GEORGE HOTZ’S MOTION FOR PROTECTIVE ORDER
Now Comes Defendant George Hotz, by and through counsel, and moves this Court for Protective Order pursuant to Federal Rules of Civil Procedure Rule 26(c) and FRCP 26(b)(2)(c), seeking to protect Defendant George Hotz from Plaintiff Sony Computer Entertainment LLC‟s (“SCEA”) overbroad jurisdictional discovery requests, which are for the purpose of annoyance, embarrassment, oppression, and are an undue burden and undue expense on Defendant. Please note that this Motion is in addition to the Joint Protective Order, which is currently being drafted with Plaintiff’s counsel.

PRELIMINARY STATEMENT
Mr. Hotz is a 21-year-old individual, who resides in New Jersey and who has not consented to the jurisdiction of this Court. Despite the fact that SCEA has filed this action and represented that this matter belongs in the Northern District of California, SCEA now attempts to engage in a jurisdictional fishing expedition as a means to utilize jurisdictional discovery to achieve other ends. Although the Court has limited discovery to jurisdictional issues, SCEA has demanded overly burdensome and expensive discovery from Plaintiffs that bears little, if any, relevance to the issues at hand.
The Defendant has shown good cause for the protective order sought herein, as the discovery SCEA seeks is harassing, irrelevant, burdensome, expensive, and intrusive. In addition, the confidential information sought to be protected could cause Defendant irreparable harm if mishandled or exposed.
Mr. Hotz is not seeking to withhold information from Plaintiff. Instead, Mr. Hotz seeks only to (1) protect the information he is willingly providing by directing that the copy of his hard drive be created as-is and unaltered, and (2) relieve the undue burden and expense of appearing in this forum for a deposition where Mr. Hotz will gladly offer the same information through written deposition. Mr. Hotzhas been extremely accommodating to SCEA’s demanding requests– being responsive to questions and inquiries at all hours of the day and night, providing his personal hard drive with commercial, confidential, and valuable information so that SCEA can determine that nothing pertaining to jurisdiction resides on such drive, turning over his Playstation Computer, and remaining accessible despite the fact that he is not in the forum.
Mr. Hotz files this Motion for a Protective Order to limit the issues at hand to the matters of jurisdiction, and to limit such discovery to less burdensome means. The protection Defendant seeks would prevent irreparable harm and undue burden on Defendant, while still granting SCEA the information it seeks to discover, without any burden.

Idk, I think the public opinion definitely isn't in $ony's favor, my friends' have always been major fanboys, they don't even hack, but they are pissed off by the lawsuits, they're saying it's unnecessary corporate greed, not to mention lawyers who know nothing about the PS3 console...

your friends and a hacking forum constitutes public opinion? Are you stupid? This is bigger than Geohot and bigger than Sony and the implications reach all platforms and consoles. Think about it this way.

If Sony wins the case then hacking take a major blow because new laws will come out which will infringe on peoples current rights and make it very difficult for people to do what they want with firmware.

If Geohot wins, then there will be laws that make hacking legal and the PS3 will be finished as everyone and their mother will cfw their ps3. The ps3 community knows how to use the internet and transferring some files over is a piece of cake for most of them. This will trickle down to other consoles and will in turn make many many many consumers mad.

You have to realize that ~95-99% of console users do not care abt cfw or jailbreak. People also need to realize that most corporations do not care about it either. It is only when leechers and other people spread the hack and exploit it to the full that this becomes an issue.

No matter who wins this case, consumers are going to be hurt.

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