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       Case 1:23-cv-03903-JSR           Document 27         Filed 07/06/23      Page 1 of 12




                      UNITED STATES DISTRICT COURT FOR THE
                         SOUTHERN DISTRICT OF NEW YORK




IN RE JP MORGAN CHASE & CO.                                  Master Case No. 1:23-CV-03903 (JSR)
DERIVATIVE LITIGATION
                                                             DERIVATIVE ACTION




                STIPULATION AND [PROPOSED] PROTECTIVE ORDER

       The parties having agreed to the following terms of confidentiality, and the Court having

found that good cause exists for issuance of an appropriately tailored confidentiality order

governing the pre-trial phase of this action, it is therefore hereby

       ORDERED that any person subject to this Order -- including without limitation the parties

to this action, their representatives, agents, experts and consultants, all third parties providing

discovery in this action, and all other interested persons with actual or constructive notice of this

Order -- shall adhere to the following terms, upon pain of contempt:

       1.      Any person subject to this Order who receives from any other person any

“Discovery Material” (i.e., information of any kind provided in the course of discovery in this

action) that is designated as “Confidential” pursuant to the terms of this Order shall not disclose

such Confidential Discovery Material to anyone else except as expressly permitted hereunder.

       2.      The person producing any given Discovery Material may designate as Confidential

only such portion of such material as consists of:

               a.      previously nondisclosed financial information (including without limitation

                       profitability reports or estimates, percentage fees, design fees, royalty rates,

                       minimum guarantee payments, sales reports and sale margins);
       Case 1:23-cv-03903-JSR         Document 27        Filed 07/06/2

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