In the ongoing Apple v. Samsung, Nos. 11-1846, 12- 80275, slip op. (N.D. Cal. Oct. 3, 2013), patent litigation in the U.S. District Court for the Northern District of California, the court is considering a sanctions motion against Samsung for allegedly violating a protective order entered in the case to protect competitive information. Apple and third parties contend that Samsung’s outside counsel shared their “attorneys’ eyes only” information with Samsung business people, primarily by failing to electronically redact the information where it appeared in an expert report provided to the Samsung business people. A Samsung executive then allegedly raised the confidential information in a separate business negotiation. In an October 3, 2013 order outlining the issues, the court explained the importance of obeying and enforcing protective orders: “a casual observer might reasonably wonder what magic a protective order works that allows outside counsel access to confidential information to advance the case without countenancing untoward uses by the client. The answer is not a magical one at all: confidential information remains confidential because counsel and clients alike follow court orders. If parties breach this basic rule, the court’s assurances become meaningless.” In a subsequent November 8, 2013 order, after further review of documentary evidence, the court held “it appears . . . that sanctions against Samsung and its attorneys are warranted” for breaches of the protective order. The court ordered Samsung and its counsel to show cause as to why sanctions should not issue. The court’s consideration of sanctions is ongoing.