`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`IBG LLC,
`INTERACTIVE BROKERS LLC,
`TRADESTATION GROUP, INC.,
`TRADESTATION SECURITIES, INC., and
`Petitioners
`
`v.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.,
`Patent Owner
`___________________
`
`Case CBM2016-00054
`Patent 7,693,768
`___________________
`
`
`
`PETITIONERS’ MOTION TO SEAL
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`
`I.
`
`RELIEF REQUESTED
`
`Petitioners respectfully request that the Board maintain as confidential and
`
`under seal the entirety of Exhibits 1063 and 1064 – the deposition transcripts of
`
`Christopher H. Thomas which were marked confidential by TT.
`
`II. GOOD CAUSE EXISTS FOR SEALING THIS CONFIDENTIAL
`INFORMATION.
`
`The Board may issue this order “for good cause.” 37 C.F.R. § 42.54. For
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`good cause, the Board needs to know why information sought to be sealed
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`constitutes confidential information. Garmin Int’l, Inc. v. Cuozzo Speed Techs.
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`LLC, IPR2012-00001, Paper 36, Decision on Revised Mot. to Seal, p. 4 (P.T.A.B.
`
`Apr. 5, 2013). The Board then balances the needs in protecting the information
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`against the public’s interest in maintaining a complete and understandable file
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`history. Id. at 8.
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`During the depositions of Mr. Thomas, TT requested that the entirety of the
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`deposition transcripts of Mr. Thomas be designated as Confidential pursuant to the
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`Protective Order. Petitioners agreed. In light of the agreement of the parties,
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`Petitioners respectfully request that Exhibits 1063 and 1064 remain under seal until
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`this Board has ruled otherwise.
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`To the best of Petitioners’ knowledge, the documents sought to be protected
`
`have not been made publically available.
`
`- 1 -
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`It is therefore respectfully requested that the Board issue an Order regarding
`
`the confidentiality of Exhibits 1063 and 1064.
`
`
`
`
`Date: April 24, 2017
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Robert Sokohl/
`
`Robert E. Sokohl (Reg. No. 36,013)
`Lori A. Gordon (Reg. No. 50,633)
`Richard M. Bemben (Reg. No. 68,658)
`Attorneys for Petitioners
`
`
`
`
`- 2 -
`
`
`
`CBM2016-00054
`U.S. Patent No. 7,693,768
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that true and correct copies of the above-
`
`captioned MOTION TO SEAL served electronically via e-mail in its entirety on
`
`April 24, 2017, upon the following counsel for Patent Owner:
`
`
`
`Michael D. Gannon, Leif R. Sigmond, Jr., Jennifer Kurcz, Cole B. Richter
`MCDONNELL BOEHNEN HULBERT & BERGHOFF LLP
`gannon@mbhb.com
`sigmond@mbhb.com
`kurcz@mbhb.com
`richter@mbhb.com
`
`Stephen F. Borsand, Jay Q. Knobloch
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`tt-patent-cbm@tradingtechnologies.com
`jay.knobloch@tradingtechnologies.com
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`/Robert Sokohl/
`
`
`Robert E. Sokohl (Reg. No. 36,013)
`Lori A. Gordon (Reg. No. 50,633)
`Richard M. Bemben (Reg. No. 68,658)
`Attorneys for Petitioners
`
`
`
`Date: April 24, 2017
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`5267260_1.docx
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