3m vs Envisionware: Plaintiffs' memorandum in support of a motion for a protective order
United States District Court District of Minnesota
Abstract: The parties have reached agreement on almost every provision of a proposed protective order in this case. However, 3M is forced to bring this motion for entry of its version of the protective order because EnvisionWare has refused to agree that 3M litigation managers Kevin Rhodes and Hildy Bowbeer can have access to Attorneys’ Eyes Only information under a proposed protective order. EnvisionWare makes this objection even though judges in the District of Minnesota have repeatedly ruled in prior patent cases that Mr. Rhodes and Ms. Bowbeer —and other 3M lawyers in the same situation—can have access to such information.