That's not how litigation works. If SimulaVR wants protection, it has to ask for it. SimulaVR has the right to ask 1) Meta and 2) the court to limit the scope

That's not how litigation works. If SimulaVR wants protection, it has to ask for it. SimulaVR has the right to ask 1) Meta and 2) the court to limit the scope of the subpoena and to set conditions on the review and distribution of the production. If Meta agrees to the conditions, great, the agreement can either be informal, or incorporated into an order for the judge to sign. If Meta is opposed, SimulaVR gets to make their case to the judge and let him decide scope and protective order details.