g., to harass or impose unnecessary\n\n 11 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the\n\n 12 Designating Party has waived the confidentiality designation by failing to file a motion to retain\n Northern District of California\n United States District Court\n\n\n\n\n 13 confidentiality as described above, all parties shall continue to afford the material in question the level of\n\n 14 protection to which it is entitled under the Producing Party\u2019s designation until the court rules on the\n\n 15 challenge.\n\n 16 7. ACCESS TO AND USE OF PROTECTED MATERIAL\n 17 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or\n\n 18 produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending,\n\n 19 or attempting to settle this litigation. Such Protected Material may be disclosed only to the categories of\n\n 20 persons and under the conditions described in this Order. When the litigation has been terminated, a\n\n 21 Receiving Party must comply with the provisions of section 15 below (FINAL DISPOSITION).\n\n 22 Protected Material must be stored and maintained by a Receiving Party at a location and in a secure\n\n 23 manner that ensures that access is limited to the persons authorized under this Order.\n\n 24 7.2 Disclosure of \u201cCONFIDENTIAL\u201d Information or Items. Unless otherwise ordered by the\n\n 25 court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or\n\n 26 item designated \u201cCONFIDENTIAL\u201d only to:\n\n 27 (a) the Receiving Party\u2019s Outside Counsel of Record in this action, as well as employees of said\n\n 28 8\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 9 of 17\n\n\n\n\n 1 Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation\n\n 2 and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit\n\n 3 A;\n\n 4 (b) the officers, directors, and employees (including House Counsel) of the Receiving Party to\n\n 5 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\n\n 6 Agreement to Be Bound\u201d (Exhibit A);\n\n 7 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is reasonably\n\n 8 necessary for this litigation and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d\n\n 9 (Exhibit A);\n\n 10 (d) the court and its personnel;\n\n 11 (e) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to\n\n 12 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\n Northern District of California\n United States District Court\n\n\n\n\n 13 Agreement to Be Bound\u201d (Exhibit A);\n\n 14 (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and\n\n 15 who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), unless otherwise\n\n 16 agreed by the Designating Party or ordered by the court. Pages of transcribed deposition testimony or\n\n 17 exhibits to depositions that reveal Protected Material must be separately bound by the court reporter and\n\n 18 may not be disclosed to anyone except as permitted under this Stipulated Protective Order.\n\n 19 (g) the author or recipient of a document containing the information or a custodian or other person\n\n 20 who otherwise possessed or knew the information.\n\n 21 7.3 Disclosure of \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d Information or\n\n 22 Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receiving\n\n 23 Party may disclose any information or item designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019\n\n 24 EYES ONLY\u201d only to:\n\n 25 (a) the Receiving Party\u2019s Outside Counsel of Record in this action,1 as well as employees of said\n\n 26 Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this litigation\n\n 27 1\n Maulin Shah of EnvisionIP is also authorized Outside Counsel for Plaintiff.\n 28 9\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 10 of 17\n\n\n\n\n 1 and who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit\n\n 2 A;\n\n 3 (b) One Designated House Counsel of the Receiving Party (1) who has no involvement in\n\n 4 competitive decision-making, (2) to whom disclosure is reasonably necessary for this litigation, (3) who\n\n 5 has signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), and (4) as to whom the\n\n 6 procedures set forth in paragraph 7.4(a)(1), below, have been followed;\n\n 7 (c) Experts of the Receiving Party (1) to whom disclosure is reasonably necessary for this\n\n 8 litigation, (2) who have signed the \u201cAcknowledgment and Agreement to Be Bound\u201d (Exhibit A), and (3) as\n\n 9 to whom the procedures set forth in paragraph 7.4(a)(2), below, have been followed];\n\n 10 (d) the court and its personnel;\n\n 11 (e) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to\n\n 12 whom disclosure is reasonably necessary for this litigation and who have signed the \u201cAcknowledgment and\n Northern District of California\n United States District Court\n\n\n\n\n 13 Agreement to Be Bound\u201d (Exhibit A); and\n\n 14 (f) the author or recipient of a document containing the information or a custodian or other person\n\n 15 who otherwise possessed or knew the information.\n\n 16 7.4 Procedures for Approving or Objecting to Disclosure of \u201cHIGHLY CONFIDENTIAL \u2013\n\n 17 ATTORNEYS\u2019 EYES ONLY\u201d Information or Items to Designated House Counsel or Experts.\n\n 18 (a)(1) Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a\n\n 19 Party that seeks to disclose to Designated House Counsel any information or item that has been designated\n\n 20 \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d pursuant to paragraph 7.3(b) first must make\n\n 21 a written request to the Designating Party that (1) sets forth the full name of the Designated House Counsel\n\n 22 and the city and state of his or her residence, and (2) describes the Designated House Counsel\u2019s current and\n\n 23 reasonably foreseeable future primary job duties and responsibilities in sufficient detail to determine if\n\n 24 House Counsel is involved, or may become involved, in any competitive decision-making.\n\n 25 (a)(2) Unless otherwise ordered by the court or agreed to in writing by the Designating Party, a\n\n 26 Party that seeks to disclose to an Expert (as defined in this Order) any information or item that has been\n\n 27 designated \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d pursuant to paragraph 7.3(c) first\n\n 28 10\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 11 of 17\n\n\n\n\n 1 must make a written request to the Designating Party that (1) identifies the general categories of \u201cHIGHLY\n\n 2 CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d information that the Receiving Party seeks permission\n\n 3 to disclose to the Expert, (2) sets forth the full name of the Expert and the city and state of his or her\n\n 4 primary residence, (3) attaches a copy of the Expert\u2019s current resume, (4) identifies the Expert\u2019s current\n\n 5 employer(s), (5) identifies each person or entity from whom the Expert has received compensation or\n\n 6 funding for work in his or her areas of expertise or to whom the expert has provided professional services,\n\n 7 including in connection with a litigation, at any time during the preceding five years,2 and (6) identifies (by\n\n 8 name and number of the case, filing date, and location of court) any litigation in connection with which the\n\n 9 Expert has offered expert testimony, including through a declaration, report, or testimony at a deposition or\n\n 10 trial, during the preceding five years.\n\n 11 (b) A Party that makes a request and provides the information specified in the preceding respective\n\n 12 paragraphs may disclose the subject Protected Material to the identified Designated House Counsel or\n Northern District of California\n United States District Court\n\n\n\n\n 13 Expert unless, within 14 days of delivering the request, the Party receives a written objection from the\n\n 14 Designating Party. Any such objection must set forth in detail the grounds on which it is based.\n\n 15 (c) A Party that receives a timely written objection must meet and confer with the Designating\n\n 16 Party (through direct voice to voice dialogue) to try to resolve the matter by agreement within seven days\n\n 17 of the written objection. If no agreement is reached, the Party seeking to make the disclosure to Designated\n\n 18 House Counsel or the Expert may file a motion as provided in Civil Local Rule 7 (and in compliance with\n\n 19 Civil Local Rule 79-5, if applicable) seeking permission from the court to do so. Any such motion must\n\n 20 describe the circumstances with specificity, set forth in detail the reasons why the disclosure to Designated\n\n 21 House Counsel or the Expert is reasonably necessary, assess the risk of harm that the disclosure would\n\n 22 entail, and suggest any additional means that could be used to reduce that risk. In addition, any such motion\n\n 23 must be accompanied by a competent declaration describing the parties\u2019 efforts to resolve the matter by\n\n 24 agreement (i.e., the extent and the content of the meet and confer discussions) and setting forth the reasons\n\n 25 advanced by the Designating Party for its refusal to approve the disclosure.\n 2 If the Expert believes any of this information is subject to a confidentiality obligation to a third-party, then the Expert\n 26\n should provide whatever information the Expert believes can be disclosed without violating any confidentiality\n 27 agreements, and the Party seeking to disclose to the Expert shall be available to meet and confer with the Designating\n Party regarding any such engagement.\n 28 11\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 12 of 17\n\n\n\n\n 1 In any such proceeding, the Party opposing disclosure to Designated House Counsel or the Expert\n\n 2 shall bear the burden of proving that the risk of harm that the disclosure would entail (under the safeguards\n\n 3 proposed) outweighs the Receiving Party\u2019s need to disclose the Protected Material to its Designated House\n\n 4 Counsel or Expert.\n\n 5 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER\n LITIGATION\n 6\n If a Party is served with a subpoena or a court order issued in other litigation that compels\n 7\n disclosure of any information or items designated in this action as \u201cCONFIDENTIAL\u201d or\n 8\n \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d that Party must:\n 9\n (a) promptly notify in writing the Designating Party. Such notification shall include a copy\n 10\n of the subpoena or court order;\n 11\n (b) promptly notify in writing the party who caused the subpoena or order to issue in the\n 12\n Northern District of California\n\n\n\n\n other litigation that some or all of the material covered by the subpoena or order is subject to this\n United States District Court\n\n\n\n\n 13\n Protective Order. Such notification shall include a copy of this Stipulated Protective Order; and\n 14\n (c) cooperate with respect to all reasonable procedures sought to be pursued by the\n 15\n Designating Party whose Protected Material may be affected.3\n 16\n If the Designating Party timely seeks a protective order, the Party served with the subpoena\n 17\n or court order shall not produce any information designated in this action as \u201cCONFIDENTIAL\u201d\n 18\n or \u201cHIGHLY CONFIDENTIAL \u2013 ATTORNEYS\u2019 EYES ONLY\u201d before a determination by the\n 19\n court from which the subpoena or order issued, unless the Party has obtained the Designating\n 20\n Party\u2019s permission. The Designating Party shall bear the burden and expense of seeking protection\n 21\n in that court of its confidential material \u2013 and nothing in these provisions should be construed as\n 22\n authorizing or encouraging a Receiving Party in this action to disobey a lawful directive from\n 23\n another court.\n 24\n\n 25\n\n 26\n 3 The purpose of imposing these duties is to alert the interested parties to the existence of this Protective Order and to\n\n 27 afford the Designating Party in this case an opportunity to try to protect its confidentiality interests in the court from\n which the subpoena or order issued.\n 28 12\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 13 of 17\n\n\n\n 9. A NON-PARTY!S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS\n 1 LITIGATION\n 2 (a) The terms of this Order are applicable to information produced by a Non-Party in\n\n 3 this action and designated as \u201cCONFIDENTIAL\u201d or \u201cHIGHLY CONFIDENTIAL \u2013\n\n 4 ATTORNEYS\u2019 EYES ONLY\u201d. Such information produced by Non-Parties in connection with this\n\n 5 litigation is protected by the remedies and relief provided by this Order. Nothing in these\n\n 6 provisions should be construed as prohibiting a Non-Party from seeking additional protections.\n\n 7 (b) In the event that a Party is required, by a valid discovery request, to produce a Non-\n\n 8 Party\u2019s confidential information in its possession, and the Party is subject to an agreement with the\n\n 9 Non-Party not to produce the Non-Party\u2019s confidential information, then the Party shall:\n\n 10 1. promptly notify in writing the Requesting Party and the Non-Party that some or all\n\n 11 of the information requested is subject to a confidentiality agreement with a Non-Party;\n\n 12 2. promptly provide the Non-Party with a copy of the Stipulated Protective Order in\n Northern District of California\n United States District Court\n\n\n\n\n 13 this litigation, the relevant discovery request(s), and a reasonably specific description of the information\n\n 14 requested; and\n\n 15 3. make the information requested available for inspection by the Non-Party.\n\n 16 (c) If the Non-Party fails to object or seek a protective order from this court within 14\n\n 17 days of receiving the notice and accompanying information, the Receiving Party may produce the\n\n 18 Non-Party\u2019s confidential information responsive to the discovery request. If the Non-Party timely\n\n 19 seeks a protective order, the Receiving Party shall not produce any information in its possession or\n\n 20 control that is subject to the confidentiality agreement with the Non-Party before a determination\n\n 21 by the court.4 Absent a court order to the contrary, the Non-Party shall bear the burden and\n\n 22 expense of seeking protection in this court of its Protected Material.\n\n 23 10. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL\n 24 If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected Material to\n\n 25 any person or in any circumstance not authorized under this Stipulated Protective Order, the Receiving\n\n 26 Party must immediately (a) notify in writing the Designating Party of the unauthorized disclosures, (b) use\n 4 The purpose of this provision is to alert the interested parties to the existence of confidentiality rights of a Non-Party\n 27\n and to afford the Non-Party an opportunity to protect its confidentiality interests in this court.\n 28 13\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 14 of 17\n\n\n\n\n 1 its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the person or persons\n\n 2 to whom unauthorized disclosures were made of all the terms of this Order, and (d) request such person or\n\n 3 persons to execute the \u201cAcknowledgment and Agreement to Be Bound\u201d that is attached hereto as Exhibit A.\n\n 4 11. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED\n MATERIAL\n 5\n When a Producing Party gives notice to Receiving Parties that certain inadvertently\n 6\n produced material is subject to a claim of privilege or other protection, the obligations of the\n 7\n Receiving Parties are those set forth in Federal Rule of Civil Procedure 26(b)(5)(B). This\n 8\n provision is not intended to modify whatever procedure may be established in an e-discovery order\n 9\n that provides for production without prior privilege review. Pursuant to Federal Rule of Evidence\n 10\n 502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure of a\n 11\n communication or information covered by the attorney-client privilege or work product protection,\n 12\n Northern District of California\n\n\n\n\n the parties may incorporate their agreement in the stipulated protective order submitted to the\n United States District Court\n\n\n\n\n 13\n court.\n 14\n 12. MISCELLANEOUS\n 15\n 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its\n 16\n modification by the court in the future.\n 17\n 14.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no\n 18\n Party waives any right it otherwise would have to object to disclosing or producing any information or item\n 19\n on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to\n 20\n object on any ground to use in evidence of any of the material covered by this Protective Order.\n 21\n 14.3 Export Control. Disclosure of Protected Material shall be subject to all applicable laws and\n 22\n regulations relating to the export of technical data contained in such Protected Material, including the\n 23\n release of such technical data to foreign persons or nationals in the United States or elsewhere. The\n 24\n Producing Party shall be responsible for identifying any such controlled technical data, and the Receiving\n 25\n Party shall take measures necessary to ensure compliance.\n 26\n 14.4 Filing Protected Material. Without written permission from the Designating Party or a\n 27\n\n 28 14\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 15 of 17\n\n\n\n\n 1 court order secured after appropriate notice to all interested persons, a Party may not file in the public\n\n 2 record in this action any Protected Material. A Party that seeks to file under seal any Protected Material\n\n 3 must comply with Civil Local Rule 79-5. Protected Material may only be filed under seal pursuant to a\n\n 4 court order authorizing the sealing of the specific Protected Material at issue. Pursuant to Civil Local Rule\n\n 5 79-5, a sealing order will issue only upon a request establishing that the Protected Material at issue is\n\n 6 privileged, protectable as a trade secret, or otherwise entitled to protection under the law. If a Receiving\n\n 7 Party's request to file Protected Material under seal pursuant to Civil Local Rule 79-5 is denied by the\n\n 8 court, then the Receiving Party may file the Protected Material in the public record pursuant to Civil Local\n\n 9 Rule 79-5 unless otherwise instructed by the court.\n\n 10 13. FINAL DISPOSITION\n 11 Within 60 days after the final disposition of this action, as defined in paragraph 4, each Receiving\n\n 12 Party must return all Protected Material to the Producing Party or destroy such material. As used in this\n Northern District of California\n United States District Court\n\n\n\n\n 13 subdivision, \u201call Protected Material\u201d includes all copies, abstracts, compilations, summaries, and any other\n\n 14 format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned\n\n 15 or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the\n\n 16 same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category,\n\n 17 where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the\n\n 18 Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format\n\n 19 reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are\n\n 20 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,\n\n 21 legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and\n\n 22 consultant and expert work product, even if such materials contain Protected Material. Any such archival\n\n 23 copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in\n\n 24 Section 4 (DURATION).\n\n 25 //\n\n 26 //\n\n 27 //\n\n 28 15\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 16 of 17\n\n\n\n\n 1 //\n\n 2 //\n\n 3\n\n 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.\n\n 5\n DATED: /s/ Michael Rodenbaugh\n 6 Attorneys for Plaintiff\n\n 7 DATED: /s/ Gina Durham\n Attorneys for Defendant\n 8\n 9 PURSUANT TO STIPULATION, IT IS SO ORDERED.\n\n 10\n DATED: ________________________ _____________________________________\n 11 [Name of Judge]\n United States District/Magistrate Judge\n 12\n Northern District of California\n United States District Court\n\n\n\n\n 13\n\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28 16\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f Case 3:23-cv-00844-JCS Document 35 Filed 08/21/23 Page 17 of 17\n\n\n\n\n 1 EXHIBIT A\n\n 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND\n\n 3 I, _____________________________ [print or type full name], of _________________\n\n 4 [print or type full address], declare under penalty of perjury that I have read in its entirety and understand\n\n 5 the Stipulated Protective Order that was issued by the United States District Court for the Northern District\n\n 6 of California on [date] in the case of Nanolabs, Inc. v. Coinbase Global Inc., Case No.: 4:22-cv-01289-\n\n 7 DMR. I agree to comply with and to be bound by all the terms of this Stipulated Protective Order and I\n\n 8 understand and acknowledge that failure to so comply could expose me to sanctions and punishment in the\n\n 9 nature of contempt. I solemnly promise that I will not disclose in any manner any information or item that\n\n 10 is subject to this Stipulated Protective Order to any person or entity except in strict compliance with the\n\n 11 provisions of this Order.\n\n 12 I further agree to submit to the jurisdiction of the United States District Court for the\n Northern District of California\n United States District Court\n\n\n\n\n 13 Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order,\n\n 14 even if such enforcement proceedings occur after termination of this action.\n\n 15\n\n 16\n\n 17 Date: _________________________________\n\n 18 City and State where sworn and signed: _________________________________\n\n 19 Printed name: ______________________________\n [printed name]\n 20\n Signature: __________________________________\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28 17\n STIPULATED PROTECTIVE ORDER\n CASE NO. 3:23-CV-844\n\ufffc\n\f","ocr_status":2,"date_upload":"2024-02-29T09:50:01.264282-08:00","document_number":"35","attachment_number":null,"pacer_doc_id":"035023464439","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation","acms_document_guid":""}],"date_created":"2023-08-21T18:05:41.398008-07:00","date_modified":"2025-09-18T09:06:06.973751-07:00","date_filed":"2023-08-21","time_filed":"18:03:43","entry_number":35,"recap_sequence_number":"2023-08-21.001","pacer_sequence_number":101,"description":"STIPULATED PROTECTIVE ORDER filed by Nanolabs, Inc.. (Comunale, Anafrancesca) (Filed on 8/21/2023) Modified on 8/22/2023 (klh, COURT STAFF). (Entered: 08/21/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/361440384/","id":361440384,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/368079200/","id":368079200,"tags":[],"absolute_url":"","date_created":"2023-08-09T11:37:38.633092-07:00","date_modified":"2023-08-10T10:30:15.198952-07:00","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":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Set Deadlines/Hearings AND ~Util - Teleconference Zoom","acms_document_guid":""}],"date_created":"2023-08-09T11:37:38.625378-07:00","date_modified":"2023-08-10T10:30:15.190885-07:00","date_filed":"2023-08-09","time_filed":"10:35:01","entry_number":null,"recap_sequence_number":"2023-08-09.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/361434323/","id":361434323,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/387573576/","id":387573576,"tags":[],"absolute_url":"","date_created":"2024-02-29T09:36:07.879823-08:00","date_modified":"2025-09-18T09:06:06.952471-07:00","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":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Set Deadlines/Hearings","acms_document_guid":""}],"date_created":"2023-08-09T11:01:13.880672-07:00","date_modified":"2025-09-18T09:06:06.930603-07:00","date_filed":"2023-08-09","time_filed":null,"entry_number":null,"recap_sequence_number":"2023-08-09.003","pacer_sequence_number":null,"description":"See Order 34 Set Deadlines/Hearings: Further Case Management Conference re-set for 11/3/2023 02:00 PM in San Francisco, - Videoconference Only. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/jcs General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. (klh, COURT STAFF) (Filed on 8/9/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/361434322/","id":361434322,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/368073079/","id":368073079,"tags":[],"absolute_url":"/docket/66862637/34/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-09T11:01:13.866607-07:00","date_modified":"2025-09-18T09:06:06.910730-07:00","sha1":"6d4b6a00e432b3ae814097bf0d0f9456e3c0563a","page_count":2,"file_size":148006,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.34.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.34.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 34 Filed 08/09/23 Page 1 of 2\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 8\n\n 9 Case No.: 3:23-cv-00844-JCS\n NANOLABS, INC.,\n 10\n\n 11 Plaintiff, STIPULATED REQUEST FOR ORDER\n CHANGING TIME OF CASE\n 12 v. MANAGEMENT CONFERENCE\nNorthern District of California\n United States District Court\n\n\n\n\n 13 COINBASE GLOBAL, INC.,\n 14\n Defendant.\n 15\n\n 16\n Pursuant to Local Rule 6-2, due to pre-scheduled conflict preventing Plaintiff\u2019s counsel\n 17 from attending, the parties stipulate to continue the Case Management Conference, currently set\n 3\n 18 for October 27, 2023, for one week, to November 2, 2023. The attached Declaration of Michael\n\n 19 Rodenbaugh, Esq., sets forth the information required by Local Rule 6-2.\n\n 20\n Dated: August 9, 2023 Respectfully submitted,\n 21\n\n 22\n\n 23\n\n 24 Mike L. Rodenbaugh (SBN 179059)\n RODENBAUGH LAW\n 25\n\n 26 Attorneys for Plaintiff,\n NANOLABS, INC.\n 27\n\n 28\n Stipulation to Continue 1\n Case Management Conference\n\f Case 3:23-cv-00844-JCS Document 34 Filed 08/09/23 Page 2 of 2\n\n\n\n\n Dated: August 9, 2023 Respectfully submitted,\n 1\n\n 2 /s/ Gina Durham\n ____________________________\n 3 Gina Durham (SBN 295910)\n 4 DLA PIPER LLP (US)\n 555 Mission Street\n 5 San Francisco, CA 94105\n Tel: (415) 836-2506\n 6 Fax: (415) 659-7333\n Gina.durham@dlapiper.com\n 7\n\n 8 Attorneys for Defendant\n COINBASE INTERNATIONAL, INC.\n 9\n\n 10\n\n 11 PURSUANT TO STIPULATION, IT IS SO ORDERED,AS MODIFIED.\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n ___________________________ August 9, 2023\n _________________\n 13\n Magistrate Judge Joseph C. Spero Date\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28\n Stipulation to Continue 2\n Case Management Conference\n\f","ocr_status":2,"date_upload":"2024-02-29T09:49:38.309702-08:00","document_number":"34","attachment_number":null,"pacer_doc_id":"035023421321","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Stipulation","acms_document_guid":""}],"date_created":"2023-08-09T11:01:13.649284-07:00","date_modified":"2025-09-18T09:06:06.880638-07:00","date_filed":"2023-08-09","time_filed":"10:32:04","entry_number":34,"recap_sequence_number":"2023-08-09.002","pacer_sequence_number":96,"description":"Order. Signed as modified on 8/9/2023 by Magistrate Judge Joseph C. Spero granting 33 Stipulation For Order Changing Time of Case Management Conference.(klh, COURT STAFF) (Filed on 8/9/2023) (Entered: 08/09/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/361398201/","id":361398201,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/368036565/","id":368036565,"tags":[],"absolute_url":"/docket/66862637/33/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-09T08:00:32.861865-07:00","date_modified":"2025-09-18T09:06:06.856537-07:00","sha1":"6103efb0abc8f964b0909c28a855146186af239c","page_count":2,"file_size":119384,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.33.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.33.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 33 Filed 08/09/23 Page 1 of 2\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 8\n\n 9 Case No.: 3:23-cv-00844-JCS\n NANOLABS, INC.,\n 10\n\n 11 Plaintiff, STIPULATED REQUEST FOR ORDER\n CHANGING TIME OF CASE\n 12 v. MANAGEMENT CONFERENCE\nNorthern District of California\n United States District Court\n\n\n\n\n 13 COINBASE GLOBAL, INC.,\n 14\n Defendant.\n 15\n\n 16\n Pursuant to Local Rule 6-2, due to pre-scheduled conflict preventing Plaintiff\u2019s counsel\n 17 from attending, the parties stipulate to continue the Case Management Conference, currently set\n 18 for October 27, 2023, for one week, to November 2, 2023. The attached Declaration of Michael\n\n 19 Rodenbaugh, Esq., sets forth the information required by Local Rule 6-2.\n\n 20\n Dated: August 9, 2023 Respectfully submitted,\n 21\n\n 22\n\n 23\n\n 24 Mike L. Rodenbaugh (SBN 179059)\n RODENBAUGH LAW\n 25\n\n 26 Attorneys for Plaintiff,\n NANOLABS, INC.\n 27\n\n 28\n Stipulation to Continue 1\n Case Management Conference\n\f Case 3:23-cv-00844-JCS Document 33 Filed 08/09/23 Page 2 of 2\n\n\n\n\n Dated: August 9, 2023 Respectfully submitted,\n 1\n\n 2 /s/ Gina Durham\n ____________________________\n 3 Gina Durham (SBN 295910)\n 4 DLA PIPER LLP (US)\n 555 Mission Street\n 5 San Francisco, CA 94105\n Tel: (415) 836-2506\n 6 Fax: (415) 659-7333\n Gina.durham@dlapiper.com\n 7\n\n 8 Attorneys for Defendant\n COINBASE INTERNATIONAL, INC.\n 9\n\n 10\n\n 11 PURSUANT TO STIPULATION, IT IS SO ORDERED,\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n ___________________________ _________________\n 13\n Magistrate Judge Joseph C. Spero Date\n 14\n\n 15\n\n 16\n\n 17\n\n 18\n\n 19\n 20\n\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28\n Stipulation to Continue 2\n Case Management Conference\n\f","ocr_status":2,"date_upload":"2024-02-29T09:49:39.928202-08:00","document_number":"33","attachment_number":null,"pacer_doc_id":"035023420428","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Stipulation","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/387573574/","id":387573574,"tags":[],"absolute_url":"/docket/66862637/33/1/nanolabs-inc-v-coinbase-global-inc/","date_created":"2024-02-29T09:36:06.033781-08:00","date_modified":"2024-03-01T03:30:24.079151-08:00","sha1":"f13ec7735dd35b79434e7965005d73a9a546eec1","page_count":1,"file_size":92814,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.33.1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.33.1.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 33-1 Filed 08/09/23 Page 1 of 1\n\n\n\n\n Michael L. Rodenbaugh (SBN 179059)\n 1\n Jonathan Frost (SBN 273189)\n 2 RODENBAUGH LAW\n 548 Market Street, Box 55819\n 3 San Francisco, CA 94104\n 4 Phone: (415) 738-8087\n\n 5 Attorneys for Plaintiff\n NANOLABS, INC.\n 6\n\n 7 IN THE UNITED STATES DISTRICT COURT\n FOR THE NORTHERN DISTRICT OF CALIFORNIA\n 8\n\n 9 Case No.: 3:23-cv-00844-JCS\n NANOLABS, INC.,\n 10\n\n 11 Plaintiff, DECLARATION OF MICHAEL\n RODENBAUGH, ESQ. IN SUPPORT OF\n 12 v. STIPULATION FOR ORDER\nNorthern District of California\n United States District Court\n\n\n\n\n CHANGING DATE OF CASE\n 13 COINBASE GLOBAL, INC., MANAGEMENT CONFERENCE\n 14\n Defendant.\n 15\n\n 16\n I, Michael Rodenbaugh, am an active member of this bar in good standing, and declare as\n 17 follows, pursuant to Local Rule 6-2.\n 18 I will be attending a pre-scheduled conference in Germany, which prevents me from\n\n 19 attending the CMC on October 27, 2023.\n Therefore, with the court\u2019s permission, the parties have stipulated to continue the Case\n 20\n Management Conference for one week, to November 2, 2023.\n 21\n There are no previous time modifications in the case, and this modification will not\n 22\n materially affect the case schedule.\n 23 Dated: August 9, 2023 Respectfully submitted,\n 24\n\n 25\n\n 26 Mike L. Rodenbaugh (SBN 179059)\n RODENBAUGH LAW\n 27\n\n 28 Attorneys for Plaintiff NANOLABS, INC.\n Declaration in Support of Stipulation 1\n\f","ocr_status":2,"date_upload":"2024-02-29T09:49:40.749606-08:00","document_number":"33","attachment_number":1,"pacer_doc_id":"035023420429","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Declaration of Michael Rodenbaugh","acms_document_guid":""}],"date_created":"2023-08-09T08:00:32.845563-07:00","date_modified":"2025-09-18T09:06:06.818140-07:00","date_filed":"2023-08-09","time_filed":"07:27:12","entry_number":33,"recap_sequence_number":"2023-08-09.001","pacer_sequence_number":94,"description":"STIPULATION WITH PROPOSED ORDER filed by Nanolabs, Inc.. (Attachments: # 1 Declaration of Michael Rodenbaugh)(Rodenbaugh, Michael) (Filed on 8/9/2023) (Entered: 08/09/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/360533705/","id":360533705,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/367144258/","id":367144258,"tags":[],"absolute_url":"/docket/66862637/32/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-02T13:33:58.452895-07:00","date_modified":"2025-09-18T09:06:06.797091-07:00","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":"32","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Clerk's Notice Setting Zoom Hearing.","acms_document_guid":""}],"date_created":"2023-08-02T13:33:58.444881-07:00","date_modified":"2025-09-18T09:06:06.769956-07:00","date_filed":"2023-08-02","time_filed":null,"entry_number":32,"recap_sequence_number":"2023-08-02.002","pacer_sequence_number":null,"description":"CLERKS NOTICE CONTINUING CASE MGMT CONFERENCE AND SETTING ZOOM HEARING. The parties have a mediation set for 10/18/2023. Therefore the Further Case Management Conference set for 10/6/2023 is continued to 10/27/2023 02:00 PM in San Francisco, - Videoconference Only. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/jcs General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. Case Management Statement due by 10/20/2023. (This is a text-only entry generated by the court. There is no document associated with this entry.) (klh, COURT STAFF) (Filed on 8/2/2023) (Entered: 08/02/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/360511785/","id":360511785,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/367121979/","id":367121979,"tags":[],"absolute_url":"/docket/66862637/31/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-02T11:27:13.326962-07:00","date_modified":"2025-09-18T09:06:06.747586-07:00","sha1":"c00b0bb5f10b619a7265b36bc0be1018bfe3132d","page_count":1,"file_size":160680,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.31.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.31.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 31 Filed 08/02/23 Page 1 of 1\n\n\n\n\n 1\n\n 2\n\n 3\n\n 4 UNITED STATES DISTRICT COURT\n\n 5 NORTHERN DISTRICT OF CALIFORNIA\n\n 6\n NANOLABS, INC.,\n 7 Case No. 23-cv-00844-JCS\n Plaintiff,\n 8\n v. ORDER RE MEDIATION\n 9\n COINBASE GLOBAL, INC., Re: Dkt. No. 30\n 10\n Defendant.\n 11\n\n 12\nNorthern District of California\n United States District Court\n\n\n\n\n 13 The court has received a joint letter dated July 28, 2023, stating that the parties intend to\n\n 14 mediate the matter before Judge Laporte, and contesting whether that mediation should be in\n\n 15 person or be held by zoom or other remote means. The issue of whether the mediation should be\n\n 16 remote or in person shall be resolved by Judge Laporte.\n\n 17 IT IS SO ORDERED.\n\n 18 Dated: August 2, 2023\n\n 19 ______________________________________\n JOSEPH C. SPERO\n 20 United States Magistrate Judge\n 21\n\n 22\n\n 23\n\n 24\n\n 25\n\n 26\n\n 27\n\n 28\n\f","ocr_status":2,"date_upload":"2024-02-29T09:49:15.346677-08:00","document_number":"31","attachment_number":null,"pacer_doc_id":"035023399505","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2023-08-02T11:27:13.319638-07:00","date_modified":"2025-09-18T09:06:06.726565-07:00","date_filed":"2023-08-02","time_filed":"10:38:37","entry_number":31,"recap_sequence_number":"2023-08-02.001","pacer_sequence_number":89,"description":"ORDER re 30 Letter on Mediation filed by Coinbase Global, Inc. Signed by Magistrate Judge Joseph C. Spero on 8/2/2023. (klh, COURT STAFF) (Filed on 8/2/2023) (Entered: 08/02/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/360511767/","id":360511767,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/367121961/","id":367121961,"tags":[],"absolute_url":"","date_created":"2023-08-02T11:27:12.447166-07:00","date_modified":"2023-08-03T18:01:33.267518-07:00","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":"","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Clerk's Notice Setting Zoom Hearing","acms_document_guid":""}],"date_created":"2023-08-02T11:27:12.443734-07:00","date_modified":"2023-08-03T18:01:33.257188-07:00","date_filed":"2023-08-02","time_filed":"10:47:17","entry_number":null,"recap_sequence_number":"2023-08-02.001","pacer_sequence_number":null,"description":"","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/360417048/","id":360417048,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/367024888/","id":367024888,"tags":[],"absolute_url":"/docket/66862637/30/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-08-01T12:59:13.796522-07:00","date_modified":"2025-09-18T09:06:06.704297-07:00","sha1":"f741f18bd639da9ea7ff4d30d90069deffbe7be2","page_count":1,"file_size":119969,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.30.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.30.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 30 Filed 08/01/23 Page 1 of 1\n\n\n\n\nJuly 28, 2023\n\nMagistrate Judge Joseph C. Spero\nUnited States District Court\nNorthern District of California\n\nVia email: jcspo@cand.uscourts.gov\n\nRe: Nanolabs, Inc. v. Coinbase Global, Inc., Case No. 3:23-cv-844-JCS\n\nDear Judge Spero,\n\nPursuant to the Court\u2019s minute order dated July 17, 2023 (Docket #29), the\nparties hereby jointly advise the Court that the parties have agreed to\nmediation conducted by Judge Elizabeth LaPorte, to be held October 18,\n2023. Defendant requested that the mediation be in person to maximize the\nopportunities for settlement. Plaintiff has refused because online mediation\nis now very common, provides additional benefits to the parties and\nmediator, and is statistically equally as successful in settling matters.\nMoreover, Plaintiff\u2019s principals live and work in London, UK, such that\ntravel to San Francisco for mediation would be unduly costly and\nburdensome.\n\nKind regards,\n\n\n\n Mike Rodenbaugh\n RODENBAUGH LAW\n\n\nBy:_____________________\n Gina Durham\n DLA PIPER LLP\n\n\n 548 Market Street, Box 55819, San Francisco, CA 94104\n Tel/Fax: +1 (415) 738-8087 Email: mike@rodenbaugh.com\n\f","ocr_status":2,"date_upload":"2024-02-29T09:48:55.237041-08:00","document_number":"30","attachment_number":null,"pacer_doc_id":"035023396276","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Letter","acms_document_guid":""}],"date_created":"2023-08-01T12:59:13.787698-07:00","date_modified":"2025-09-18T09:06:06.682163-07:00","date_filed":"2023-08-01","time_filed":"12:35:42","entry_number":30,"recap_sequence_number":"2023-08-01.001","pacer_sequence_number":87,"description":"Letter from Mike Rodenbaugh and Gina Durham to Magistrate Judge Joseph C. Spero. (Durham, Gina) (Filed on 8/1/2023) (Entered: 08/01/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/358939739/","id":358939739,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/365522392/","id":365522392,"tags":[],"absolute_url":"/docket/66862637/25/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-07-17T08:34:35.119975-07:00","date_modified":"2025-09-18T09:06:06.463146-07:00","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":"25","attachment_number":null,"pacer_doc_id":"","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Clerk's Notice Setting Zoom Hearing.","acms_document_guid":""}],"date_created":"2023-07-17T08:34:35.112269-07:00","date_modified":"2025-09-18T09:06:06.437379-07:00","date_filed":"2023-06-09","time_filed":null,"entry_number":25,"recap_sequence_number":"2023-06-09.002","pacer_sequence_number":null,"description":"CLERKS NOTICE CHANGING TIME AND SETTING ZOOM HEARING. Initial Case Management Conference set for 7/14/2023 at 9:30 AM will now be held at 02:00 PM PDT in San Francisco, - Videoconference Only. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/jcs Court Appearances: Advanced notice is required of counsel or parties who wish to be identified by the court as making an appearance or will be participating in the argument at the hearing. A list of names and emails must be sent to the CRD at jcscrd@cand.uscourts.gov no later than 7/12/2023 by 3:00 PM PDT.General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/. Case Management Statement due by 7/7/2023. (This is a text-only entry generated by the court. There is no document associated with this entry.) (klh, COURT STAFF) (Filed on 6/9/2023) (Entered: 06/09/2023)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/358937849/","id":358937849,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/66862637/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/365520440/","id":365520440,"tags":[],"absolute_url":"/docket/66862637/29/nanolabs-inc-v-coinbase-global-inc/","date_created":"2023-07-17T08:17:31.399357-07:00","date_modified":"2025-09-18T09:06:06.660402-07:00","sha1":"7b7bf3dfa03316a39e887fbe9cee39ddbe4f8bd1","page_count":1,"file_size":76289,"filepath_local":"recap/gov.uscourts.cand.408841/gov.uscourts.cand.408841.29.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.cand.408841/gov.uscourts.cand.408841.29.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":" Case 3:23-cv-00844-JCS Document 29 Filed 07/17/23 Page 1 of 1\n\n\n\n\n UNITED STATES DISTRICT COURT\n NORTHERN DISTRICT OF CALIFORNIA\n ZOOM CIVIL MINUTE ORDER\n\nCase No.: 23-cv-00844-JCS Case Name: Nanolabs, Inc. v. Coinbase Global, Inc.\nMagistrate Judge: JOSEPH C. Date: July 14, 2023 Time: 15 M (2:08-2:23)\nSPERO\n\nAttorney for Plaintiff: Michael Rodenbaugh\nAttorney for Defendant: Gina Durham, Kristina Fernandez Mabrie, Aislinn Smalling\n\nDeputy Clerk: Karen Hom Court Reporter: Not Reported\n\n ZOOM WEBINAR PROCEEDINGS\n\n1. Initial Case Mgmt Conference - Held\n\n ORDERED AFTER HEARING\n\nA joint letter shall be filed on 7/28/2023 identifying the method of mediation. If mediation is\nprivate, it should state the name of the mediator and the date of mediation.\n\nCourt adopted the dates in the joint case mgmt. conference statement, ECF 28, and clarified that\nthe dispositive motions deadline date is the filing date, not the hearing date. Final pretrial\nconference and trial date will be set later.\n\nUpdated joint case mgmt. conference statement due 9/29/2023.\n\nCASE CONTINUED TO: 10/6/2023 at 2:00 PM for a further case management conference\nby Zoom. Zoom Webinar ID 161 926 0804 Password: 050855. Please see Judge Spero\u2019s website\nfor additional Zoom information.\n\nPRETRIAL SCHEDULE:\nInitial Disclosures:\nNumber of Depos:\nLast day to seek leave of Court to amend pleadings: 11/10/2023\nDiscovery Cutoff: 12/22/2023\nExpert Disclosure: 1/19/2024\nExpert Rebuttal: 2/16/2024\nExpert Discovery Cutoff: 3/29/2024\nDeadline to File Dispositive Motions: 4/26/2024. To be filed on a seven (7) week track with\nthe reply brief to be due four (4) weeks before the scheduled hearing date.\nMotions Hearing & Daubert Motions: at 9:30 AM\nPretrial Conference: at 2:00 PM\nTrial: at 8:30 AM for days [ ] Jury [ ] Court\n\f","ocr_status":2,"date_upload":"2024-02-29T09:48:36.821551-08:00","document_number":"29","attachment_number":null,"pacer_doc_id":"035023342776","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Case Management Conference - Initial","acms_document_guid":""}],"date_created":"2023-07-17T08:17:31.389778-07:00","date_modified":"2025-09-18T09:06:06.637673-07:00","date_filed":"2023-07-17","time_filed":"07:57:20","entry_number":29,"recap_sequence_number":"2023-07-17.001","pacer_sequence_number":83,"description":"Minute Entry for ZOOM proceedings held before Magistrate Judge Joseph C. Spero: Initial Case Management Conference held on 7/14/2023. Further Case Management Conference set for 10/6/2023 02:00 PM in San Francisco, - Videoconference Only. This proceeding will be held via a Zoom webinar.Webinar Access: All counsel, members of the public, and media may access the webinar information at https://www.cand.uscourts.gov/jcs General Order 58. Persons granted access to court proceedings held by telephone or videoconference are reminded that photographing, recording, and rebroadcasting of court proceedings, including screenshots or other visual copying of a hearing, is absolutely prohibited.Zoom Guidance and Setup: https://www.cand.uscourts.gov/zoom/.Joint letter on method of mediation due: 7/28/2023. Case Management Statement due by 9/29/2023.Last day to seek leave of Court to Amended Pleadings due by 11/10/2023. Close of Fact Discovery due by 12/22/2023.Designation of Experts due by 1/19/2024. Rebuttal Reports due by 2/16/2024. Close of Expert Discovery due by 3/29/2024. Dispositive Motion due by 4/26/2024. To be filed on a seven (7) week track with the reply brief to be due four (4) weeks before the scheduled hearing date. Digital Recording Time: Not Reported. Attorney for Plaintiff: Michael Rodenbaugh.Attorney for Defendant: Gina Durham, Kristina Fernandez Mabrie, Aislinn Smalling.(klh, COURT STAFF) (Date Filed: 7/17/2023) (Entered: 07/17/2023)","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=66862637&page_size=40"}