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Full title: Stipulation, Protective Order Filed by CIP United Co. Ltd., Prestige Century Investments Limited. (Kornberg, Bernard) (Entered: 01/15/2021)

Document posted on Jan 14, 2021 in the bankruptcy, 17 pages and 0 tables.

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Designating Party: a Party or Non-Party that designates information or items that it 16 produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY CONFIDENTI17 – ATTORNEYS’ EYES ONLY”.Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in 11 this action.A Receiving Party may use Protected Material that is disclosed or 12 produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending13 or attempting to settle this litigation.If the Designating Party timely seeks a protective order, the Party served with the subpoe5 or court order shall not produce any information designated in this action as “CONFIDENTIAL” or 6 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before a determination by the court from 7 which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. Th8 In the event that a Party is required, by a valid discovery request, to produce a No19 Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-20 Party not to produce the Non-Party’s confidential information, then the Party shall: 21 1. promptly notify in writing the Requesting Party and the Non-Party that some or a22 of the information requested is subject to a confidentiality agreement with a Non-Party; 23 2.

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DONALD H. CRAM (State Bar No. 160004) 1 dhc@severson.com BERNARD J. KORNBERG (State Bar No. 252006) 2 bjk@severson.com SEVERSON & WERSON 3 A Professional Corporation One Embarcadero Center, Suite 2600 4 San Francisco, California 94111 Telephone: (415) 398-3344 5 Facsimile: (415) 956-0439 6 Attorneys for Prestige Century Investments Limited and CIP United Co. Ltd. 7 UNITED STATES BANKRUPTCY COURT 8 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 9 10 In re Case No. 20-50682 11 Wave Computing, Inc., et al.1 Chapter 11 (Jointly Administered) 12 Debtors. STIPULATED PROTECTIVE ORDER FO 13 LITIGATION INVOLVING PATENT HIGHLY SENSITIVE CONFIDENTIA 14 INFORMATION AND/OR TRADE SECRETS 15 Judge: Hon. M. Elaine Hammond 16 17 18 19 1. PURPOSES AND LIMITATIONS 20 Disclosure and discovery activity in this action are likely to involve production of confidential, 21 proprietary, or private information for which special protection from public disclosure and from use for a22 purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate 23 and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that thi24 Order does not confer blanket protections on all disclosures or responses to discovery and that the protecti25 26 1 The Debtors in these Chapter 11 cases are Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave Computing (27 Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC. The Debtors’ mailing address is 3201 SBlvd, Santa Clara, CA 95054.

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it affords from public disclosure and use extends only to the limited information or items that are entitled 1 confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth i2 Section 14.4, below, that this Stipulated Protective Order does not entitle them to file confidential 3 information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the 4 standards that will be applied when a party seeks permission from the court to file material under seal. 5 6 2. DEFINITIONS 7 2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or8 items under this Order. 9 2.2 “CONFIDENTIAL” Information or Items: information (regardless of how it is generated,10 stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 11 26(c). 12 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as th13 support staff). 14 2.4 INTENTIONALLY LEFT BLANK 15 2.5 Designating Party: a Party or Non-Party that designates information or items that it 16 produces in disclosures or in responses to discovery as “CONFIDENTIAL” or “HIGHLY CONFIDENTI17 – ATTORNEYS’ EYES ONLY”. 18 2.6 Disclosure or Discovery Material: all items or information, regardless of the medium or 19 manner in which it is generated, stored, or maintained (including, among other things, testimony, transcri20 and tangible things), that are produced or generated in disclosures or responses to discovery in this matter. 21 2.7 Expert: a person with specialized knowledge or experience in a matter pertinent to the 22 litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a consulta23 in this action, (2) is not a past or current employee of a Party or of a Party’s competitor, and (3) at the tim24 of retention, is not anticipated to become an employee of a Party or of a Party’s competitor. 25 2.8 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or Items: 26 extremely sensitive “Confidential Information or Items,” disclosure of which to another Party or Non-Part27 would create a substantial risk of serious harm that could not be avoided by less restrictive means.

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2.9 INTENTIONALLY LEFT BLANK 1 2.10 House Counsel: attorneys who are employees of a party to this action. House Counsel do2 not include Outside Counsel of Record or any other outside counsel. 3 2.11 Non-Party: any natural person, partnership, corporation, association, or other legal entity 4 not named as a Party to this action. 5 2.12 Outside Counsel of Record: attorneys and their support staff who are not employees of a 6 party to this action but are retained to represent or advise a party to this action and have appeared in this 7 action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party. 8 2.13 Party: any party to this action, including all of its officers, directors, employees, consulta9 retained experts, and Outside Counsel of Record (and their support staffs). 10 2.14 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in 11 this action. 12 2.15 Professional Vendors: persons or entities that provide litigation support services (e.g., 13 photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or 14 retrieving data in any form or medium) and their employees and subcontractors. 15 2.16 Protected Material: any Disclosure or Discovery Material that is designated as 16 “CONFIDENTIAL,” or as “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 17 2.17 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing18 Party. 19 20 3. SCOPE The protections conferred by this Stipulation and Order cover not only Protected Material (as 21 defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, 22 excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or 23 presentations by Parties or their Counsel that might reveal Protected Material. However, the protections 24 conferred by this Stipulation and Order do not cover the following information: (a) any information that is25 the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain afte26 its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, includi27

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Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a sour1 who obtained the information lawfully and under no obligation of confidentiality to the Designating Party2 Any use of Protected Material at trial shall be governed by a separate agreement or order. 3 4. DURATION 4 Even after final disposition of this litigation, the confidentiality obligations imposed by this Order5 shall remain in effect until a Designating Party agrees otherwise in writing or a court order otherwise 6 directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this 7 action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all8 appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any moti9 or applications for extension of time pursuant to applicable law. 10 5. DESIGNATING PROTECTED MATERIAL 11 5.1 Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non12 Party that designates information or items for protection under this Order must take care to limit any such 13 designation to specific material that qualifies under the appropriate standards. To the extent it is practical 14 do so, the Designating Party must designate for protection only those parts of material, documents, items, 15 oral or written communications that qualify – so that other portions of the material, documents, items, or 16 communications for which protection is not warranted are not swept unjustifiably within the ambit of this 17 Order. 18 Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be19 clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily encumber or 20 retard the case development process or to impose unnecessary expenses and burdens on other parties) 21 expose the Designating Party to sanctions. 22 If it comes to a Designating Party’s attention that information or items that it designated for 23 protection do not qualify for protection at all or do not qualify for the level of protection initially asserted,24 that Designating Party must promptly notify all other parties that it is withdrawing the mistaken designati25 5.2 Manner and Timing of Designations. Except as otherwise provided in this Order (see, e.g26 second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or Discovery 27 Material that qualifies for protection under this Order must be clearly so designated before the

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material is disclosed or produced. 1 Designation in conformity with this Order requires: 2 (a) for information in documentary form (e.g., paper or electronic documents, but excludi3 transcripts of depositions or other pretrial or trial proceedings), that the Producing Party affix the legend 4 “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY to each page that 5 contains protected material. If only a portion or portions of the material on a page qualifies for protection,6 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate marki7 in the margins) and must specify, for each portion, the level of protection being asserted. If such measur8 are not practicable, the producing party shall designate the Disclosure or Discovery Materials as 9 Confidential or Highly Confidential through other feasible means. 10 A Party or Non-Party that makes original documents or materials available for inspection need no11 designate them for protection until after the inspecting Party has indicated which material it would like 12 copied and produced. During the inspection and before the designation, all of the material made available 13 for inspection shall be deemed “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” After the 14 inspecting Party has identified the documents it wants copied and produced, the Producing Party must 15 determine which documents, or portions thereof, qualify for protection under this Order. Then, before 16 producing the specified documents, the Producing Party must affix the appropriate legend 17 (“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to each page that 18 contains Protected Material. If only a portion or portions of the material on a page qualifies for protection,19 the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate marki20 in the margins) and must specify, for each portion, the level of protection being asserted. 21 (b) for testimony given in deposition or in other pretrial or trial proceedings, that the 22 Designating Party identify on the record, before the close of the deposition, hearing, or other proceeding, 23 protected testimony and specify the level of protection being asserted. When it is impractical to identify 24 separately each portion of testimony that is entitled to protection and it appears that substantial portions of25 the testimony may qualify for protection, the Designating Party may invoke on the record (before the 26 deposition, hearing, or other proceeding is concluded) a right to have up to 21 days to identify the specific27

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asserted. Only those portions of the testimony that are appropriately designated for protection within the 21 days shall be covered by the provisions of this Stipulated Protective Order. Alternatively, a Designating 2 Party may specify, at the deposition or up to 21 days afterwards if that period is properly invoked, that the3 entire transcript shall be treated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS4 EYES ONLY.” 5 Parties shall give the other parties notice if they reasonably expect a deposition, hearing or other 6 proceeding to include Protected Material so that the other parties can ensure that only authorized individu7 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) are present at those 8 proceedings. The use of a document as an exhibit at a deposition shall not in any way affect its designatio9 as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY.” 10 Transcripts containing Protected Material shall have an obvious legend on the title page that the 11 transcript contains Protected Material, and the title page shall be followed by a list of all pages (including 12 line numbers as appropriate) that have been designated as Protected Material and the level of protection 13 being asserted by the Designating Party. The Designating Party shall inform the court reporter of these 14 requirements. Any transcript that is prepared before the expiration of a 21-day period for designation shal15 be treated during that period as if it had been designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ 16 EYES ONLY” in its entirety unless otherwise agreed. After the expiration of that period, the transcript sh17 be treated only as actually designated. 18 (c) for information produced in some form other than documentary and for any other 19 tangible items, that the Producing Party affix in a prominent place on the exterior of the container or 20 containers in which the information or item is stored the legend “CONFIDENTIAL” or “HIGHLY 21 CONFIDENTIAL – ATTORNEYS’ EYES ONLY”. If only a portion or portions of the information or ite22 warrant protection, the Producing Party, to the extent practicable, shall identify the protected portion(s) an23 specify the level of protection being asserted. 24 5.3 Inadvertent Failures to Designate. If timely corrected, an inadvertent failure to designate 25 qualified information or items does not, standing alone, waive the Designating Party’s right to secure 26 protection under this Order for such material. Upon timely correction of a designation, the Receiving Part27

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Order. 1 2 6. CHALLENGING CONFIDENTIALITY DESIGNATIONS 6.1 Timing of Challenges. Any Party or Non-Party may challenge a designation of 3 confidentiality at any time. Unless a prompt challenge to a Designating Party’s confidentiality designation4 necessary to avoid foreseeable, substantial unfairness, unnecessary economic burdens, or a significant 5 disruption or delay of the litigation, a Party does not waive its right to challenge a confidentiality 6 designation by electing not to mount a challenge promptly after the original designation is disclosed. 7 6.2 Meet and Confer. The Challenging Party shall initiate the dispute resolution process by 8 providing written notice of each designation it is challenging and describing the basis for each challenge. 9 avoid ambiguity as to whether a challenge has been made, the written notice must recite that the challenge10 confidentiality is being made in accordance with this specific paragraph of the Protective Order. The parti11 shall attempt to resolve each challenge in good faith and must begin the process by conferring directly (in12 voice to voice dialogue; other forms of communication are not sufficient) within 14 days of the date of 13 service of notice. In conferring, the Challenging Party must explain the basis for its belief that the 14 confidentiality designation was not proper and must give the Designating Party an opportunity to review t15 designated material, to reconsider the circumstances, and, if no change in designation is offered, to explai16 the basis for the chosen designation. A Challenging Party may proceed to the next stage of the challenge 17 process only if it has engaged in this meet and confer process first or establishes that the Designating Part18 is unwilling to participate in the meet and confer process in a timely manner. 19 6.3 Judicial Intervention. If the Parties cannot resolve a challenge without court intervention, 20 the Designating Party shall file and serve a motion to retain confidentiality under the applicable rules and 21 procedures within 21 days of the initial notice of challenge or within 14 days of the parties agreeing that t22 meet and confer process will not resolve their dispute, whichever is earlier. Each such motion must be 23 accompanied by a competent declaration affirming that the movant has complied with the meet and confe24 requirements imposed in the preceding paragraph. Failure by the Designating Party to make such a motio25 including the required declaration within 21 days (or 14 days, if applicable) shall automatically waive the 26 confidentiality designation for each challenged designation. In addition, the Challenging Party may file a 27

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challenge to the designation of a deposition transcript or any portions thereof. Any motion brought pursua1 to this provision must be accompanied by a competent declaration affirming that the movant has complie2 with the meet and confer requirements imposed by the preceding paragraph. 3 The burden of persuasion in any such challenge proceeding shall be on the Designating Party. 4 Frivolous challenges and those made for an improper purpose (e.g., to harass or impose unnecessary 5 expenses and burdens on other parties) may expose the Challenging Party to sanctions. Unless the 6 Designating Party has waived the confidentiality designation by failing to file a motion to retain 7 confidentiality as described above, all parties shall continue to afford the material in question the level of 8 protection to which it is entitled under the Producing Party’s designation until the court rules on the 9 challenge. 10 11 7. ACCESS TO AND USE OF PROTECTED MATERIAL 7.1 Basic Principles. A Receiving Party may use Protected Material that is disclosed or 12 produced by another Party or by a Non-Party in connection with this case only for prosecuting, defending13 or attempting to settle this litigation. Such Protected Material may be disclosed only to the categories of 14 persons and under the conditions described in this Order. When the litigation has been terminated, a 15 Receiving Party must comply with the provisions of section 15 below (FINAL DISPOSITION). 16 Protected Material must be stored and maintained by a Receiving Party at a location and in a secu17 manner2 that ensures that access is limited to the persons authorized under this Order. 18 7.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the19 court or permitted in writing by the Designating Party, a Receiving Party may disclose any information or20 item designated “CONFIDENTIAL” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 22 said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this 23 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is attached heret24 as Exhibit A; 25 26 27 2 It may be appropriate under certain circumstances to require the Receiving Party to store any electronic Protected Materiapassword-protected form.

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(b) the officers, directors, and employees (including House Counsel) of the Receiving Par1 to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment2 and Agreement to Be Bound” (Exhibit A); 3 (c) Experts (as defined in this Order) of the Receiving Party to whom disclosure is 4 reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be 5 Bound” (Exhibit A); 6 (d) the court and its personnel; 7 (e) court reporters and their staff, professional jury or trial consultants, and Professional 8 Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the 9 “Acknowledgment and Agreement to Be Bound” (Exhibit A); 10 (f) during their depositions, witnesses in the action to whom disclosure is reasonably 11 necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless 12 otherwise agreed by the Designating Party or ordered by the court. Pages of transcribed deposition 13 testimony or exhibits to depositions that reveal Protected Material must be separately bound by the court 14 reporter and may not be disclosed to anyone except as permitted under this Stipulated Protective Order. 15 (g) the author or recipient of a document containing the information or a custodian or oth16 person who otherwise possessed or knew the information. 17 7.3 Disclosure of “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY Information 18 Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, a Receivin19 Party may disclose any information or item designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ 20 EYES ONLY” only to: 21 (a) the Receiving Party’s Outside Counsel of Record in this action, as well as employees 22 said Outside Counsel of Record to whom it is reasonably necessary to disclose the information for this 23 litigation and who have signed the “Acknowledgment and Agreement to Be Bound” that is attached heret24 as Exhibit A; 25 (b) INTENTIONALLY LEFT BLANK 26 (c) Experts of the Receiving Party (1) to whom disclosure is reasonably necessary for this27

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to whom the procedures set forth in paragraph 7.4(a)(2), below, have been followed]; 1 (d) the court and its personnel; 2 (e) court reporters and their staff, professional jury or trial consultants,3 and Professional 3 Vendors to whom disclosure is reasonably necessary for this litigation and who have signed the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A); and 5 (f) the author or recipient of a document containing the information or a custodian or othe6 person who otherwise possessed or knew the information. 7 7.4 Procedures for Approving or Objecting to Disclosure of “HIGHLY CONFIDENTIAL – 8 ATTORNEYS’ EYES ONLY” Information or Items to Experts. 9 (a)(1) INTENTIONALLY LEFT BLANK 10 (a)(2) Unless otherwise ordered by the court or agreed to in writing by the Designating 11 Party, a Party that seeks to disclose to an Expert (as defined in this Order) any information or item that ha12 been designated “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” pursuant to paragraph 13 7.3(c) first must make a written request to the Designating Party that (1) identifies the general categories 14 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information that the Receiving Party seek15 permission to disclose to the Expert, (2) sets forth the full name of the Expert and the city and state of his 16 her primary residence, (3) attaches a copy of the Expert’s current resume, (4) identifies the Expert’s curre17 employer(s), (5) identifies each person or entity from whom the Expert has received compensation or 18 funding for work in his or her areas of expertise or to whom the expert has provided professional services,19 including in connection with a litigation, at any time during the preceding five years, and (6) identifies (b20 name and number of the case, filing date, and location of court) any litigation in connection with which th21 Expert has offered expert testimony, including through a declaration, report, or testimony at a deposition 22 trial, during the preceding five years.4 23 24 25 3 Alternative: The parties may wish to allow disclosure of information not only to professional jury or trial consultants, but also tmock jurors, to further trial preparation. In that situation, the parties may wish to draft a simplified, precisely tailored Undertakin26 for mock jurors to sign. 4 It may be appropriate in certain circumstances to restrict the Expert from undertaking certain limited work prior to the terminati27 of the litigation that could foreseeably result in an improper use of the Designating Party’s “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” information.

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(b) A Party that makes a request and provides the information specified in the preceding 1 respective paragraphs may disclose the subject Protected Material to the identified Expert unless, within 12 business day of delivering the request, the Party receives a written objection from the Designating Party. 3 Any such objection must set forth in detail the grounds on which it is based. 4 (c) A Party that receives a timely written objection must meet and confer with the 5 Designating Party (through direct voice to voice dialogue) to try to resolve the matter by agreement withi6 seven days of the written objection. If no agreement is reached, the Party seeking to make the disclosure t7 the Expert may file a motion as provided in Civil Local Rule 7 (and in compliance with Civil Local Rule 8 5, if applicable) seeking permission from the court to do so. Any such motion must describe the 9 circumstances with specificity, set forth in detail the reasons why the disclosure to the Expert is reasonabl10 necessary, assess the risk of harm that the disclosure would entail, and suggest any additional means that 11 could be used to reduce that risk. In addition, any such motion must be accompanied by a competent 12 declaration describing the parties’ efforts to resolve the matter by agreement (i.e., the extent and the conte13 of the meet and confer discussions) and setting forth the reasons advanced by the Designating Party for its14 refusal to approve the disclosure. 15 In any such proceeding, the Party opposing disclosure to the Expert shall bear the burden of provi16 that the risk of harm that the disclosure would entail (under the safeguards proposed) outweighs the 17 Receiving Party’s need to disclose the Protected Material to its Designated House Counsel or Expert. 18 19 8. INTENTIONALLY LEFT BLANK 20 9. INTENTIONALLY LEFT BLANK 21 10. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN OTHER LITIGATION 22 If a Party is served with a subpoena or a court order issued in other litigation that compel23 disclosure of any information or items designated in this action as “CONFIDENTIAL” or “HIGHLY 24 CONFIDENTIAL – ATTORNEYS’ EYES ONLY” that Party must: 25 (a) promptly notify in writing the Designating Party. Such notification shall include a cop26 of the subpoena or court order; 27 (b) promptly notify in writing the party who caused the subpoena or order to issue in the

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other litigation that some or all of the material covered by the subpoena or order is subject to this Protecti1 Order. Such notification shall include a copy of this Stipulated Protective Order; and 2 (c) cooperate with respect to all reasonable procedures sought to be pursued by the 3 Designating Party whose Protected Material may be affected.5 4 If the Designating Party timely seeks a protective order, the Party served with the subpoe5 or court order shall not produce any information designated in this action as “CONFIDENTIAL” or 6 “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY” before a determination by the court from 7 which the subpoena or order issued, unless the Party has obtained the Designating Party’s permission. Th8 Designating Party shall bear the burden and expense of seeking protection in that court of its confidential 9 material – and nothing in these provisions should be construed as authorizing or encouraging a Receiving 10 Party in this action to disobey a lawful directive from another court. 11 12 11. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED IN THIS LITIGATION 13 (a) The terms of this Order are applicable to information produced by a Non-Party in14 this action and designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EY15 ONLY”. Such information produced by Non-Parties in connection with this litigation is protected by the 16 remedies and relief provided by this Order. Nothing in these provisions should be construed as prohibitin17 Non-Party from seeking additional protections. 18 (b) In the event that a Party is required, by a valid discovery request, to produce a No19 Party’s confidential information in its possession, and the Party is subject to an agreement with the Non-20 Party not to produce the Non-Party’s confidential information, then the Party shall: 21 1. promptly notify in writing the Requesting Party and the Non-Party that some or a22 of the information requested is subject to a confidentiality agreement with a Non-Party; 23 2. promptly provide the Non-Party with a copy of the Stipulated Protective Order in24 this litigation, the relevant discovery request(s), and a reasonably specific description of the information 25 26 5 The purpose of imposing these duties is to alert the interested parties to the existence of this Protective Order and to afford the 27 Designating Party in this case an opportunity to try to protect its confidentiality interests in the court from which the subpoena or order issued.

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requested; and 1 3. make the information requested available for inspection by the Non-Party. 2 3 (c) If the Non-Party fails to object or seek a protective order from this court within 14 days of receivithe notice and accompanying information, the Receiving Party may produce the Non-Party’s 4 confidential information responsive to the discovery request. If the Non-Party timely seeks a protective order, the Receiving Party shall not produce any information in its possession or contro5 that is subject to the confidentiality agreement with the Non-Party before a determination by the court.6 Absent a court order to the contrary, the Non-Party shall bear the burden and expense of 6 seeking protection in this court of its Protected Material.INTENTIONALLY LEFT BLANK 7 12. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed Protected 8 Material to any person or in any circumstance not authorized under this Stipulated Protective Order, the 9 Receiving Party must immediately (a) notify in writing the Designating Party of the unauthorized 10 disclosures, (b) use its best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform11 the person or persons to whom unauthorized disclosures were made of all the terms of this Order, and (d) 12 request such person or persons to execute the “Acknowledgment and Agreement to Be Bound” that is 13 attached hereto as Exhibit A. 14 15 13. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL 16 The Parties agree that any production of documents or information that is subject to a clai17 of privilege or protection is and will be inadvertent, and subject to claw back. When a Producing Party 18 gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of 19 privilege or other protection, the obligations of the Receiving Parties are those set forth in Federal Rule of20 Civil Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure may be 21 established in an e-discovery order that provides for production without prior privilege review. Pursuant t22 Federal Rule of Evidence 502(d) and (e), insofar as the parties reach an agreement on the effect of 23 disclosure of a communication or information covered by the attorney-client privilege or work product 24 protection, the parties may incorporate their agreement in the stipulated protective order submitted to the 25 court. 26 27

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14. MISCELLANEOUS 1 14.1 Right to Further Relief. Nothing in this Order abridges the right of any person to seek its 2 modification by the court in the future. 3 14.2 Right to Assert Other Objections. By stipulating to the entry of this Protective Order no 4 Party waives any right it otherwise would have to object to disclosing or producing any information or ite5 on any ground not addressed in this Stipulated Protective Order. Similarly, no Party waives any right to 6 object on any ground to use in evidence of any of the material covered by this Protective Order. 7 14.3 Export Control. Disclosure of Protected Material shall be subject to all applicable laws and 8 regulations relating to the export of technical data contained in such Protected Material, including the 9 release of such technical data to foreign persons or nationals in the United States or elsewhere. The 10 Producing Party shall be responsible for identifying any such controlled technical data, and the Receiving 11 Party shall take measures necessary to ensure compliance.]14.4 Filing Protected Material. Without writt12 permission from the Designating Party or a court order secured after appropriate notice to all interested 13 persons, a Party may not file in the public record in this action any Protected Material. A Party that seeks 14 file under seal any Protected Material must comply with Civil Local Rule 79-5. Protected Material may o15 be filed under seal pursuant to a court order authorizing the sealing of the specific Protected Material at 16 issue. Pursuant to Civil Local Rule 79-5, a sealing order will issue only upon a request establishing that th17 Protected Material at issue is privileged, protectable as a trade secret, or otherwise entitled to protection 18 under the law. If a Receiving Party's request to file Protected Material under seal pursuant to Civil Local 19 Rule 79-5(e) is denied by the court, then the Receiving Party may file the Protected Material in the public 20 record pursuant to Civil Local Rule 79-5(e)(2) unless otherwise instructed by the court. 21 15. FINAL DISPOSITION 22 Within 60 days after the final disposition of this action, as defined in paragraph 4, each 23 Receiving Party must return all Protected Material to the Producing Party or destroy such material. As use24 in this subdivision, “all Protected Material” includes all copies, abstracts, compilations, summaries, and a25 other format reproducing or capturing any of the Protected Material. Whether the Protected Material is 26 returned or destroyed, the Receiving Party must submit a written certification to the Producing Party (and,27 not the same person or entity, to the Designating Party) by the 60-day deadline that (1) identifies (by

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category, where appropriate) all the Protected Material that was returned or destroyed and (2) affirms that1 the Receiving Party has not retained any copies, abstracts, compilations, summaries or any other format 2 reproducing or capturing any of the Protected Material. Notwithstanding this provision, Counsel are entitl3 to retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts, legal 4 memoranda, correspondence, deposition and trial exhibits, expert reports, attorney work product, and 5 consultant and expert work product, even if such materials contain Protected Material. Any such archival 6 copies that contain or constitute Protected Material remain subject to this Protective Order as set forth in 7 Section 4 (DURATION). 8 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 9 10 11 DATED: January 15, 2021 SEVERSON & WERSON 12 A Professional Corporation 13 14 By: /s/ Bernard J. Kornberg 15 BERNARD J. KORNBERG 16 Attorneys for Prestige Century Investments Limited a CIP United Co. Ltd. 17 18 19 20 DATED: January 15, 2021 SIDLEY AUSTIN LLP 21 22 23 By: /s/ Eric Schwartz Eric Schwartz 24 Attorneys for Debtors and Debtors in Possession 25 26 27

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EXHIBIT A 1 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 I, _____________________________ [print or type full name], of _________________ 3 [print or type full address], declare under penalty of perjury that I have read in its entirety and understand 4 the Stipulated Protective Order that was issued by the United States District Court for the Northern Distri5 of California on [date] in the case of ___________ [insert formal name of the case and the number an6 initials assigned to it by the court]. I agree to comply with and to be bound by all the terms of this 7 Stipulated Protective Order and I understand and acknowledge that failure to so comply could expose me 8 sanctions and punishment in the nature of contempt. I solemnly promise that I will not disclose in any 9 manner any information or item that is subject to this Stipulated Protective Order to any person or entity 10 except in strict compliance with the provisions of this Order. 11 I further agree to submit to the jurisdiction of the United States District Court for the 12 Northern District of California for the purpose of enforcing the terms of this Stipulated Protective Order, 13 even if such enforcement proceedings occur after termination of this action. 14 I hereby appoint __________________________ [print or type full name] of 15 _______________________________________ [print or type full address and telephone number] as my 16 California agent for service of process in connection with this action or any proceedings related to 17 enforcement of this Stipulated Protective Order. 18 19 Date: _________________________________ 20 City and State where sworn and signed: _________________________________ 21 22 Printed name: ______________________________ [printed name] 23 Signature: __________________________________ 24 [signature] 25 26 27

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PROOF OF SERVICE 1 At the time of service, I was over 18 years of age and not a party to this action. I am 2 employed in the County of San Francisco, State of California. My business address is One Embarcadero Center, Suite 2600, San Francisco, CA 94111. 3 On January 15, 2021, I served true copies of the following document(s): 4 STIPULATED PROTECTIVE ORDER FOR LITIGATION INVOLVING 5 PATENTS, HIGHLY SENSITIVE CONFIDENTIAL INFORMATION AND/OR TRADE SECRETS 6 on the interested parties in this action as follows: 7 8 BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed the 9 document(s) with the Clerk of the Court by using the CM/ECF system. Participants in the case who are registered CM/ECF users will be served by the CM/ECF system. Participants in the cas10 who are not registered CM/ECF users will be served by mail or by other means permitted by the court rules. 11 I declare under penalty of perjury under the laws of the United States of America that the 12 foregoing is true and correct and that I am employed in the office of a member of the bar of this Court at whose direction the service was made. 13 Executed on January 15, 2021, at San Francisco, California. 14 15 /s/ Bernard J. Kornberg 16 Bernard J. Kornberg 17 18 19 20 21 22 23 24 25 26 27