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Federal Communications Commission

DA 12-51

Before the

Federal Communications Commission

Washington, D.C. 20554

In the Matter of
)
)
Application of Cellco Partnership d/b/a
)     WT Docket No. 12-4
Verizon Wireless and SpectrumCo LLC 
)
For Consent To Assign Licenses 
)
)
Application of Cellco Partnership d/b/a
)
Verizon Wireless and Cox TMI Wireless, LLC 
)
For Consent To Assign Licenses 
)

SECOND PROTECTIVE ORDER

Adopted: January 17, 2012

 

Released: January 17, 2012

By the Chief, Wireless Telecommunications Bureau:
1. In this Second Protective Order, we adopt procedures to provide more limited access to 
certain especially competitively sensitive information that may be filed in this proceeding, which, if 
released to competitors or those with whom the Submitting Party does business, would allow those 
persons to gain a significant advantage in the marketplace or in negotiations.  We anticipate that such 
materials will be necessary to develop a more complete record on which to base the Commission’s 
decision.  While we are mindful of the highly sensitive nature of such information, we are also mindful of 
the right of the public to participate in this proceeding in a meaningful way.  Therefore, consistent with 
past practice,1 we will make such information available to participants in this proceeding, but limit such 
access to their Outside Counsel of Record, their Outside Consultants and experts whom they retain to 
assist them in this proceeding, and employees of such Outside Counsel and Outside Consultants.  We 
conclude that the procedures we adopt in this Second Protective Order give appropriate access to the 
public while protecting especially competitively sensitive information from improper disclosure, and that 
the procedures thereby serve the public interest. 
2. Definitions. As used herein, capitalized terms not otherwise defined in this Second Protective 
Order shall have the following meanings:
“Acknowledgement” means the Acknowledgement of Confidentiality attached as Appendix B 
hereto.
“Competitive Decision-Making” means that a person’s 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 in a business relationship 
with the Submitting Party.
 
 
1 See, e.g., Applications of AT&T Inc. and Deutsche Telekom AG for Consent To Assign or Transfer Control of 
Licenses and Authorizations, WT Docket No. 11-65, Second Protective Order, 26 FCC Rcd 6243 (WTB 2011); 
News Corporation, General Motors Corporation, and Hughes Electronic Corporation, MB Docket No. 03-124, 
Order, 18 FCC Rcd 15198 (MB 2003) (adopting a second protective order).

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“Highly Confidential Information” means information that is not otherwise available from 
publicly available sources; that the Submitting Party has kept strictly confidential; that is subject to 
protection under FOIA and the Commission’s implementing rules; that the Submitting Party claims 
constitutes some of its most sensitive business data which, if released to competitors or those with whom 
the Submitting Party does business, would allow those persons to gain a significant advantage in the 
marketplace or in negotiations; and that it is described in Appendix A to this Second Protective Order, as 
the same may be amended from time to time.
“Outside Counsel of Record” or “Outside Counsel” means the attorney(s), firm(s) of attorneys, or 
sole practitioner(s), as the case may be, retained by a party in this proceeding, provided that such 
attorneys are not involved in Competitive Decision-Making.  The term “Outside Counsel of Record” 
includes any attorney representing a non-commercial party in this proceeding, provided that such attorney 
is not involved in Competitive Decision-Making.  
“Outside Consultant” means a consultant or expert retained for the purpose of assisting Outside 
Counsel or a party in this proceeding, provided that such consultant or expert is not involved in 
Competitive Decision-Making.  The term “Outside Consultant” includes any consultant or expert 
employed by a non-commercial party in this proceeding, provided that such consultant or expert is not 
involved in Competitive Decision-Making.
“Outside Firm” means a firm, whether organized as a partnership, limited partnership, limited 
liability partnership, limited liability company, corporation or otherwise, of Outside Counsel or Outside 
Consultants.
“Redacted Highly Confidential Document” means a copy of a Stamped Highly Confidential 
Document where the Highly Confidential Information has been redacted.
“Reviewing Party” means a person who has obtained access to Highly Confidential Information 
(including Stamped Highly Confidential Documents) pursuant to paragraphs 7 or 11 of this Second 
Protective Order.
“Stamped Highly Confidential Document” means any document, or any part thereof, that contains 
Highly Confidential Information and that bears the legend (or which otherwise shall have had the legend 
recorded upon it in a way that brings its attention to a reasonable examiner) “HIGHLY CONFIDENTIAL 
INFORMATION – SUBJECT TO SECOND PROTECTIVE ORDER IN WT DOCKET NO. 12-4 
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION,” unless the Commission determines, 
sua sponte or by request pursuant to sections 0.459 or 0.461 of its rules, that any such document is not 
entitled to highly confidential or confidential treatment.  The term “document” means any written, 
recorded, electronically stored, or graphic material, whether produced or created by the Submitting Party 
or another person.  By designating a document a “Stamped Highly Confidential Document,” a Submitting 
Party signifies and represents that it contains Highly Confidential Information.
“Submitting Party” means a person who submits a Stamped Highly Confidential Document.
3. Designation of Information as Highly Confidential. Before a Submitting Party may designate 
documents and information as Highly Confidential, it must receive the written approval of the 
Commission staff, which, based on the Submitting Party’s representations, will make a preliminary 
determination whether the proposed designation meets the requirements set forth in this Second 
Protective Order.  A Submitting Party may designate as Highly Confidential only that information 
described in Appendix A to this Second Protective Order, as the same may be amended from time to time.  
If a Submitting Party believes that the existing list of descriptions contained in Appendix A should be 
revised, the Submitting Party shall submit a request to amend Appendix A along with a supporting 
explanation.  If the request is granted, in whole or in part, an amended Appendix A will be issued. 
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4. Effect of Designation.  By designating documents and information as Highly Confidential 
under this Second Protective Order, a Submitting Party will be deemed to have submitted a request that 
the material not be made routinely available for public inspection under the Commission’s rules.2 Any 
person wishing to challenge the designation of a document or portion of a document as Highly 
Confidential must file such a challenge at the Commission and serve it on the Submitting Party.  The 
Submitting Party must file any reply within five business days, and include a justification for treating the 
information as confidential.3 The documents and information challenged will continue to be accorded 
confidential treatment until the Commission acts on the request and all subsequent appeal and stay 
proceedings have been exhausted.4 Any decision on whether the materials should be accorded 
confidential treatment does not constitute a resolution of the merits concerning whether such information 
would be released publicly by the Commission upon a proper request under our rules implementing the 
Freedom of Information Act (FOIA).5  
5. Submission of Stamped Highly Confidential Documents. A Submitting Party shall submit to 
the Secretary’s Office one copy of each Stamped Highly Confidential Document it wishes to file, two 
copies of the Redacted Highly Confidential Document in redacted form and an accompanying cover 
letter.  Each page of the Stamped Highly Confidential Document shall be stamped “HIGHLY 
CONFIDENTIAL INFORMATION – SUBJECT TO SECOND PROTECTIVE ORDER IN WT 
DOCKET NO. 12-4 BEFORE THE FEDERAL COMMUNICATIONS COMMISSION.”  The cover 
letter also shall contain this legend.  Each Redacted Highly Confidential Document shall have the same 
pagination as the Stamped Highly Confidential Document from which it is derived.  The two copies of the 
Redacted Highly Confidential Document and the accompanying cover letter shall be stamped 
“REDACTED – FOR PUBLIC INSPECTION.”  To the extent that any page of the filing contains both 
Highly Confidential Information or Confidential Information and non-confidential information, only the 
Highly Confidential Information and Confidential Information may be redacted and the page of the 
unredacted filing shall clearly distinguish among the Highly Confidential Information, the Confidential 
Information, and the non-confidential information.  In addition, two copies of each Stamped Highly 
Confidential Document and the accompanying cover letter must be delivered, as directed by Commission 
staff to Sandra K. Danner, Broadband Division, Wireless Telecommunications Bureau, Federal 
Communications Commission, 445 12th Street, S.W., Room 3A-266, Washington, D.C. 20554.
6. Copying Sensitive Documents.  If, in the reasonable judgment of the Submitting Party, a 
document contains information so sensitive that copying of it should be restricted, the Submitting Party 
may mark the document with the legend “Additional Copying Restricted.”  Subject to the provisions for 
access to information in electronic format in paragraph 9, each Outside Firm shall receive only one copy 
of the document and no more than two additional copies, in any form, shall be made.  Further, the Outside 
Firms hired by any individual party to this proceeding shall collectively hold no more than 15 copies of 
the document.  Application for relief from this restriction against further copying may be made to the 
Commission, with notice to Counsel of Record for the Submitting Party, which will be granted only for 
cause.
7. Procedure for Obtaining Access to Highly Confidential Information. Access to Stamped 
Highly Confidential Documents and Highly Confidential Information is limited to Outside Counsel of 
Record, Outside Consultants, and those employees of Outside Counsel and Outside Consultants described 
in paragraph 11.  Any person seeking access to Stamped Highly Confidential Documents and Highly 
Confidential Information subject to this Second Protective Order shall sign and date the Acknowledgment 
agreeing to be bound by the terms and conditions of this Second Protective Order; and file the 
 
 
2 See 47 C.F.R. §§ 0.459(a), 0.459(a)(3).
3 See 47 C.F.R. § 0.459(b).
4 See 47 C.F.R. § 0.459(g).
5 See 47 C.F.R. §§ 0.459(h), 0.461.
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Acknowledgment with the Bureau, on behalf of the Commission.  Where the person seeking access is 
Outside Counsel or an Outside Consultant, a copy of the Acknowledgment shall be served upon the 
relevant Submitting Party through its Counsel of Record so that it is received at least five business days 
prior to such person’s reviewing or having access to the Submitting Party’s Stamped Highly Confidential 
Documents or Highly Confidential Information; where the person seeking access is one described in 
either clause 1 or 2 of paragraph 11, the Acknowledgment shall be served upon the Submitting Party 
promptly prior to the person’s obtaining access. Where there are multiple Submitting Parties, a copy of 
the Acknowledgment must be served on each Submitting Party within the time periods stated above.  
Each Submitting Party shall have an opportunity to object to the disclosure of its Stamped Highly 
Confidential Documents or Highly Confidential Information to any such person. A 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 a copy of that person’s 
Acknowledgment (or where the person seeking access is one described in clause 1 or 2 of paragraph 11, 
file and serve such objection as promptly as practicable after receipt of the Acknowledgment). Further, if 
a Submitting Party files additional Highly Confidential Documents, it must file any objection to the 
disclosure of those additional Highly Confidential Documents to any Reviewing Party before or 
contemporaneous with filing those documents.  Until any 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 person subject to an objection from a Submitting Party shall not have access to 
relevant Stamped Highly Confidential Documents or Highly Confidential Information.  
8. Review of Stamped Highly Confidential Documents. A Submitting Party shall make available 
for review the Stamped Highly Confidential Documents of such party at the offices of the party’s Outside 
Counsel of Record.  Subject to the terms of paragraph 6, a Reviewing Party shall be provided the 
following alternatives: (1) a Reviewing Party shall be provided adequate opportunity to inspect the 
documents on site; (2) a Reviewing Party may inspect the documents on site with the ability to request 
copies, at cost, of some or all of the documents; or (3) a Reviewing Party may request a complete set of 
the documents at cost, allowing two business days after the request is made for receipt of the copies.  If a 
Reviewing Party plans on requesting a complete set of documents, it is encouraged to make such a request 
at the time it submits the Acknowledgment to allow it the opportunity to begin reviewing the documents 
at the end of the five-day period referred to in paragraph 7.  All copies of documents that are removed 
from the Submitting Party’s office must be returned or destroyed in accordance with the terms of 
paragraph 20.
9. Review of Highly Confidential Information in Electronic Format. A Submitting Party shall 
make available to a Reviewing Party one copy of Highly Confidential Information contained, recorded, or 
electronically stored on a CD-ROM, DVD, flash drive, portable hard drive or similar electronic storage 
device, which shall be considered a Stamped Highly Confidential Document.  The disk or other medium 
containing the information in electronic format should be physically sent to the Reviewing Party; a 
Reviewing Party may not require that it be transmitted electronically.  A Reviewing Party may 
temporarily load onto a computer the information in electronic format.  Once loaded onto a computer, any 
files containing Highly Confidential Information shall be password protected immediately.  The Highly 
Confidential Information may not be stored on a computer after being analyzed.  After the analysis is 
complete, the results of such analysis may be stored by saving the results (but not the original underlying 
Highly Confidential Information) to a mobile data storage medium, which, if it contains Highly 
Confidential Information, shall be treated as a Stamped Highly Confidential Document and so marked.  
All files containing Highly Confidential Information shall be deleted from the computer as soon as 
practicable.  The original disk or other storage medium shall be stored securely and a record kept of any 
persons given access to it.  
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10. Use of Highly Confidential Information.  Persons obtaining access to Highly Confidential 
Information (including Stamped Highly Confidential Documents) under this Second Protective Order 
shall use the information 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 documents or information for any other purpose, including without limitation 
business, governmental, or commercial purposes, or in other administrative, regulatory or judicial 
proceedings.  Should the Commission rely upon or otherwise make reference to the contents of any of the 
Stamped Highly Confidential Documents or Highly Confidential Information in its decision in this 
proceeding, it will do so by redacting any Highly Confidential 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 Highly Confidential Information under this Second Protective Order.   
11. Permissible Disclosure.  A Reviewing Party may discuss and share the contents of the 
Stamped Highly Confidential Documents and Highly Confidential Information with another Reviewing 
Party and with the Commission and its staff.  A Submitting Party’s Stamped Highly Confidential 
Documents and Highly Confidential Information may also be disclosed to employees and Counsel of the 
Submitting Party.  Subject to the requirements of paragraph 7, a Reviewing Party may disclose Stamped 
Highly Confidential Documents and Highly Confidential Information 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 documents connected with this 
proceeding.  
12. Filings with the Commission.  A Reviewing Party or a Submitting Party may in any document 
that it files in this proceeding disclose Highly Confidential Information only if it complies with the 
following procedure.  The party shall submit to the Secretary’s Office one copy of the filing containing 
Highly Confidential Information (the “Highly Confidential Filing”), two copies of the filing in redacted 
form, i.e., containing no Highly Confidential Information (the “Redacted Highly Confidential Filing”), 
and an accompanying cover letter.  The cover or first page of the Highly Confidential Filing and each 
page of the Highly Confidential Filing that contains or discloses Highly Confidential Information must be
clearly marked “HIGHLY CONFIDENTIAL INFORMATION – SUBJECT TO SECOND 
PROTECTIVE ORDER IN WT DOCKET NO. 12-4 BEFORE THE FEDERAL COMMUNICATIONS 
COMMISSION.”  The cover letter shall also contain this legend.  The Highly Confidential Filing shall be 
made under seal, and will not be placed in the Commission’s public file.  The two copies of the Redacted 
Highly Confidential Filing and the accompanying cover letter shall be stamped “REDACTED – FOR 
PUBLIC INSPECTION.”  The cover letter accompanying the Redacted Highly Confidential Filing shall 
state that the party is filing a redacted version of the filing.  Each Redacted Highly Confidential Filing 
shall have the same pagination as the Highly Confidential Filing from which it is derived.  To the extent 
that any page of the Highly Confidential Filing contains any type of Confidential Information, only the 
Confidential Information (of whatever type) may be redacted and the page of the unredacted Confidential 
Filing shall clearly distinguish among the various types of Confidential Information and the non-
confidential information.  Two copies of each Highly Confidential Filing and the accompanying cover 
letter must be delivered, as directed by Commission staff, to Sandra K. Danner, Broadband Division, 
Wireless Telecommunications Bureau, Federal Communications Commission, 445 12th Street, S.W., 
Room 3A-266, Washington, D.C. 20554, and one copy must be served on the relevant Submitting Party.  
Parties should not provide courtesy copies of pleadings containing Highly Confidential Information to 
Commission staff unless the Bureau so requests, and any such courtesy copies shall be submitted under 
seal.
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13. Non-Disclosure of Stamped Highly Confidential Documents and Highly Confidential 
Information.  Except with the prior written consent of the Submitting Party or as provided under this 
Second Protective Order, neither a Stamped Highly Confidential Document nor any Highly Confidential 
Information may be disclosed further.  
14. Protection of Stamped Highly Confidential Documents and Highly Confidential Information.
A Reviewing Party shall have the obligation to ensure that access to Stamped Highly Confidential 
Documents and Highly Confidential Information is strictly limited as prescribed in this Second Protective 
Order. A Reviewing Party shall further have the obligation to ensure that Stamped Highly Confidential 
Documents and Highly Confidential Information are used only as provided in this Second Protective 
Order.
15. Requests for Additional Disclosure.  If any person requests disclosure of Highly Confidential 
Information outside the terms of this Second Protective Order, such a request will be treated in 
accordance with sections 0.442 and 0.461 of the Commission’s rules.
16. Client Consultation.  Nothing in this Second Protective Order shall prevent or otherwise 
restrict Outside Counsel 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 Stamped Highly Confidential Documents or Highly Confidential Information; provided, 
however, that in rendering such advice and otherwise communicating with such client, Outside Counsel 
shall not disclose Stamped Highly Confidential Documents or Highly Confidential Information.
17. No Waiver of Confidentiality.  Disclosure of Highly Confidential Information as provided 
herein by any person shall not be deemed a waiver by any Submitting Party of any privilege or 
entitlement to confidential treatment of such Highly Confidential Information. Reviewing Parties, by 
viewing this material, agree: (1) not to assert any such waiver; (2) not to use Highly Confidential 
Information to seek disclosure in any other proceeding; and (3) that accidental disclosure of Highly 
Confidential Information by a Submitting Party shall not be deemed a waiver of any privilege or 
entitlement as long as the Submitting Party takes prompt remedial action.
18. Subpoena by Courts, Departments, or Agencies.  If a court, or a federal or state department or 
agency issues a subpoena for or orders the production of Stamped Highly Confidential Documents or 
Highly Confidential Information that a party has obtained under terms of this Second Protective Order, 
such party shall promptly notify each 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 Stamped Highly Confidential Document or Highly Confidential 
Information.
19. Violations of Second Protective Order.  Should a Reviewing Party violate any of the terms of 
this Second 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 disclosure of 
Highly Confidential Information, the violating person shall take all necessary steps to remedy the 
improper disclosure.  The Commission retains its full authority to fashion appropriate sanctions for 
violations of this Second Protective Order, including but not limited to suspension or disbarment of 
Outside Counsel or Consultants from practice before the Commission, forfeitures, cease and desist orders, 
and denial of further access to Highly Confidential Information in this or any other Commission 
proceeding. Nothing in this Second Protective Order shall limit any other rights and remedies available to 
the Submitting Party at law or in equity against any person using Highly Confidential Information in a 
manner not authorized by this Second Protective Order.
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20. Termination of Proceeding.  The provisions of this Second 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 
Stamped Highly Confidential Documents and all copies of the same.  No material whatsoever derived 
from Stamped Highly Confidential Documents may be retained by any person having access thereto, 
except Outside Counsel may retain, under the continuing strictures of this Second 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 Highly Confidential Information, and one copy of orders issued by the Commission or 
Bureau that contain Highly Confidential Information.  All Outside Counsel shall certify compliance with 
these terms and shall deliver such certification to Outside Counsel for the Submitting Party not more than 
three weeks after conclusion of this proceeding.  The provisions of this paragraph regarding retention of 
Stamped Highly Confidential Documents and copies of the same and Highly Confidential Information 
shall not be construed to apply to the Commission or its staff.
21. Authority.  This Order is issued pursuant to sections 4(i), 214 and 310(d) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 214 and 310(d), Section 4 of the 
Freedom of Information Act, 5 U.S.C. § 552(b)(4), and authority delegated under section 0.291 of the 
Commission’s rules, 47 C.F.R. § 0.291, and is effective upon its adoption.
FEDERAL COMMUNICATIONS COMMISSION
Rick Kaplan
Chief, Wireless Telecommunications Bureau
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APPENDIX A

Highly Confidential Information and Documents

As specified in paragraphs 2 and 3 of the Second Protective Order, only information and 
documents set forth in this Appendix and that otherwise meet the definition of Highly Confidential 
Information or Highly Confidential Documents may be designated as Highly Confidential.  This 
Appendix will be updated as necessary.
1. Information that details the terms and conditions of or strategy related to a Submitting Party’s 
most sensitive contracts (e.g., marketing, service or product agreements, nondisclosure 
agreements relating to potential mergers and acquisitions, and comparably sensitive
contracts).
2. Information that discusses specific steps that will be taken to integrate companies or 
discussions of specific detail or disaggregated quantification of merger integration benefits or 
efficiencies (including costs, benefits, timeline, and risks of the integration).
3. Information that discusses in detail current or future plans to compete for a customer or 
specific groups or types of customers (e.g., business or wholesale customers), including 
future procurement strategies, pricing strategies, product strategies, advertising or marketing 
strategies, future business plans, technology implementation or deployment plans and 
strategies (e.g., engineering capacity planning documents), plans for handling acquired 
customers, and human resources and staffing strategies.
4. Information that provides granular information about a Submitting Party’s current or future 
costs, revenues, marginal revenues, or market share.
5. Information that provides numbers of customers and revenues broken down by customer type 
(e.g., business) and market area (e.g., CMA/MSA/RSA, DMA, state, regional cluster) or zip 
code.
6. Information that discloses the identity or characteristics (including identifying information 
about specific customer facilities) of specific customers (including their levels of demand) or 
of those a company is targeting or with whom a company is negotiating.
7. Information that discusses in detail the number or anticipated changes in the number of 
customers or amount of traffic, including churn rate data, broken down by zip code or market 
and detailed information about why customers discontinue service.
8. Information that provides detailed or granular engineering capacity information or 
information about specific facilities, including collocation sites, cell sites, or maps of network 
facilities.
9. Information that provides detailed technical performance data and test results.
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APPENDIX B

Acknowledgment of Confidentiality

WT Docket No. 12-4

  I hereby acknowledge that I have received and read a copy of the foregoing Second Protective 
Order in the above-captioned proceeding, and I understand it.
I agree that I am bound by the Second Protective Order and that I shall not disclose or use 
Stamped Highly Confidential Documents or Highly Confidential Information except as allowed by the 
Second Protective Order.
I acknowledge that a violation of the Second Protective Order is a violation of an order of the 
Federal Communications Commission.
I certify that I am not involved in Competitive Decision-Making.
  Without limiting the foregoing, to the extent that I have any employment, affiliation, or role with 
any person or entity other than a conventional private law firm (such as, but not limited to, a lobbying or 
advocacy organization), I acknowledge specifically that my access to any information obtained as a result 
of the Second Protective Order is due solely to my capacity as Outside Counsel or Outside Consultant to a 
party or as a person described in paragraph 11 of the foregoing Second 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 Stamped Highly Confidential Documents are 
not duplicated except as specifically permitted by the terms of the Second Protective Order.  
I certify that I have verified that there are in place procedures at my firm or office to prevent 
unauthorized disclosure of Stamped Highly Confidential Documents and Highly Confidential 
Information.
Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them 
in the Protective Order or the Second Protective Order.
Executed this ___ day of _____________, 2012.
 
_________________________________
 
[Name]
 
[Position]
 
[Firm]
[Telephone]
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