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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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`SAMSUNG ELECTRONICS AMERICA, INC. and
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
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`v.
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`SMARTFLASH LLC,
`Patent Owner
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`Case CBM2014-00190
`Patent 7,334,720
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`PETITIONER’S OPPOSITION TO
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`PATENT OWNER’S MOTION TO SEAL
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`Case CBM2014-00190
`Attorney Docket No: 39843-0003CP1
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`Pursuant to 37 C.F.R. §§ 42.54 and 42.23, Petitioner, SAMSUNG
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`ELECTRONICS AMERICA, INC. and SAMSUNG ELECTRONICS CO., LTD.
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`(“Petitioner”), hereby submits its Opposition to the Motion to Seal submitted by
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`SMARTFLASH LLC (“Patent Owner”), on June 1, 2015 in connection with
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`CBM2014-00190.
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`In its Motion to Seal, Patent Owner requested that Exhibit 2057, a transcript
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`containing confidential testimony provided by Dr. Jeffrey Bloom during his
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`deposition of May 20, 2015, be sealed in its entirety1 and treated as PROTECTIVE
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`ORDER MATERIAL under the Board’s Standing Protective Order. Patent Owner
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`justified its request by referring to its belief that a third party, Dr. Jeffrey Bloom’s
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`employer, Sirius XM, might desire to maintain the confidentiality of the transcript.
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`Exhibit 2057 does contain many pages of material touching on topics that are
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`arguably confidential to Sirius XM. Specifically, the pages of Exhibit 2057
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`containing arguably confidential material are those marked: 193-95, 219-239, and
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`243-246. Petitioner does not oppose Patent Owner’s request to seal those specific
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`pages of Exhibit 2057.
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`The remaining pages of the transcript, however, do not appear to contain
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`testimony touching on confidential topics. As such, Petitioner does oppose Patent
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`1 The transcript begins on a page marked 189 and ends on a page marked 287.
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`2
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`Case CBM2014-00190
`Attorney Docket No: 39843-0003CP1
`Owner’s request to seal those remaining pages of Exhibit 2057, which are marked:
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`189-192, 196-218, 240-42, and 247-287.
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`Date: June 19, 2015
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`Respectfully submitted,
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`/W. Karl Renner/
`W. Karl Renner
`Reg. No. 41,265
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`3
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`Case CBM2014-00190
`Attorney Docket No: 39843-0003CP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on June 19, 2015, a complete and entire copy of this Petitioner’s Opposition to
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`Patent Owner’s Motion to Seal was provided via email to the Patent Owner by
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`serving the correspondence email addresses of record as follows:
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`Michael R. Casey
`J. Scott Davidson
`Davidson Berquist Jackson & Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
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`Email: mcasey@dbjg.com
`jsd@dbjg.com
` docket@dbjg.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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`4
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