Axelrod et al v. Lenovo (United States) Inc.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
United States District Court
Northern District of California
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
ANDREW AXELROD, et al.,
Plaintiffs,
v.
LENOVO (UNITED STATES) INC.,
Defendant.
Case No. 21-cv-06770-JSW
ORDER GRANTING INJUNCTION RE
ALLEGED VIOLATIONS OF
PROTECTIVE ORDER AND SETTING
STATUS HEARING
Re: Dkt. Nos. 455, 467
On August 10, 2026, the Court granted the parties’ joint motion for a temporary restraining
order (“TRO”) against Mohammad Waqqad regarding his alleged violations of the Protective
Order entered in this matter. (Dkt. 455.) On August 14, 2026, the Court held a hearing on the
parties’ request. Mr. Waqqad did not appear, and the Court extended the TRO and set a further
hearing for September 4, 2026, to consider whether Mr. Waqqad should be held in contempt of the
Protective Order.
The parties appeared on September 4, 2026. Mr. Waqqad did not appear. The Court
concludes the parties have shown that the injunction should be made permanent as there is a
continued threat that Lenovo’s confidential information may be misused. However, at this stage
the record does not show clear and convincing evidence that Mr. Waqqad has disclosed or used
the information he received in violation of the terms of the Protective Order.
Accordingly, it is HEREBY ORDERED:
PART ONE: PERMANENT INJUNCTION:
Mohammed Waqqad, Badreddine Meghirbi, and all persons acting in active concert or
participation with Mr. Waqqad by for instance reviewing, copying, accessing, selling, or buying
Lenovo’s confidential records, who receive actual notice of this Order, are immediately,
Case 4:21-cv-06770-JSW Document 482 Filed 09/04/26 Page 1 of 4

2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
United States District Court
Northern District of California
permanently RESTRAINED AND ENJOINED from
1. 	Selling, transferring, conveying, licensing, pledging, or hypothecating, any
materials produced by Lenovo in this action that were designated as Confidential or Highly
Confidential – Attorneys’ Eyes Only pursuant to the Protective Order entered in this action on
May 30, 2023 [Dkt. 54] (the “Protective Order”), or any copies, summaries, extracts, analyses, or
derivatives thereof, in any form or medium, whether electronic, physical, or otherwise
(collectively, “Lenovo’s Protected Materials”) and from or otherwise disposing of, in whole or in
part Lenovo’s Protected Materials except in strict conformance with Part Four of this Order
(Destruction of Lenovo’s Protected Materials”);
2. 	Disclosing, publishing, disseminating, communicating, or transmitting any of
Lenovo’s Protected Materials, or the substance or contents thereof, to any person or entity not
authorized to receive such materials under the Protective Order;
3. 	Using any of Lenovo’s Protected Materials, or the information contained therein,
for any purpose other than as may be specifically authorized by further order of this Court; and
4. 	Destroying, altering, concealing, or otherwise disposing of any of Lenovo’s
Protected Materials or any records reflecting the identity of persons or entities to whom any of
Lenovo’s Protected Materials have been disclosed, transferred, or provided, except in strict
conformance with Part Four of this Order.
PART TWO: DEPOSITION OF MR. WAQQAD
IT IS FURTHER ORDERED that, Mr. Waqqad shall appear for deposition by October 5,
2026, or such reasonable time thereafter as the parties and Mr. Waqqad agree. This deposition
will cover, inter alia, the extent of Mr. Waqqad’s alleged violations of the Protective Order and
TRO, and any remediation taken by Mr. Waqqad.
PART THREE: MANDATORY DISCLOSURE AND CERTIFICATION
IT IS FURTHER ORDERED that, no later than October 5, 2026, Mr. Waqqad shall submit
to this Court a sworn declaration, signed under penalty of perjury, that includes each of the
following:
1. 	Status of Materials. A statement identifying each and every device, account,
Case 4:21-cv-06770-JSW Document 482 Filed 09/04/26 Page 2 of 4

3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
United States District Court
Northern District of California
storage medium, cloud service, or other location, whether physical or electronic, in which any of
Lenovo’s Protected Materials are currently stored, maintained, or accessible by Mr. Waqqad or
any person acting at his direction;
2. 	Prior Disclosures. The identity of each and every person or entity to whom Mr.
Waqqad has disclosed, transferred, provided access to, sold, or transmitted any of Lenovo’s
Protected Materials at any time, including the date of each such disclosure or transfer, the nature
and description of the materials disclosed or transferred, and the means by which the disclosure or
transfer was made;
3. 	Confirmation of No Further Disclosure. A statement confirming that, since the
time of service of this Order, Mr. Waqqad has not disclosed, transferred, sold, or transmitted any
of Lenovo’s Protected Materials to any person or entity; and
4. 	Compliance with Restraints. A statement confirming Mr. Waqqad’s understanding
of and compliance with the restraints imposed by this Order.
PART FOUR: DESTRUCTION OF LENOVO’S PROTECTED MATERIALS
IT IS FURTHER ORDERED that Mr. Waqqad shall fully and finally destroy all copies of
Lenovo’s Protected Materials taking whatever steps necessary to destroy the materials (in
whatever format they may be held, including in digital repositories) such that they are not capable
of being restored. Mr. Waqqad shall provide confirmation from an independent third party that all
copies of Lenovo’s Protected Materials in his possession have been fully and finally destroyed.
PART FIVE: RETENTION OF JURISDICTION
IT IS FURTHER ORDERED that this Court retains jurisdiction over Mr. Waqqad (and
Mr. Meghirbi, as applicable) for all purposes related to the enforcement of the permanent
injunction issued herein and any other part of this Order.
The parties shall serve a copy of this Order on Mr. Waqqad (and Mr. Meghirbi as
applicable) by the means set forth in the TRO.
The Court advises Mr. Waqqad that failure to appear for deposition or to comply with the
terms of this Order may result in the Court holding him in contempt in his absence based on the
violations set forth in the TRO and any additional violations that may come to the attention of the
Case 4:21-cv-06770-JSW Document 482 Filed 09/04/26 Page 3 of 4

4
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
United States District Court
Northern District of California
Court.
The Court further advises Mr. Waqqad that information about proceeding without a lawyer
may be found on the Court’s website: https://cand.uscourts.gov at the “Representing Yourself”
tab.
IT IS FURTHER ORDERED that the parties shall appear for a status hearing on October
30, 2026, at 9:00 a.m. by Zoom webinar. The Court will convert that status conference to a
contempt hearing as needed. If a motion for contempt sanctions is not filed, the parties shall file a
joint status report by October 23, 2026.
IT IS SO ORDERED.
Dated: September 4, 2026
______________________________________
JEFFREY S. WHITE
United States District Judge
Case 4:21-cv-06770-JSW Document 482 Filed 09/04/26 Page 4 of 4