`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Attorney Docket No:
`01980-00035-72001
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`Petitioner: Google Inc.
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`In re Covered Business Method Review
`of:
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`U.S. Patent No. 7,334,720
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`Issued: February 26, 2008
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`Inventors: Hermen-ard Hulst and
`Patrick Racz
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`Application No. 11/336,758
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`Filed: January 19, 2006
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`For: DATA STORAGE AND
`ACCESS SYSTEMS
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`MOTION TO SEAL AND FOR ENTRY OF PROTECTIVE ORDER
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`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S.P.T.O.
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Pursuant to 37 C.F.R. §42.14, Petitioner Google Inc. requests that the Board
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`seal Exhibit 1016 and Petitioner’s unredacted Petition for Covered Business
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`Method Review, which refers to that exhibit. Pursuant to Appendix B to the Trial
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`Practice Guide, Petitioner is concurrently filing a non-confidential version of the
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`Petition with the confidential material redacted.
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`Exhibit 1016 is excerpts from the Patent Owner’s infringement contentions
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`served in the underlying litigation. The Patent Owner contends that these
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`infringement contentions contain its confidential analysis and has designated them
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`confidential pursuant to the Protective Order entered in the district court litigation.
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`As such, dissemination of this exhibit is limited by the district court’s Protective
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`Order. The Patent Owner has further requested that any filing of this exhibit or
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`reference to it be accompanied by a Motion to Seal. Good cause therefore exists
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`for sealing this exhibit, redacting reference to it in the publicly filed Petition for
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`Covered Business Method Review, and entering the attached Protective Order.
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`Attached hereto is a proposed Protective Order. This Protective Order is
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`based on the model protective order contained in Appendix B to the Trial Practice
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`Guide. Additional requested provisions, which are based on provisions in the
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`district court protective order in the underlying litigation, to which the parties
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`agreed in that proceeding, are indicated in redline.
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`enter an Order sealing the unredacted version of Petitioner’s Petition for Covered
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`Business Method Review and Exhibit 1016 and requiring the parties to abide by
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`the attached Protective Order.
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`Dated: May 6, 2015
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`Respectfully submitted,
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`/Raymond N. Nimrod/
`
`Raymond N. Nimrod (Reg. No. 31,987)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Telephone: 202-849-7000
`Fax: 212-849-7100
`
`Charles K. Verhoeven (pro hac vice
`motion to be filed)
`Melissa J. Baily (pro hac vice motion to
`be filed)
`Andrew M. Holmes (Reg. No. 64,718)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Telephone: 415-875-6000
`Fax: 415-875-6700
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`Counsel for Petitioner Google Inc.
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`2
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on May 6, 2015, I caused a true and correct copy of the
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`foregoing Motion to Seal and for Entry of Protective Order to be served via
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`Federal Express Priority Overnight to the below addresses:
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`Davidson Berquist Jackson & Gowdey LLP
`8300 Greensboro Drive
`Suite 500
`McLean, VA 22102
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`Kilpatrick Townsend & Stockton LLP
`Two Embarcadero Ctr.
`8th Floor
`San Francisco, CA 94111-3834
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`/Andrew M. Holmes
`Andrew M. Holmes
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`Date: May 6, 2015
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`3
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