Opinion
CV-21-01700-PHX-SPL
01-11-2023
Scott Chaverri, et al., Plaintiffs, v. Platinum LED Lights LLC, et al., Defendants. Date Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis Basis
ORDER
HONORABLE STEVEN P. LOGAN, DISTRICT JUDGE
On December 6, 2022, the parties filed the pending Joint Motion for Discovery Dispute Resolution (Doc. 69), arising from Defendants' refusal to produce certain documents absent an agreement to protect their confidentiality. On December 9, 2022, the Court ordered the parties to meet and confer in an effort to propose a protective order, specifically limited to the documents at issue, that would resolve the discovery dispute. On December 30, 2022, the parties filed the pending Joint Motion for Protective Order (Doc. 72), which designates eight documents containing third-party consumer information as Confidential and 129 documents containing trade secrets and propriety information as Attorneys' Eyes Only. Finding the proposed protective order to be sufficiently narrow and in compliance with Federal Rule of Civil Procedure 26(c), and finding good cause for its entry, IT IS ORDERED that the Joint Motion for Discovery Dispute Resolution (Doc. 69) is denied as moot.
IT IS FURTHER ORDERED that the Joint Motion for Protective Order (Doc. 72) is granted. The Court enters the following Protective Order:
1. PURPOSES AND LIMITATIONS
1.1. This Stipulated Protective Order (the “Order”) shall apply to the above-captioned action (the “Litigation”). Disclosure and discovery activity in the Litigation may involve production of confidential or non-public proprietary business information or sensitive personal information not generally known to third parties for which special protection from public disclosure and from use for any purpose other than prosecuting this Litigation may be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to enter the following Order. This Protective Order does not, by itself, authorize filing any document under seal. Any party wishing to file Confidential Information in connection with a motion, brief, or other submission to the Court must comply with Fed.R.Civ.P. 26(c) and LRCiv 5.6.
1.2. This Order shall apply to all currently named and later joined or added parties in this action that receive a copy of this Order from any party or third party to this Litigation.
2. DEFINITIONS
2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.
2.2 “CONFIDENTIAL” Information or Items: the information or tangible things designated as “CONFIDENTIAL” as set forth in Appendix A-1 and supplements thereto approved by the Court.
2.3 Counsel: attorneys representing a named Party in this Litigation, including all support staff working under the supervision of such Counsel.
2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY.
2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.
2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the Litigation who (1) has been retained by a Party or its Counsel to serve as an expert witness or as a non-testifying consultant in this Litigation; (2) who is not currently employed by a Party or a Party's competitor; (3) who is not a past or current employee, partner, agent, shareholder, member, officer, contractor, client, or attorney of a Party or of a Party's competitor; and (4) at the time of retention, other than for purposes of being retained as an Expert in the Litigation, is not anticipated to become an employee partner, agent, shareholder, member, officer, contractor, client, or attorney of a Party or of a Party's competitor.
2.7 “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information or Items: extremely sensitive Confidential Information or Items for attorneys' eyes only as set forth in Appendix A-1 supplements thereto approved by the Court.
2.7 Non-Party: any natural person, partnership, corporation, association, court, or governmental agency or administrative body, or other legal entity not named as a Party to this action.
2.8 Party or Parties: any party to this Litigation, including all of its officers, directors, employees, consultants, retained experts, and Counsel (and their respective support staff).
2.9 PII: third-party consumer personal information.
2.10 Producing Party: a Party or Non-Party that produces Protected Material in this action.
2.11 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.
2.12 Protected Material: any information or tangible things designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” hereunder.
2.13 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.
3. SCOPE
3.1. The protections conferred by this Order cover not only Protected Material, but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material.
3.2. The protections conferred by this Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial, Court Order, or otherwise; and (b) any information known to the Receiving Party prior to the disclosure and not subject to any obligation of confidentiality, or obtained by the Receiving Party after the disclosure from a source who obtained the information lawfully and under no obligation of confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by this Order, in addition to any applicable separate orders.
4. DURATION
Even after final disposition of this Litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this action, with or without prejudice; or (2) final judgment herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any motions or applications for extension of time pursuant to applicable law.
5. DESIGNATING PROTECTED MATERIAL
5.1 Exercise of Restraint and Care in Designating Material for Protection.
Any information produced in this Litigation that is reasonably believed in good faith by the Producing Party to be confidential may be designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS EYES ONLY.”
The Parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the terms of this Order and applicable legal principles.
Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. To the extent it is practical to do so, the Designating Party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify, so that other portions of the material, documents, items, or oral or written communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or retard the case development process or to impose unnecessary expenses and burdens on other Parties) shall expose the Designating Party to sanctions.
If it comes to a Designating Party's attention that information or items that it designated for protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, that Designating Party must promptly notify all other Parties that it is withdrawing the mistaken designation.
5.2 Manner and Timing of Designations. Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic documents, but excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL -ATTORNEYS' EYES ONLY” to each page that contains Protected Material. If only a portion or portions of the material on a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings in the margins) and must specify, for each portion, the level of protection being asserted. If the Producing Party designates any portion or portions of material on a page “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY,” the designated portion or portions of the material must be redacted, and the remaining portion or portions of the material must be produced.
(b) for testimony given in deposition or in other pretrial or trial proceedings, that the Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, all protected testimony and specify the level of protection being asserted. When it is impractical to identify separately each portion of testimony that is entitled to protection and it appears that substantial portions of the testimony may qualify for protection, the Designating Party may invoke on the record (before the deposition, hearing, or other proceeding is concluded) a right to have up to 10 days after receipt of the transcript of the pertinent testimony, to identify the specific portions of the testimony as to which protection is sought and to specify the level of protection being asserted. Only those portions of the testimony that are appropriately designated for protection within the 10 days shall be covered by the provisions of this Order.
Parties shall give the other Parties notice if they reasonably expect a deposition, hearing, or other proceeding to include Protected Material so that the other Parties can ensure that only authorized individuals who have signed the “Acknowledgment and Agreement to Be Bound” (Appendix A) are present at those proceedings. The use of a document as an exhibit at a deposition shall not in any way affect its designation as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY.”
Transcripts containing Protected Material shall have an obvious legend on the title page that the transcript contains Protected Material, and the title page shall be followed by a list of all pages (including line numbers as appropriate) that have been designated as Protected Material and the level of protection being asserted by the Designating Party. The Designating Party shall inform the court reporter of these requirements prior to the taking of the deposition.
(c) for information produced in some form other than documentary and for any other tangible items, that the Producing Party affix in a prominent place on the exterior of the container or containers in which the information or item is stored the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY.” If only a portion or portions of the information or item warrant protection, the Producing Party, to the extent practicable, shall identify the protected portion(s) and specify the level of protection being asserted.
6. CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of confidentiality at any time. Unless a prompt challenge to a Designating Party's confidentiality designation is necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant disruption or delay of the litigation, a Party does not waive its right to challenge a confidentiality designation by electing not to mount a challenge promptly after the original designation is disclosed.
6.2 Conference. The Challenging Party shall initiate the dispute resolution process by providing written notice of each designation it is challenging to Counsel of record for all Parties and counsel of record for all affected Non-Parties, if any, and briefly describe the basis for each challenge to the Designating Party. To avoid ambiguity as to whether a challenge has been made, the written notice must recite that the challenge to confidentiality is being made in accordance with this specific paragraph of the Order. The Parties shall attempt to resolve each challenge in good faith by conferring by via telephone or written correspondence, including email, within 10 calendar days of the date of service of notice. In conferring, the Designating Party must explain the basis for its belief that the confidentiality designation was proper or agree to de-designate the material. If the Parties cannot reach an agreement regarding some or all of the challenged designations, the Designating Party shall have the burden of seeking judicial intervention within 14 calendar days from the date the Challenging Party notifies the Designating Party that the challenge was not resolved through conferring.
6.3 Judicial Intervention; Failure to Obtain. If the Designating Party fails to timely seek judicial Intervention within the above-referenced 14 calendar days pursuant to Rule 26(c) or other applicable law, the challenged designation shall automatically be withdrawn. If the Designating Party timely seeks judicial intervention, the designated material shall be treated according to the applicable designation and pursuant to the terms set forth herein.
The burden of persuasion in any such challenge proceeding shall be on the Designating Party. Frivolous challenges and those made for an improper purpose (e.g., to harass or impose unnecessary expenses and burdens on other Parties) may expose the Challenging Party to sanctions.
7. ACCESS TO AND USE OF PROTECTED MATERIAL
7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or produced by another Party or by a Non-Party in connection with this Litigation only for prosecuting, defending, or attempting to settle this Litigation. When this Litigation has been terminated, a Receiving Party must comply with the provisions of Section 13 below (FINAL DISPOSITION).
Protected Material must be stored and maintained by a Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order.
7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated “CONFIDENTIAL” only to:
(a) the Receiving Party's Counsel;
(b) the Parties, and the officers, directors, and employees of the Receiving Party to whom disclosure is reasonably necessary for this Litigation;
(c) Experts and consultants of the Receiving Party to whom disclosure is reasonably necessary for this Litigation and have executed the Acknowledgment attached as Appendix B;
(d) the Court and its personnel;
(e) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to whom disclosure is reasonably necessary for this Litigation;
(f) during their depositions or in preparation for their depositions, witnesses in the Litigation who are current or former employees of any Party that produced the applicable document(s), or who appear based on the document itself or testimony in a deposition, to have knowledge of the contents of the Protected Material designated “CONFIDENTIAL” or the specific events, transactions, discussion, or date reflected in the document, provided such witness executes the Acknowledgment attached as Appendix B;
(g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information prior to its production in this Litigation;
(h) any private mediators utilized in the Litigation, provided such person executes the Acknowledgment attached as Appendix B; and,
(i) such other persons as hereafter may be designated by written agreement of all Parties in this Litigation or by Order of the Court, such Order obtained on noticed motion (or on shortened time as the Court may allow), permitting such disclosure.
7.3 Disclosure of “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information or Items. Unless otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or item designated “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” only to:
(a) the Receiving Party's Counsel in this action, as well as employees of said Counsel to whom it is reasonably necessary to disclose the information for this Litigation;
(b) Experts and consultants of the Receiving Party to whom disclosure is reasonably necessary for this Litigation and have executed the Acknowledgment attached as Appendix B;
(c) the Court and its personnel;
(d) court reporters and their staff, professional jury or trial consultants, and Professional Vendors to whom disclosure is reasonably necessary for this Litigation and have executed the Acknowledgment attached as Appendix B; and
(e) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information prior to its production in this Litigation;
(f) any private mediators utilized in the Litigation, provided such person executes the Acknowledgment attached as Appendix B ; and,
(g) such other persons as hereafter may be designated by written agreement of all Parties in this Litigation or by Order of the Court, such Order obtained on noticed motion (or on shortened time as the Court may allow), permitting such disclosure.
8. A NON-PARTY'S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION
8.1 The terms of this Order are applicable to information produced by a NonParty in this action for such documents approved by the Court.
Such information produced by Non-Parties in connection with this Litigation is protected by the remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibiting a Non-Party from seeking additional protections.
9. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL
If information is produced in discovery, including information produced by a third party, that is claimed to be Protected Material or otherwise privileged, the Party making the claim may notify any Receiving Party that received the information of the claim and the basis for it. After being notified, the Receiving Party must promptly return or destroy the specified information and any copies it has and may not sequester, use, or disclose the information until the claim is resolved. This includes a restriction against presenting the information to the Court for a determination of the claim. This provision is not intended to modify whatever procedure may be established in an e-discovery order that provides for production without prior privilege review.
10. MISCELLANEOUS
10.1 Right to Further Relief. Nothing in this Order abridges the right of any Party to seek its modification by the Court in the future.
10.2 Right to Assert Other Objections. By stipulating to the entry of this Order no Party waives any right it otherwise would have to object to disclosing or producing any information or item on any ground, including relevance, not addressed in this Order. Similarly, no Party waives any right to object on any ground to use in evidence of any of the material covered by this Order.
10.3 Filing Protected Material. In the event that any “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY INFORMATION” is included with, or the contents thereof are in any way disclosed in any pleading, motion, disposition, transcript, or other paper filed with the Clerk of this Court, the Party filing the Protected Material shall request sealing of the information.
As further clarification, a mere reference or discussion of “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information does not warrant sealing of the entire document and all attachments to be filed. Instead, the Party who is contemplating sealing any item should redact or request sealing of only the very specific portions of documents that contain or refer to the “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information. Then, the Party may elect to file the motion to seal the Protected Material or a notice to the Court that a motion to seal may be filed in the future, when and if it is necessary to do so.
The Parties shall give the other Parties notice if they reasonably expect that a Motion, Opposition, or other document to be filed with the Court will include an Exhibit containing Protected Material so that the Parties may meet and confer as provided by Paragraph 6.2 prior to the need to file the Protected Material. In the event that it is impossible to provide such notice, the Parties agree that the Party seeking to file Protected Material will abide by the provisions of this Paragraph.
Notwithstanding the foregoing, “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information, documents, or testimony introduced into evidence at trial may not be sealed or otherwise treated as confidential by the Court except pursuant to a further order of the Court at the request of either Party during pretrial proceedings or trial.
10.4. Party's Own Information. A Party is free to do whatever it desires with its own “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information.
10.5. Non-Party Subpoenas and Orders. In the event any Party is required by subpoena or court order to produce Protected Material to any person or entity not subject to this Protective Order (e.g., a Non-Party), the Party so required shall give notice of such court order or subpoena to all other Parties at least twenty (20) calendar days before making such production, so that the other Parties may have an opportunity to intervene and/or seek a protective order. If no motion for protective order and/or motion to quash is filed within the twenty-day period, the Party may comply with the subpoena or court order but must notify the requesting party of this Protective Order. If a motion for protective order and/or motion to quash is filed within the twenty-day period, the Party shall refrain from producing any Protected Material until ordered by the court.
10.6. Court's Jurisdiction. The Court retains jurisdiction to make such amendments, modifications, deletions, and additions to this Order as the Court may from time to time deem appropriate. The provisions of this Order regarding the use or disclosure of “CONFIDENTIAL” and “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information shall survive the termination of this Litigation to the extent the “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information is not or does not become known to the public in accordance with the terms set forth herein, and the Court shall retain jurisdiction with respect to this Order.
10.7. Effective Date. Upon the signing of this Order by the Court this Order shall be effective as against all Parties currently named, or later joined or added in this Litigation. Plaintiffs must serve a copy of this Order on each party added to the Litigation after the date of this Order.
11. FINAL DISPOSITION
Within 60 days after the final disposition of this Litigation, each Receiving Party must return all Protected Material to the Producing Party or destroy such material. As used in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and any other format reproducing or capturing any of the Protected Material. Whether the Protected Material is returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and, if not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by category, where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and consultant and expert work product, even if such materials contain Protected Material. Any such archival copies that contain or constitute Protected Material remain subject to this Order.
APPENDIX A
1. The following documents shall be deemed “Confidential” hereunder:
Document Title
Date
Bate Stamp
Doc Type
From
To
Basis
1
FW_BIOMAX 900 ORDER
10- Aug-22
CONFIDPLAT0000583- CONFIDPLAT0000587
Mark Sawyer
Tom Johnson
PII
2
FW_New customer message on October 3,2019 at 7 48 pm
4- Oct- 19
CONFIDPLAT0000593- CONFIDPLAT0000595
Mark Sawyer
Alex Fergus
PII
3
Irradiance Peak
27-Jan- 20
CONFIDPLAT0000596- CONFIDPLAT0000598
Tom Johnson
Mark Sawyer
PII
4
Katia Grinkov change
22-Aug- 22
CONFIDPLAT0000599- CONFIDPLAT0000605
Mark Sawyer
Susie Kristofka
PII
5
Lester Sawicki left a 5 star review for 'PlatinumLED.. .BIOMAX Series'
11- Sep-19
CONFIDPLAT0000606
Judge.me
Mark Sawyer
PII
6
New BIOMAX
13- Aug-22
CONFIDPLAT0000617- CONFIDPLAT0000618
Mark Sawyer
Alex Fergus
PII
Document Title
Date
Bate Stamp
Doc Type
From
To
Basis
7
AEO Re_FW_Question from Katia using Platinum Therapy.. .hts chat box.2
14- Aug-22
AEOPLAT0000805- AEOPLAT0000810
Mike Volkin
Mark Sawyer
PII
8
AEO Re_FW_Question from Katia using Platinum Therapy.. .hts chat box..
14- Aug-22
AEOPLAT0000811- AEOPLAT0000815
Mark Sawyer
Mike Volkin
PII
2. The following documents shall be deemed “Highly Confidential - Attorneys' Eyes Only” hereunder:
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
1
Platinum LED Lights, LLC Balance Sheet and Income Statement 2018
TO BE BATES
Young & Company LLC
Proprietary Financial Data
2
Platinum LED Lights, LLC Balance Sheet and Income Statement 2019
TO BE BATES
Young & Company LLC
Proprietary Financial Data
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
3
Platinum LED Lights, LLC Balance Sheet and Income Statement 2020
TO BE BATES
Young & Company LLC
Proprietary Financial Data
4
Platinum LED Lights, LLC Balance Sheet and Income Statement 2021
TO BE BATES
Young & Company LLC
Proprietary Financial Data
5
Platinum LED Lights, LLC Balance Sheet and Income Statement 2022
To be Produced Once Finalized
Proprietary Financial Data
6
Sales over time 1.20.8.22
TO BE BATES
Print Out
Mark Sawyer
Proprietary Sales Data
7
sales_2018-06-05_2022-06-05
TO BE BATES
Excel
Mark Sawyer
Proprietary Sales Data
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
8
Re-Platinum Led Therapy Lights VideoReport #001 (163)
4-Aug- 20
AEOPLAT0001013 - AEOPLAT0001015
Fabiano Valmorbi da Marcal Pessoa
Mark Sawyer
Competitive Analysis
9
Re-Platinum Led Therapy Lights VideoReport #001 (164)
3-Aug- 20
AEOPLAT0001016 - AEOPLAT0001017
Mark Sawyer
Fabiano Valmorbi da Marcal Pessoa; Mike Volkin
Competitive Analysis
10
RE-Platinum Therapy
26-Jul- 22
AEOPLAT0001047 - AEOPLAT0001053
Shubham Sagare
Mark Sawyer
Competitive Analysis
11
RE-Platinum Therapy (3)
26-Jul- 22
AEOPLAT0001022 - AEOPLAT0001026
Mark Sawyer
Shubham Sagare; Mike Volkin
Competitive Analysis
12
RE-Platinum Therapy (4)
26-Jul- 22
AEOPLAT0001027 - AEOPLAT0001031
Shubham Sagare
Mark Sawyer; Mike Volkin
Competitive Analysis
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
13
RE-Platinum Therapy (5)
25-Jul- 22
AEOPLAT0001032 - AEOPLAT0001035
Mark Sawyer
Shubham Sagare; Mike Volkin
Competitive Analysis
14
RE-Platinum Therapy (6)
25-Jul- 22
AEOPLAT0001036 - AEOPLAT0001038
Shubham Sagare
Mike Volkin
Competitive Analysis
15
RE-Platinum Therapy (7)
22-Jul- 22
AEOPLAT0001039 - AEOPLAT0001041
Shubham Sagare
Mike Volkin
Competitive Analysis
16
RE-Platinum Therapy (8)
22-Jul- 22
AEOPLAT0001042 - AEOPLAT0001044
Mark Sawyer
Mike Volkin; Shubham Sagare
Competitive Analysis
17
RE-Platinum Therapy (9)
22-Jul- 22
AEOPLAT0001045 - AEOPLAT0001046
Mike Volkin
Shubham Sagare
Competitive Analysis
18
Re- PlatinumLED SEO report
1 -Aug- 22
AEOPLAT0001212 - AEOPLAT0001215
Rifat Ahmed
Mark Sawyer
Competitive Analysis
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
19
AEO Ad Campaign Question
25-Feb- 20
AEOPLAT0000700
Rachel Callahan
Mark Sawyer
Discussion of Ad Budget
20
AEO FW_Platinum LED SEO report
2-Aug- 22
AEOPLAT0000723 - AEOPLAT0000726
Mark Sawyer
Soumik Chowdhur y
Discussion of SEO Strategy
21
AEO Fwd_Platinum LED SEO report 2
2-Aug- 22
AEOPLAT0000730 - AEOPLAT0000733
Rifat Ahmed
Mark Sawyer
Discussion of SEO Strategy
22
AEO Fwd Update
19-Jan- 21
AEOPLAT0000736
Mike Volkin
Mark Sawyer
Corresponden ce re website strategy
23
AEO MR1
25-Feb- 20
AEOPLAT0000747
Rachel Callahan
Mark Sawyer
Ad Budget
24
AEO PlatinumLED SEO report
1 -Aug- 22
AEOPLAT0000748
Mark Sawyer
Rifat Ahmed
SEO Audit
25
aeo PlatinumLED Therapy Lights - SEO (1) (002)
N/A
AEOPLAT0000749 - AEOPLAT0000764
Analysis document
N/A
N/A
SEO Audit
26
AEO PTL comparison 2
N/A
AEOPLAT0000765 - AEOPLAT0000768
Web data
Semrush
N/A
Web Traffic Analysis of Platinum and Competitors
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
27
AEO PTL comparison SEM Rush
N/A
AEOPLAT0000769 - AEOPLAT0000772
Web data
Semrush
N/A
Web Traffic Analysis of Platinum and Competitors
28
AEO RE_Ad Campaign Question 2
25-Feb- 20
AEOPLAT0000773 - AEOPLAT0000774
Mark Sawyer
Rachel Callahan
Discussion of Ad Budget
29
AEO RE_Ad Campaign Question 3
26-Feb- 20
AEOPLAT0000775 - AEOPLAT0000776
Rachel Callahan
Mike Volkin
Discussion of Ad Budget
30
AEO Re_Auction insight 6 29
30-Jun- 20
AEOPLAT0000777 - AEOPLAT0000778
Support -IWDM
Mark Sawyer
Discussion of Impression Share vis a vis competitors
31
AEO Re_Ecommerc e Audit
1 -Aug- 22
AEOPLAT0000779 - AEOPLAT0000795
Kunal Patil
Soumik Chowdhur y
SEO Audit
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
32
8-Oct- 21 AEO Re_FW_allega tion against the firm Platinum LED Holdings LLC
AEOPLAT0000796 - AEOPLAT0000802
Mike Volkin
Mark Sawyer
Response to Medical Device Marketing Complaint to FDA
33
aeo Re
7-Apr- 21
AEOPLAT0000853 - AEOPLAT0000854
Mike Volkin
Tom Johnson
SEO and Mito Red Video
34
CPC Screen Shot
N/A
AEOPLAT0000855
Screensh ot
N/A
N/A
Ad CPC Analysis
35
FW- PlatinumLED SEO report
2-Aug- 22
AEOPLAT0000860 - AEOPLAT0000862
Mark Sawyer
Soumik Chowdhur y
SEO Report
36
Re-3w vs 5w (160)
6-Sep- 20
AEOPLAT0000891 - AEOPLAT0000897
Mark Sawyer
Josh Piepmeier; Tom Johnson
SEO Audit
37
Re-Seller Rating (97)
3-Dec- 20
AEOPLAT0001444 - AEOPLAT0001447
Mark Sawyer
Mike Volkin; Support-IWDM
Discussion of Mito Red and Website Strategy
38
Re-Seller Rating (106)
19- Nov-20
AEOPLAT0001435 - AEOPLAT0001438
Mike Volkin
Support-IWDM
Discussion of Mito Red and Website Strategy
39
Re-Seller Rating (107)
19- Nov-20
AEOPLAT0001439 - AEOPLAT0001441
Support -IWDM
Mark Sawyer
Discussion of Mito Red and Website Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
40
Re-Seller Rating (109)
19- Nov-20
AEOPLAT0001442 - AEOPLAT0001443
Mark Sawyer
Mike Volkin; Support-IWDM
Discussion of Mito Red and Website Strategy
41
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (190)
11-Sep- 19
AEOPLAT0001450 - AEOPLAT0001486
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
42
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (191)
11-Sep- 19
AEOPLAT0001487 - AEOPLAT0001513
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
43
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (192)
11-Sep- 19
AEOPLAT0001514 - AEOPLAT0001540
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
44
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (199)
9-Sep- 19
AEOPLAT0001541 - AEOPLAT0001579
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
45
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (200)
9-Sep- 19
AEOPLAT0001580 - AEOPLAT0001608
Mark Sawyer
Rachael Piper
SEO Analysis / Strategy
46
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (201)
9-Sep- 19
AEOPLAT0001609 - AEOPLAT0001645
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
47
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (202)
9-Sep- 19
AEOPLAT0001646 - AEOPLAT0001672
Mark Sawyer
Rachael Piper
SEO Analysis / Strategy
48
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (203)
9-Sep- 19
AEOPLAT0001673 - AEOPLAT0001703
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
49
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (204)
9-Sep- 19
AEOPLAT0001704 - AEOPLAT0001742
Jake Pearson
Rachael Piper
SEO Analysis / Strategy
50
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (205)
9-Sep- 19
AEOPLAT0001743 - AEOPLAT0001780
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
51
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (206)
9-Sep- 19
AEOPLAT0001781 - AEOPLAT0001808
Mark Sawyer
Rachael Piper
SEO Analysis / Strategy
52
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (207)
9-Sep- 19
AEOPLAT0001809 - AEOPLAT0001844
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
53
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (208)
9-Sep- 19
AEOPLAT0001845 - AEOPLAT0001880
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
54
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (209)
9-Sep- 19
AEOPLAT0001881 - AEOPLAT0001907
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
55
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (211)
6-Sep- 19
AEOPLAT0001908 - AEOPLAT0001933
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
56
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (212)
3-Sep- 19
AEOPLAT0001934 - AEOPLAT0001966
Jake Pearson
Rachael Piper
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
57
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (213)
20- Aug-19
AEOPLAT0001967 - AEOPLAT0001999
Jake Pearson
Rachael Piper
SEO Analysis / Strategy
58
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (214)
20- Aug-19
AEOPLAT0002000 - AEOPLAT0002031
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
59
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (215)
20- Aug-19
AEOPLAT0002032 - AEOPLAT0002054
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
60
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (216)
20- Aug-19
AEOPLAT0002055 - AEOPLAT0002084
Rachael Piper
Jake Pearson
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
61
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (217)
20- Aug-19
AEOPLAT0002085 - AEOPLAT0002113
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
62
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (218)
20- Aug-19
AEOPLAT0002114 - AEOPLAT0002134
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
63
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (219)
16- Aug-19
AEOPLAT0002135 - AEOPLAT0002154
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
64
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (220)
16- Aug-19
AEOPLAT0002155 - AEOPLAT0002181
Jake Pearson
Rachael Piper
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
65
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (221)
16- Aug-19
AEOPLAT0002182 - AEOPLAT0002208
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
66
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (222)
15- Aug-19
AEOPLAT0002209 - AEOPLAT0002226
Mark Sawyer
Jake Pearson
SEO Analysis / Strategy
67
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (223)
15- Aug-19
AEOPLAT0002227 - AEOPLAT0002251
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
68
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (224)
15- Aug-19
AEOPLAT0002252 - AEOPLAT0002268
Mark Sawyer
Jake Pearson; Rachael Piper
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
69
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (225)
14- Aug-19
AEOPLAT0002269 - AEOPLAT0002291
Rachael Piper
Jake Pearson
SEO Analysis / Strategy
70
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (226)
14- Aug-19
AEOPLAT0002292 - AEOPLAT0002313
Jake Pearson
Rachael Piper
SEO Analysis / Strategy
71
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (227)
13- Aug-19
AEOPLAT0002314 - AEOPLAT0002334
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
72
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (228)
13- Aug-19
AEOPLAT0002335 - AEOPLAT0002348
Mark Sawyer
Rachael Piper
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
73
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (229)
13- Aug-19
AEOPLAT0002349 - AEOPLAT0002368
Rachael Piper
Mark Sawyer
SEO Analysis / Strategy
74
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (233)
8-Aug- 19
AEOPLAT0002369 - AEOPLAT0002382
Mark Sawyer
Jake Pearson
SEO Analysis / Strategy
75
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (234)
8-Aug- 19
AEOPLAT0002383 - AEOPLAT0002401
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
76
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (235)
8-Aug- 19
AEOPLAT0002402 - AEOPLAT0002414
Mark Sawyer
Jake Pearson
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
77
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (236)
8-Aug- 19
AEOPLAT0002415 - AEOPLAT0002432
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
78
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (237)
6-Aug- 19
AEOPLAT0002433 - AEOPLAT0002444
Mark Sawyer
Jake Pearson
SEO Analysis / Strategy
79
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (238)
6-Aug- 19
AEOPLAT0002445 - AEOPLAT0002461
Jake Pearson
Mark Sawyer
SEO Analysis / Strategy
80
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (239)
5-Aug- 19
AEOPLAT0002462 - AEOPLAT0002478
Michael Shipley
Mark Sawyer
SEO Analysis / Strategy
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
81
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (240)
2-Aug- 19
AEOPLAT0002479 - AEOPLAT0002490
Mark Sawyer
Jake Pearson; Michael Shipley; Rachael Piper
SEO Analysis / Strategy
82
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights (241)
2-Aug- 19
AEOPLAT0002491 - AEOPLAT0002506
Michael Shipley
Jake Pearson; Mark Sawyer; Rachael Piper
SEO Analysis / Strategy
83
Re-SEO_SEM Proposal--PlatinumLED Therapy Lights
12-Sep- 19
AEOPLAT0002507 - AEOPLAT0002543
Rachael Piper
Jake Pearson
SEO Analysis / Strategy
84
RE-SEO
22- Apr-20
AEOPLAT0001448 - AEOPLAT0001449
Mike Volkin
Mark Sawyer
SEO Analysis / Strategy
85
AEO adffiliate update
3-Sep- 21
AEOPLAT0000701
Mike Volkin
Mark Sawyer
Status of Affiliate Marketing Program
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
86
AEO FW [URGEN T] Re_[affiliatly] Your registration for affiliate program
24-Sep- 19
AEOPLAT0000708 - AEOPLAT0000718
Mark Sawyer
Juntae DeLane
Affiliate Commission Negotiations
87
AEO mark update
N/A
AEOPLAT0000743 - AEOPLAT0000744
Word doc
N/A
N/A
Affiliate Strategy
88
RE-No word from Mark again (ALEX FERGUS) (171)
10- Dec-19
AEOPLAT0000987 - AEOPLAT0000991
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
89
RE-No word from Mark again (ALEX FERGUS) (172)
9-Dec- 19
AEOPLAT0000992 - AEOPLAT0000997
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
90
RE-No word from Mark again (ALEX FERGUS)
10- Dec-19
AEOPLAT0000998 - AEOPLAT0001005
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
91
RE-Order from Sept that needs to be fulfilled #11945 Tatiana Teppoeva
14-Oct- 20
AEOPLAT0001006 - AEOPLAT0001012
Susie Kristofka
Mark Sawyer; Tom Johnson
Affiliate Commission Negotiations
92
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (230)
13- Aug-19
AEOPLAT0002591 - AEOPLAT0002611
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
93
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (231)
9-Aug- 19
AEOPLAT0002612 - AEOPLAT0002626
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
94
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (258)
23-Jul- 19
AEOPLAT0002627 - AEOPLAT0002644
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
95
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (260)
22-Jul- 19
ACPPLAT0002645- ACPPLAT0002658
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
96
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (261)
12-Jul- 19
ACPPLAT0002659- ACPPLAT0002672
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
97
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (265)
9-Jul- 19
ACPPLAT0002673- ACPPLAT0002689
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
98
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (266)
8-Jul- 19
ACPPLAT0002690- ACPPLAT0002701
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
99
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (267)
8-Jul- 19
ACPPLAT0002702- ACPPLAT0002715
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
100
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (268)
26-Jun- 19
ACPPLAT0002716- ACPPLAT0002729
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
101
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (269)
19-Jun- 19
ACPPLAT0002730- ACPPLAT0002740
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
102
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (270)
10-Jun- 19
ACPPLAT0002741- ACPPLAT0002750
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
103
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (271)
10-Jun- 19
ACPPLAT0002751- ACPPLAT0002762
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
104
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (272)
10-Jun- 19
ACPPLAT0002763- ACPPLAT0002772
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
105
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (273)
10-Jun- 19
ACPPLAT0002773- ACPPLAT0002782
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
106
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (274)
10-Jun- 19
ACPPLAT0002783- ACPPLAT0002793
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
107
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX (275)
7-Jun- 19
ACPPLAT0002794- ACPPLAT0002802
Mark Sawyer
Alex Fergus
Affiliate Commission Negotiations
108
Re-We're taking Red Light Therapy to the next level-Meet BIOMAX
31- Aug-19
ACPPLAT0002803- ACPPLAT0002823
Alex Fergus
Mark Sawyer
Affiliate Commission Negotiations
109
RE-RE Curved case (133)
23-Sep- 20
AEOPLAT0001216 - AEOPLAT0001226
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
110
RE-RE Curved case (134)
23-Sep- 20
AEOPLAT0001227 - AEOPLAT0001237
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
111
RE-RE Curved case (137)
19-Sep- 20
AEOPLAT0001238 - AEOPLAT0001245
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
112
RE-RE Curved case (139)
18-Sep- 20
AEOPLAT0001246 - AEOPLAT0001253
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
113
RE-RE Curved case (141)
15-Sep- 20
AEOPLAT0001254 - AEOPLAT0001263
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
114
RE-RE Curved case (147)
10-Sep- 20
AEOPLAT0001264 - AEOPLAT0001272
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
115
RE-RE Curved case (148)
10-Sep- 20
AEOPLAT0001273 - AEOPLAT0001283
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
116
RE-RE Curved case (149)
10-Sep- 20
AEOPLAT0001284 - AEOPLAT0001294
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
117
RE-RE Curved case (150)
10-Sep- 20
AEOPLAT0001295 - AEOPLAT0001305
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
118
RE-RE Curved case
25-Sep- 20
AEOPLAT0001306 - AEOPLAT0001316
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
119
RE-RE-LEDs in PRO
13- Aug-20
AEOPLAT0001317 - AEOPLAT0001329
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
120
RE-RE-RE Curved case (146)
10-Sep- 20
AEOPLAT0001330 - AEOPLAT0001339
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
121
RE-RE-RE Curved case (152)
10-Sep- 20
AEOPLAT0001340 - AEOPLAT0001347
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
122
RE-RE-RE Curved case (153)
10-Sep- 20
AEOPLAT0001348 - AEOPLAT0001354
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
123
RE-RE-RE Curved case (156)
9-Sep- 20
AEOPLAT0001355 - AEOPLAT0001361
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
#
Document Title
Date
Bates Stamp
Doc Type
From
To
Basis
124
RE-RE-RECurved case (157)
9-Sep- 20
AEOPLAT000136 2- AEOPLAT000136 7
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
125
RE-RE-RE Curved case
25- Sep-20
AEOPLAT000136 8- AEOPLAT000137 7
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
126
Re-RE-RE LEDs in PRO (161)
13- Aug-20
AEOPLAT000137 8- AEOPLAT000138 9
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
127
Re-RE-RE LEDs in PRO (162)
13- Aug-20
AEOPLAT000139 0- AEOPLAT000140 1
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
128
Re-RE-RE LEDs in PRO
14- Aug-20
AEOPLAT000140 2- AEOPLAT000141 4
Mark Sawyer
Zhan Vicky
Analyzing MitoRed bulbs / Discussion With Supplier
129
RE-RE-RE-RE-LEDs in PRO
14- Aug-20
AEOPLAT000141 5- AEOPLAT000142 8
Zhan Vicky
Mark Sawyer
Analyzing MitoRed bulbs / Discussion With Supplier
3. Should any of the above documents be reproduced under a different Bates number (e.g., to correct a prior AEO designation or overlapping Bates numbers), the Order shall apply to the newly numbered Bates document as well.
ACKNOWLEDGEMENT OF PROTECTIVE ORDER AND AGREEMENT TO BE BOUND
The undersigned hereby acknowledges and agrees that (s)he has reviewed the Confidentiality Order entered in the above-captioned matter and is obligated to abide by its terms.