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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