`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`SAMSUNG ELECTRONICS AMERICA, INC. AND
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
`Petitioner,
`
`v.
`
`SMARTFLASH LLC,
`
`Patent Owner.
`
`____________
`
`Case CBM2014-00193
`
`Patent 8,061,598
`
`____________
`
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.14, Patent Owner Smartflash, LLC moves that
`
`the Board seal Exhibit 2057 and Patent Owner’s unredacted Patent Owner’s
`
`Response, which refers to that exhibit. Pursuant to Appendix B to the Trial
`
`Practice Guide, Petitioner is concurrently filing a non-confidential version of the
`
`Petition with the confidential material redacted.
`
`Exhibit 2057 is the transcript of the Confidential Portion of the Deposition
`
`of Jeffery Adam Bloom, PhD taken on May 20, 2015. It is unclear at the time of
`
`filing Patent Owner’s Response whether Dr. Bloom’s employer, SiriusXM desires
`
`to maintain the confidentiality designation and counsel for Petitioner could not
`
`give counsel for Patent Owner a definitive answer before the deadline for filing.
`
`Good cause therefore exists for sealing this exhibit, redacting reference to it in the
`
`publicly filed Patent Owner’s Response and treating it as PROTECTIVE ORDER
`
`MATERIAL under the Board’s Standing Protective Order until such time as
`
`counsel for Petitioner can give a definitive answer.
`
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`enter an Order sealing the unredacted version of Patent Owner’s Response and
`
`Exhibit 2057.
`
`
`
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson &
`
`Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7700
`Fax : (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: June 1, 2015
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that this PATENT OWNER’S MOTION TO
`SEAL was served, by agreement of the parties, June 1, 2015 by emailing copies to
`counsel for the Petitioner as follows:
`
`W. Karl Renner (renner@fr.com)
`Thomas Rozylowicz (rozylowicz@fr.com)
`CBM39843-0005CP1@fr.com
`
`
` /
`
` Michael R. Casey /
`
`
`Michael R. Casey
`Registration No. 40,294
`Davidson Berquist Jackson &
`
`Gowdey, LLP
`8300 Greensboro Dr., Suite 500
`McLean, VA 22102
`Telephone: (571) 765-7700
`Fax : (571) 765-7200
`Email: mcasey@dbjg.com
`Attorney for Patent Owner
`
`
`
`Dated: June 1, 2015