UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION

FEDERAL TRADE COMMISSION, CASE NO. 4:14-cv-00815-BCW
Plaintiff,
V.

BF LABS, INC., et al.

Defendants.

STIPULATED MOTION FOR ENTRY OF PROTECTIVE ORDER
Plaintiff Federal Trade Commission (“FTC”) respectfully moves the Court pursuant to

Federal Rule of Civil Procedure 26(c) to enter the proposed Protective Order attached hereto as
Exhibit 1. Defendants BF Labs, Inc., Sonny Vleisides, and Darla Drake, stipulate to its entry.
Defendant Nasser Ghoseiri does not oppose entry of the protective order and has agreed to abide
by it. The proposed protective order, as described in the Joint Proposed Discovery Plan And
Scheduling Order (DE #209), protects the interests of the parties and third parties against improper
use and disclosure of confidential information, which is limited to sensitive personal information or
trade secrets or other confidential research, development, or commercial information.

Respectfully submitted,

JONATHAN E. NUECHTERLEIN

General Counsel
Dated: April 20, 2015 /s/ Leah Frazier

Helen Wong, DC Bar # 997800

Leah Frazier, DC Bar# 492540

Gregory A. Ashe, VA Bar #39131
Jason Adler, IL Bar # 6295738

Case 4:14-cv-00815-BCW Document 294 Filed 04/20/15 Page 1 of 3

Federal Trade Commission
600 Pennsylvania Ave., N.W.
Mail Stop CC-10232
Washington, D.C. 20580
202-326-3779 (Wong)
202-326-2187 (Frazier)
202-326-3719 (Ashe)
202-326-3231 (Adler)
Facsimile: 202-326-3768
hwong @ftc.gov

Ifrazier @ftc.gov

gashe @ftc.gov

jadler @ ftc.gov

TAMMY DICKINSON
United States Attorney

Dated: April 20, 2015 /s/ Charles M. Thomas
Charles M. Thomas, MO Bar #28522
Assistant United States Attorney
Charles Evans Whittaker Courthouse
400 East Ninth Street, Room 5510
Kansas City, MO 64106
Telephone: (816) 426-3130
Facsimile: (816) 426-3165
E-mail: charles.thomas @usdoj.gov

Attorneys for Plaintiff
FEDERAL TRADE COMMISSION

Z

Case 4:14-cv-00815-BCW Document 294 Filed 04/20/15 Page 2 of 3

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on April 20, 2015, a true and correct copy of
the foregoing was filed electronically with the United States District Court for the Western
District of Missouri using the CM/ECF system, which sent notification to all parties of interest
participating in the CM/ECF system.

/s/ Leah Frazier
Attorney for Plaintiff Federal Trade Commission

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