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CostQuest Supplemental Protective Order

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Released: September 9, 2011

Federal Communications Commission

DA 11-1525

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)

Developing a Unified Intercarrier Compensation
)
CC Docket No. 01-92
Regime
)
)

Establishing Just and Reasonable Rates for Local
)
WC Docket No. 07-135
Exchange Carriers
)
)

Connect America Fund
)
WC Docket No. 10-90
)
High-Cost Universal Service Support
)
WC Docket No. 05-337
)
A National Broadband Plan for Our Future
)
GN Docket No. 09-51

SUPPLEMENTAL PROTECTIVE ORDER

Adopted: September 9, 2011


Released: September 9, 2011

By the Chief, Wireline Competition Bureau:
1. On July 29, 2011, a coalition of parties filed a proposal in the above-captioned dockets
regarding how the Commission might reform universal service and intercarrier compensation (Industry
Plan).1 In developing their proposal, the coalition members relied on the use of a cost model owned by
CostQuest Associates, Inc. (CostQuest) that is not regularly available to the public.2 To enable the public
and the Commission to evaluate their proposal, coalition members have arranged for the public and the
Commission to have access to the cost model to the extent described below for purposes of this
proceeding.
2. To ensure that the proprietary features of the cost model are afforded adequate protection in
these dockets, the Wireline Competition Bureau (Bureau), on its own motion, adopts this Supplemental
Protective Order to govern the terms and conditions of access to the cost model.3 We adhere, to the
extent practical, to the standard terms used in other Commission protective orders, making modifications
as appropriate to reflect that the material being made available is access to and the output of proprietary
software accessible via the Internet. We do not intend to make any change to the treatment of documents
and other materials already submitted or that may be submitted under the first Protective Order in this


1 Letter from Robert W. Quinn, Jr., Senior Vice President Federal Regulatory & Chief Privacy Officer, AT&T et
al. to Marlene H. Dortch, Secretary, FCC (July 29, 2011).
2 Industry Plan, Attach. 1 at 4.
3 This Supplemental Protective Order does not constitute a determination whether access to or outputs from the cost
model would be released publicly by the Commission upon a proper request under the Freedom of Information Act
or otherwise.

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DA 11-1525

proceeding.4 Nor do parties who previously followed procedures to review materials under the original
Protective Order need to take any additional steps except with regard to accessing and reviewing the cost
model.
3. Definitions. As used herein, capitalized terms not otherwise defined in this Supplemental
Protective Order shall have the following meanings:
"Acknowledgement" means the Acknowledgement of Confidentiality attached as Appendix A
hereto.
"CQBAT" means the CostQuest Associates Broadband Analysis Tool, a proprietary software
application owned by CostQuest.
"Licensed Materials" means compiled, running copies of CQBAT available over an Internet
connection, any output or databases generated by CQBAT, and any sample CQBAT database provided by
CostQuest.
"Licensing Agreement" means the Limited License attached as Appendix B hereto.
"Reviewing Party" means a person who has obtained access to Licensed Materials pursuant to
paragraphs 4 and 7 of this Supplemental Protective Order.
"Submitting Party" means CostQuest.
4. Procedure for Obtaining Access to Licensed Materials. Any person participating in this
proceeding or assisting a person participating in this proceeding--other than a person whose activities,
association, or relationship with any of its clients involve advice about or participation in the relevant
business decisions or the analysis underlying the relevant business decisions of the client in competition
with or a business relationship with the Submitting Party--may seek access to Licensed Materials. Any
person seeking access shall sign and date the Acknowledgment agreeing to be bound by the terms and
conditions of the Protective Order, and sign and date the Licensing Agreement agreeing to be bound by
the terms and conditions of the Licensing Agreement, and file both with the Bureau, on behalf of the
Commission. Such person shall also serve a copy of the Acknowledgement and a copy of the Licensing
Agreement to the Submitting Party through its Counsel of Record so that they are received at least five
business days prior to such person's reviewing or having access to the Submitting Party's Licensed
Materials, except that, where the person seeking access is one described in either clause 1 or clause 2 of
paragraph 7, the Acknowledgment and Licensing Agreement shall be delivered promptly prior to the
person's obtaining access. The Submitting Party shall have an opportunity to object to granting access to
Licensed Materials to any such person. The Submitting Party must file any such objection at the
Commission and serve it on counsel representing, retaining or employing such person within three
business days after receiving copies of that person's Acknowledgment and Licensing Agreement (or
where the person seeking access is one described in clause 1 or 2 of paragraph 7, file and serve such
objection as promptly as practicable after receipt of the relevant Acknowledgment and Licensing
Agreement). Until any such objection is resolved by the Commission and, if appropriate, by any court of
competent jurisdiction, and unless such objection is resolved in favor of the person seeking access, a


4 Developing a Unified Intercarrier Compensation Regime; Establishing Just and Reasonable Rates for Local
Exchange Carriers; Connect America Fund; High-Cost Universal Service Support; A National Broadband Plan for
Our Future
, DA 10-1749, CC Docket No. 01-92, WC Docket Nos. 17-135, 10-90, 05-337, GN Docket No. 09-51,
Protective Order, 25 FCC Rcd 13160 (Wireline Comp. Bur. rel. Sept. 16, 2010).
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person subject to an objection from a Submitting Party shall not have access to Licensed Materials.
Unless the Submitting Party has filed an objection to granting access to Licensed Materials to a person
seeking such access, and that objection remains pending at the Commission, the Submitting Party shall
execute the Licensing Agreement on or before the fourth business day after receiving the Licensing
Agreement (or where the person seeking access is one described in clause 1 or 2 of paragraph 7, as
promptly as practicable after receipt of the relevant Acknowledgment and Licensing Agreement) and
return a copy of the Licensing Agreement to the Reviewing Party.
5. Access to Licensed Materials. The Submitting Party shall provide each Reviewing Party a
login and a password that will enable access to the Licensed Materials over the Internet, using Internet
Explorer version 8 or version 9. The Submitting Party shall grant sufficient access to the Licensed
Materials to enable the Reviewing Party to be able to generate reports based on the same database of
results that produced model outputs contained in the Industry Plan or any other outputs generated using
CQBAT and submitted by the coalition members into the record of this proceeding. (Input data used to
create the Industry Plan have been filed in this docket.5) The Submitting Party shall grant the Reviewing
Party the capability to test the sensitivities of various parameters, including, at a minimum: Total Max
Funding, Target Benchmark, Alternative Technology Cost Cutoff, FCC Portion, Monthly Support
Funding Cap, Mark with Provider, and Cable Unserved. The Submitting Party shall also grant the
Reviewing Party the capability to generate reports at the following levels of geography: Census
Designated Place, Census Block Group, Census Tract, service area, Company, County, OCN-Operating
Company, and SAC-Study Area Code. No Reviewing Party will be charged any fee by the Submitting
Party for access in the manner noted in this Order to the above-described Licensed Materials.
6. Use of Licensed Materials. A Reviewing Party shall use the Licensed Materials solely for the
preparation and conduct of this proceeding before the Commission and any subsequent judicial
proceeding arising directly from this proceeding and, except as provided herein, shall not use such
Licensed Materials for any other purpose, including without limitation business, governmental, or
commercial purposes, or in other administrative, regulatory or judicial proceedings. A Reviewing Party
also may not disassemble, decompile, reverse engineer, or otherwise recreate the Licensed Materials, or
allow any other person to do so. Should the Commission rely upon or otherwise make reference to the
Licensed Materials in its decision in this proceeding, it will do so by redacting any proprietary
information from the public version of the decision and by making the unredacted version of the decision
available only to a court and to those persons entitled to access to Licensed Materials under this
Supplemental Protective Order.
7.
Permissible Disclosure. A Reviewing Party may discuss and share the Licensed Materials
with another Reviewing Party and with the Commission and its staff. A Submitting Party's Licensed
Materials may also be disclosed to employees and counsel of the Submitting Party. Subject to the
requirements of paragraph 4, a Reviewing Party may disclose Licensed Materials to (1) paralegals or
other employees of such Reviewing Party assisting them in this proceeding; and (2) employees of third-
party contractors involved solely in one or more aspects of organizing, filing, coding, converting, storing,
or retrieving documents or data or designing programs for handling data connected with this proceeding,
or performing other clerical or ministerial functions with regard to materials connected with this
proceeding.
8.
Filings with the Commission. A Reviewing Party or a Submitting Party may in any
document that it files in this proceeding reference or disclose the outputs of Licensed Materials only if


5 Letter from Mike Lieberman, Executive Director, Public Policy, et al., to Marlene Dortch, Secretary, FCC, WC
Docket No. 10-90 et al. (Aug. 12, 2011).
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they comply with the following procedure. The party shall submit to the Secretary's Office one copy of
the filing containing Licensed Materials (the "Confidential Filing"), two copies of the filing in redacted
form, i.e., containing no Licensed Materials (the "Redacted Confidential Filing"), and an accompanying
cover letter. The cover or first page of the filing, and each page of the filing that contains or discloses
Licensed Materials subject to this order must be clearly marked: "CONFIDENTIAL INFORMATION
SUBJECT TO SUPPLEMENTAL PROTECTIVE ORDER IN CC DOCKET NO. 01-92, WC DOCKET
NOS. 05-337, 07-135, 10-90 AND GN DOCKET NO. 09-51 BEFORE THE FEDERAL
COMMUNICATIONS COMMISSION." The cover letter shall also contain this legend. The
Confidential Filing shall be made under seal, and will not be placed in the Commission's public file. The
two copies of the Redacted Confidential Filing and the accompanying cover letter shall be stamped
"REDACTED FOR PUBLIC INSPECTION." The cover letter accompanying the Redacted
Confidential Filing shall state that the party is filing a redacted version of the filing. Each Redacted
Confidential Filing shall have the same pagination as the Confidential Filing from which it is derived. To
the extent that any page of the Confidential Filing contains both Licensed Materials and non-licensed
materials, only the Licensed Materials may be redacted and the page of the unredacted Confidential Filing
shall clearly distinguish the Licensed Materials from the non-licensed materials. Two copies of each
Confidential Filing and the accompanying cover letter must be delivered in person to Katie King,
Telecommunications Access Policy Division, Wireline Competition Bureau, Federal Communications
Commission, 445 12th Street, S.W., Washington, D.C. 20554, and one copy must be served on the
Submitting Party. Parties should not provide courtesy copies of pleadings containing Licensed Materials
to Commission staff unless the Bureau so requests, and any courtesy copies shall be submitted under seal.
9.
Non-Disclosure of Licensed Materials. Except with the prior written consent of the
Submitting Party, or as provided under this Supplemental Protective Order, no Licensed Materials may be
disclosed further.
10. Protection of Licensed Materials. A Reviewing Party shall have the obligation to ensure
that access to Licensed Materials is strictly limited as prescribed in this Supplemental Protective Order.
A Reviewing Party shall further have the obligation to ensure that Licensed Materials are used only as
provided in this Supplemental Protective Order.
11. Requests for Additional Disclosure. If any person requests disclosure of Licensed Materials
outside the terms of this Supplemental Protective Order, requests will be treated in accordance with
Sections 0.442 and 0.461 of the Commission's rules.
12. Client Consultation. Nothing in this Supplemental Protective Order shall prevent or
otherwise restrict Reviewing Parties from rendering advice to their clients relating to the conduct of this
proceeding and any subsequent judicial proceeding arising therefrom and, in the course thereof, relying
generally on examination of Licensed Materials; provided, however, that in rendering such advice and
otherwise communicating with such client, Reviewing Parties shall not disclose Licensed Materials to
anyone who is not a Reviewing Party.
13. No Waiver of Confidentiality. Disclosure of Licensed Materials as provided herein by any
person shall not be deemed a waiver by any Submitting Party of any privilege, trade secret claim or
entitlement to confidential treatment of such Licensed Materials. Reviewing Parties, by accessing this
material, agree: (1) not to assert any such waiver; (2) not to use Licensed Materials to seek disclosure in
any other proceeding; and (3) that accidental disclosure of Licensed Materials by a Submitting Party shall
not be deemed a waiver of any privilege, trade secret claim or entitlement as long as the Submitting Party
takes prompt remedial action.
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14. Subpoena by Courts, Departments, or Agencies. If a court or a federal or state department
or agency issues a subpoena for or orders production of Licensed Materials that a party has obtained
under terms of this Supplemental Protective Order, such party shall promptly notify the Submitting Party
of the pendency of such subpoena or order. Consistent with the independent authority of any court,
department or agency, such notification must be accomplished such that the Submitting Party has a full
opportunity to oppose such production prior to the production or disclosure of any Licensed Materials.
15. Violations of Supplemental Protective Order. Should a Reviewing Party violate any of the
terms of this Supplemental Protective Order, such Reviewing Party shall immediately convey that fact to
the Commission and to the Submitting Party. Further, should such violation consist of improper access to
or disclosure of Licensed Materials, the violating person shall take all necessary steps to remedy the
improper access or disclosure. The Commission retains its full authority to fashion appropriate sanctions
for violations of this Supplemental Protective Order, including but not limited to suspension or
disbarment of counsel from practice before the Commission, forfeitures, cease and desist orders, and
denial of further access to Licensed Materials in this or any other Commission proceeding. Nothing in
this Supplemental Protective Order shall limit any other rights and remedies available to the Submitting
Party at law or in equity against any person using Licensed Materials in a manner not authorized by this
Supplemental Protective Order.
16. Termination of Proceeding. The provisions of this Supplemental Protective Order shall not
terminate at the conclusion of this proceeding. Within two weeks after conclusion of this proceeding and
any administrative or judicial review, Reviewing Parties shall destroy or return to the Submitting Party
Licensed Materials and all copies of the same. No material whatsoever derived from Licensed Materials
may be retained by any person having access thereto, except counsel may retain, under the continuing
strictures of this Supplemental Protective Order, two copies of pleadings (one of which may be in
electronic format) prepared in whole or in part by that party that contain Licensed Materials, and one copy
of orders issued by the Commission or Bureau that contain Licensed Materials. All Reviewing Parties
shall certify compliance with these terms and shall deliver the same to counsel for the Submitting Party
not more than three weeks after conclusion of this proceeding. The provisions of this paragraph regarding
retention of Licensed Materials and copies of same shall not be construed to apply to the Commission or
its staff.
17. Authority. This Order is issued pursuant to sections 4(i), 4(j), and 403 of the
Communications Act of 1934, as amended, 47 U.S.C. 154(i), 154(j) and 403, Section 4 of the Freedom
of Information Act, 5 U.S.C. 552(b)(4), and authority delegated under sections 0.91 and 0.291 of the
Commission's rules, 47 C.F.R. 0.91 and 0.291, and is effective upon its adoption.
FEDERAL COMMUNICATIONS COMMISSION
Sharon E. Gillett
Chief, Wireline Competition Bureau
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APPENDIX A

Acknowledgment of Confidentiality

CC Docket No. 01-92, WC Docket Nos. 05-337, 07-135, 10-90, GN Docket No. 09-51

I hereby acknowledge that I have received and read a copy of the foregoing Supplemental
Protective Order in the above-captioned proceedings and the following CostQuest Associates, Inc.
Restricted CQBAT License (the "Limited License"), and I understand both.
I agree that I am bound by the Supplemental Protective Order and by the Limited License and
that I shall not disclose or use Licensed Materials except as allowed by the Supplemental Protective Order
and the Limited License.
I acknowledge that a violation of the Supplemental Protective Order is a violation of an order of
the Federal Communications Commission.
I acknowledge specifically that my access to any information obtained as a result of the
Supplemental Protective Order and the Limited License is due solely to my capacity as a party or
representative of a party to this proceeding or as a person described in paragraph 7 of the foregoing
Supplemental Protective Order and agree that I will not use such information in any other capacity.
I acknowledge that it is my obligation to ensure that Licensed Materials are not accessed or used
except as specifically permitted by the terms of the Supplemental Protective Order and the Limited
License.
I certify that I have verified that there are in place procedures at my firm or office to prevent
unauthorized access to or disclosure of Licensed Materials.
Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them
in the Supplemental Protective Order.

Executed this ___ day of _____________, ____.

_________________________________


[Name]

[Position]

[Address]


[Telephone]
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APPENDIX B

CostQuest Associates, Inc. Restricted CQBAT License Limited To Use Solely for Review and

Evaluation for Purposes of the FCC Proceeding in CC Docket No. 01-92, WC Docket Nos. 05-337,

07-135, 10-90, GN Docket No. 09-51
THIS LIMITED LICENSE ("Agreement") is accepted and made effective as of the ___ day of
____________, 2011 ("Effective Date"), between CostQuest Associates, Inc. ("Licensor") and
__________________ ("Licensee") with respect to (i) Licensor's proprietary CQBAT software
application ("CQBAT"), (ii) the output of CQBAT ("CQBAT Output") and, if applicable, (iii) a sample
CQBAT database ("Sample Database"), which supports and may be used in CQBAT and therefore
indirectly accessed by Licensee.
Licensor hereby grants to Licensee, and Licensee hereby accepts, a non-exclusive, non-
transferable, limited license to use the Licensed Materials, without fees, charges, or costs to the Licensee
of any kind, under the following terms and restrictions:
1. License Grants and Restrictions
1.1. Licensee will utilize the Licensed Materials only for official purposes pertaining to providing
comments and other filings to the Federal Communication Commission (FCC) for use in the
proceeding identified above, and in subsequent judicial proceedings (the "Project").
1.2. Licensee will not transfer, sell, rent, disclose, make available or otherwise communicate, resell,
sublicense or use the Licensed Materials for any other purpose or in any other manner.
1.3. Upon conclusion of the Project, Licensee shall at the option of Licensor, either return to Licensor
or destroy all copies of Licensed Materials and cease all further use of Licensed Materials for
any purpose.


1.4. Licensee shall only make copies of the licensed CQBAT Output as required for the Project as
described in the Supplemental Protective Order. On any copy of the CQBAT Output that
Licensee is permitted to make or distribute, Licensee shall reproduce all copyright notices and
any other proprietary legends of Licensor as they appear.
1.5. Licensee shall not make any copies, distribute, sublicense, transfer, sell, rent, disclose, or make
available any Sample Database provided under this Agreement except consistent with the
Supplemental Protective Order.
1.6. Licensee shall at all times maintain the confidentiality of the Licensed Materials, handling the
Licensed Materials in compliance with the Supplemental Protective Order. In the event that any
portion of the Licensed Materials should come into the possession of unauthorized third parties
as a result of a breach by Licensee of this Agreement, Licensee will, at its expense and without
limiting any other rights available to Licensor, immediately notify Licensor and use all
commercially reasonable efforts to retrieve such materials and will reimburse Licensor for all
reasonable expenses incurred by Licensor in attempting to retrieve such materials.
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1.7. If Licensee sells, makes available to a third party, or otherwise disposes of Licensee-owned
media on which the Licensed Materials are or were resident, that media must be erased and
scrubbed before such sale or disposal.
1.8. Licensee will not, and will not permit any third party to, disassemble, decompile, reverse
engineer, or otherwise recreate the Licensed Materials.
1.9. In accessing or using the Licensed Materials, Licensee will not, by any action or inaction, violate
laws or regulations promulgated by any governmental or quasi-governmental authorities that are
binding upon it and will take all reasonable steps to assist Licensor or any other participant in the
Project, or their affiliates, to avoid any violations of any such laws or regulations that are binding
upon them.
1.10. Upon reasonable notice to Licensee, and at Licensor's sole expense, Licensor's auditors shall
have the right to inspect Licensee's records relating to the Project as necessary for Licensor to
verify Licensee's compliance with the terms of this Agreement. Audits shall be conducted at
Licensee's premises during normal business hours and in a manner that does not unreasonably
interfere with Licensee's operations.
2. Disclaimer of Warranties
2.1. LICENSEE ACKNOWLEDGES AND AGREES THAT (A) LICENSOR HAS NOT MADE
ANY EXPRESS OR IMPLIED WARRANTIES TO LICENSEE REGARDING THE
LICENSED MATERIALS AND (B) THE LICENSED MATERIALS ARE BEING PROVIDED
TO LICENSEE "AS IS," WITHOUT WARRANTIES OF ANY KIND. LICENSOR DOES
NOT WARRANT THAT THE LICENSED MATERIALS ARE FREE FROM DEFECTS.
LICENSOR EXPRESSLY EXCLUDES AND DISCLAIMS ANY IMPLIED WARRANTY OF
FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NON-
INFRINGEMENT OF THIRD PARTY RIGHTS.
3. Term and Termination
3.1. This Agreement shall terminate automatically upon the termination of the above-captioned
proceeding and any administrative or judicial review.
3.2. Notwithstanding section 3.1, if Licensee agrees that Licensee does not continue to require
Licensed Materials, Licensor may terminate this Agreement.
3.3. If Licensor believes that Licensee is in violation of the Supplemental Protective Order or this
Licensing Agreement, Licensor shall so notify the Commission. If the Commission determines
that Licensee is in violation of this Supplemental Protective Order or this Licensing Agreement,
Licensor may terminate this Agreement.
4. Limitation of Liability
4.1. IN NO EVENT SHALL LICENSOR HAVE ANY LIABILITY FOR DAMAGES SUSTAINED
BY LICENSEE IN CONNECTION WITH THIS AGREEMENT, THE PROJECT OR THE
POSSESSION OR USE OF LICENSED MATERIALS, INCLUDING, WITHOUT
LIMITATION, ANY LOST REVENUES OR PROFITS, OR ANY INDIRECT,
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CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES, EVEN IF LICENSOR HAS
BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
5. Ownership of Intellectual Property
5.1. Licensee acknowledges that the Licensed Materials, including without limitation all output and
derivatives of, as well as all modifications and customizations to the Licensed Materials, are
proprietary to Licensor and that Licensor retains exclusive ownership of all such Licensed
Materials and all proprietary rights associated therewith. Licensee shall, at the direction of
Licensor, take all commercially reasonable measures to protect Licensor's rights in the Licensed
Materials.
5.2. Except as expressly provided herein, Licensee is not granted any other rights or license to
patents, copyrights, trade secrets, data or trademarks with respect to Licensed Materials.
Licensee shall promptly notify Licensor in writing upon its discovery of any unauthorized use or
infringement of the Licensed Materials.
6. Additional Terms
6.1. Compliance with FCC Requirements and Other Laws. This Licensing Agreement is expressly
made subject to any United States government laws, regulations, orders or other restrictions
regarding the Project or use of software, data, output or products thereof. Notwithstanding
anything to the contrary in this Licensing Agreement, Licensee will not directly or indirectly
export, or permit the transfer of, any software, data, output or products (a) to any country or
destination for which the United States government or a United States governmental agency
requires an export license or other approval for export without first having obtained such license
or other approval; or (b) otherwise contrary to United States law, including, without limitation,
FCC rules, policies and regulations.
6.2. No Waivers. No delay or omission by either party to exercise any right or power accruing upon
any noncompliance or default by the other party with respect to any of the terms of this
Agreement will impair any such right or power or be construed to be a waiver thereof. A waiver
by either party of any breach of the covenants, conditions or agreements to be performed or
honored by the other party will not be construed to be a waiver of any later breach thereof or of
any other covenant, condition or agreement herein contained.
6.3. Assignments. This Agreement is binding upon and inures to the benefit of the parties hereto and
their respective successors and assigns. Licensee shall not assign this Agreement or transfer any
rights granted hereunder, in whole or in part, without obtaining the prior written consent of
Licensor, and any attempted assignment or transfer in violation of this provision is void.
6.4. Severability and Survival of Obligations. If any provision of this Agreement is held invalid or
unenforceable, the remainder of this Agreement will not be affected thereby, and each remaining
provision of this Agreement will be valid and enforceable to the extent permitted by law.
Sections 1.1 1.10, 2, 4, 5, and 6 shall survive any expiration or termination of this Agreement.
6.5. Governing Law. This Agreement will be governed by and construed in accordance with Federal
law.
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6.6. Entire Agreement. This Agreement and the Supplemental Protective Order constitute the
parties' entire understanding with regard to the matters herein, and there are no other
understandings, either written or unwritten, with regard to such matters. The Agreement may
not be modified, amended, canceled or waived, in whole or in part, except by a written
instrument signed by the parties hereto.
IN WITNESS WHEREOF, the parties have executed this Agreement by their duly authorized
representatives effective as of the date first set forth above.
LICENSOR:
LICENSEE:
CostQuest Associates, Inc. _______________________________________
[name]
By: ___________________
Jim Stegeman, President
_______________________________________
[position]
________________________________________
Outside Counsel of Record:
[company]
Margaret Avril Lawson
________________________________________
Taft Stettinius & Hollister LLP
[address]
425 Walnut Street, Suite 1800
Cincinnati, Ohio 45202-3957
________________________________________
(513) 381-2838 (tel)
[telephone]
(513) 381-0205 (fax)
Lawson@taftlaw.com
________________________________________
[email address]
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