`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CLIO USA, INC.,
`Petitioner
`v.
`THE PROCTER & GAMBLE COMPANY,
`Patent Owner
`
`Case IPR 2013-00448
`Patent No. 5,891,453
`
`PETITIONER’S MOTION TO SEAL
`CONFIDENTIAL DEPOSITION TESTIMONY
`
`
`
`Case IPR2013-00448
`Patent 5,891,453
`
`Pursuant to the Protective Order that has been agreed to by the parties, but
`
`not yet formally entered, Petitioner, Clio USA, Inc., hereby moves to file under
`
`seal as Exhibit 1022 the deposition transcript of Dr. Jerry Atwood. During the
`
`course of this deposition, counsel for Patent Owner, The Procter & Gamble
`
`Company, asserted that the testimony comprised confidential information, but has
`
`not yet identified specific confidential portions. Accordingly, Petitioner moves to
`
`file the entire transcript under seal, but will file a public redacted version once
`
`Patent Owner’s counsel has designated specific portions of the transcript as
`
`confidential.
`
`Respectfully submitted,
`
`VORYS, SATER, SEYMOUR and PEASE, LLP
`
`/s/William H. Oldach III
`William H. Oldach III
`Attorney for Petitioner, CLIO USA, INC.
`Registration No. 42,048
`
`Date: May 14, 2014
`
`VORYS, SATER, SEYMOUR and PEASE, LLP
`1909 K Street NW, Ninth Floor
`Washington, D.C. 20006-1152
`Tel: 202-467-8800 / Fax: 202-533-9187
`
`1
`
`
`
`Case IPR2013-00448
`Patent 5,891,453
`
`CERTIFICATION OF SERVICE (37 C.F.R. §§ 42.6(e))
`
`The undersigned hereby certifies that the above-captioned Petitioner’s
`
`Motion To Seal Confidential Deposition Testimony was served on May 14, 2014,
`
`by e-mail, pursuant to agreement of the parties, on the following:
`
`David M. Maiorana (dmaiorana@jonesday.com)
`Kenneth S. Luchesi (kluchesi@jonesday.com)
`John V. Biernacki (jvbiernacki@jonesday.com)
`David M. Weirich (weirich.dm@pg.com)
`Armina E. Stricklin (stricklin.ae@pg.com)
`
`/s/William H. Oldach III
`William H. Oldach III
`
`5/13/2014 19338152
`
`2
`
`
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