Like what you posted, there has to be "Good Cause" shown for a Protective Order to issue e.

The fact they only cite their opinion that idiscovery costs may eceed the "Vaue" of the claim by EDIG is mere OPINION and is insufficient as "Good Cause"...

They must do better than that...

For example, they have to show EDIG is out to VEX through bombarding them through repeated discovery reqests for irrelevancies, immaterial items, and dated material that is impossible to produce...

At least we know we are going to the Markman Hearing, as here is when the defense cranks up the billing. Because their request for PROTECTIVE ORDER is down right silly, if framed without anyything more that "it is going to cost us a lot, may be more than the claim is worth.". As proposed it shall be denied by Jduge krieger...

Gil...