The proponent of a protective order has the burden to show good cause for its entry, as per Rule 26. Some courts are requiring that the party seeking a prosecution bar establish that the other side's counsel is engaged in "competitive decision-making." E.g., Clayton Corp. v. Momentive Performance Materials, Inc., 2013 WL 2099436 (E.D. Mo. May 14, 2013).
That is unworkable. In Clayton, the court denied a bar because the lawyers seeking it didn't submit affidavits showing what opposing counsel was doing for their client.
How could they?
It seems a much better approach is to place the burden of showing that the information being disclosed is "important enough" to warrant a bar, and, if the opposing party objects to inclusion of a prosecution bar, to require them to establish that they are *not* engaged in competitive decision-making.