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`Paper 39
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`Filed on behalf of: CRS Advanced Technologies, Inc.
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`By: E. Robert Yoches, Reg. No. 30,120
`Darrel C. Karl, pro hac vice
`
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`Aaron J. Capron, Reg. No. 56,170
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`Finnegan, Henderson, Farabow,
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` Garrett & Dunner, LLP
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`901 New York Avenue, N.W.
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`Washington, D.C. 20001-4413
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`Phone: (202) 408-4000
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`Fax: (202) 408-4400
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
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`CRS ADVANCED TECHNOLOGIES, INC.,
`Petitioner,
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`v.
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`Patent of FRONTLINE TECHNOLOGIES, INC.,
`Patent Owner.
`_______________
`
`Case CBM2012-00005
`Patent 6,675,151C1
`_______________
`
`
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`PETITIONER CRS ADVANCED TECHNOLOGIES, INC.’S
`MOTION TO FILE DOCUMENTS UNDER SEAL
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`
`
`Case CBM2012-00005
`Patent 6,675,151C1
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`
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`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I.
`
`Relief Requested
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`Pursuant to 37 C.F.R. § 42.14, Petitioner CRS Advanced Technologies, Inc.
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`(“CRS”) hereby requests permission to file its Petitioner CRS Advanced
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`Technologies, Inc.’s Reply to Patent Owner’s Response Pursuant to 37 C.F.R. §
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`42.220 (“Reply”) and selected exhibits, due on May 20, 2013, under seal. The
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`parties have agreed that the Protective Order (CRS Ex. 1018) previously entered by
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`the District Court governs the treatment of confidential materials before the Patent
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`Trial and Appeal Board (the “Board”).
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`II.
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`Statement of Facts Showing There is Good Cause for the Board to
`Allow the Filing Under Seal
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`In accordance with Paragraph 15 of the Protective Order (CRS Exh. 1018),
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`“all transcripts of depositions, exhibits, answers to interrogatories, pleadings,
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`briefs, and other documents submitted . . . that have been designated as
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`CONFIDENTIAL INFORMATION or that contain information so designated,
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`shall be filed (or otherwise submitted) under seal.”
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`CRS’s Reply includes documents and information designated by Patent
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`Owner under the Protective Order as “CONFIDENTIAL.” More specifically,
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`CRS’s Reply and selected exhibit being filed concurrently with the Reply include a
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`2
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`deposition transcript (CRS Ex. 1015) and a license agreement involving the patent
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`Case CBM2012-00005
`Patent 6,675,151C1
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`at issue in this proceeding (CRS Ex. 1016), that have been designated by Patent
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`Owner under the Protective Order as “CONFIDENTIAL.”
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`Petitioner CRS submits that Patent Owner’s designation of these materials as
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`“CONFIDENTIAL” under the Protective Order constitutes good cause for the
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`Board to allow the filing under seal pursuant to 37 C.F.R. § 42.14.
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`III. Conclusion
`For the foregoing reasons, Petitioner CRS respectfully requests that the
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`Board enter the proposed Protective Order, grant this motion, and permit the filing
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`of its Reply to Patent Owner’s Response Pursuant to 37 C.F.S. § 42.220 and
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`selected exhibits under seal. A public, non-confidential version of CRS’s Reply is
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`being separately filed with the Board.
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`3
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`Dated: May 20, 2013
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`Respectfully submitted,
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`Case CBM2012-00005
`Patent 6,675,151C1
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`
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`
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`By: /s/ Aaron J. Capron
`E. Robert Yoches, Reg. No. 30,120
`Darrel C. Karl, pro hac vice
`Aaron J. Capron, Reg. No. 56,170
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, LLP
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Phone: (202) 408-4000
`Fax: (202) 408-4400
`
`Attorneys for Petitioner
`CRS Advanced Technologies, Inc..
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`4
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`CERTIFICATE OF SERVICE
`I hereby certify that on this 20th day of May, 2013, a true and correct copy of
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`Case CBM2012-00005
`Patent 6,675,151C1
`
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`the foregoing PETITIONER CRS ADVANCED TECHNOLOGIES, INC.’S
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`MOTION TO FILE DOCUMENTS UNDER SEAL was served, in accordance
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`with the parties’ electronic service agreement, by electronic mail upon the
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`following lead and backup counsel of record for Patent Owner Frontline
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`Technologies, Inc.:
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`John P. Donohue, Jr., Lead Counsel
`Woodcock Washburn, LLP
`Cira Centre – 12th Floor
`2929 Arch Street
`Philadelphia, PA 19103
`Phone: 215.568.3100
`Fax: 215.568.3439
`Email: donohue@woodcock.com
`
`John E. McGlynn, Back-up Counsel
`Woodcock Washburn, LLP
`Cira Centre – 12th Floor
`2929 Arch Street
`Philadelphia, PA 19104
`Phone: 215.564.8382
`Fax: 215.568.3439
`Email: mcglynn@woodcock.com
`
`R. Scott Tewes
`Tewes Law Group LLC
`Sugarloaf Corporate Center
`2180 Satellite Blvd., Suite 400
`Duluth, GA 30097
`STewes@TewesLaw.com
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`5
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`Case CBM2012-00005
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`Patent 6,675,151C1
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`
`/s/ Jacob Mersing
`Jacob Mersing
`Legal Assistant
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, LLP
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`6
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