`Motion to Seal
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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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`CONOPCO, INC. dba UNILEVER
`Petitioner
`v.
`THE PROCTOR & GAMBLE COMPANY
`Patent Owner
`
`_____________
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`Patent No. 6,451,300
`Case No. IPR2013-00509
`____________________________________________________________
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`PETITIONER’S MOTION TO SEAL
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`4833-1072-8990.
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`Inter Partes Review No. IPR2013-00509
`Motion to Seal
`Petitioner Conopco, Inc. dba Unilever (“Petitioner”) hereby moves to seal
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`the following:
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`Exhibit 1036, the unredacted deposition testimony of Robert Y. Lochhead,
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`Ph.D. A public, redacted version of the deposition testimony of Robert Y.
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`Lochhead, Ph.D is filed as Petitioner Exhibit 1037.
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`Petitioner certifies that it has previously conferred with Patent Owner The
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`Proctor and Gamble Company (“Patent Owner”) regarding the proposed default
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`protective order, and agreement was reached. A Joint Motion to Enter Default
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`Protective Order was filed. See Paper 34.
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`REASONS FOR SEALING
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`Each of the following portions of Petitioner’s Exhibits contain information
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`designated confidential by Patent Owner under the Protective Order.
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`A. Certain passages of the deposition testimony of Robert Y. Lochhead,
`Ph.D. taken on September 9, 2014: Exhibit 1036 (unredacted); Exhibit
`1037 (redacted, public)
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`A public, redacted version of the deposition testimony of Robert Y.
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`Lochhead, Ph.D. is filed as Petitioner Exhibit 1037, whereas a non-redacted
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`version is filed as Exhibit 1036, which is to be kept under seal. Patent Owner has
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`designated certain passages of the deposition testimony of Robert Y. Lochhead,
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`Ph.D. as confidential pursuant to the Protective Order. Because Patent Owner has
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`designated the subject information confidential, Petitioner will defer to Patent
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`2
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`Inter Partes Review No. IPR2013-00509
`Motion to Seal
`Owner to justify its designations in its response hereto, with Petitioner reserving
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`the right to contest any such designations in reply, if deemed warranted by
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`Petitioner.
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`Dated: September 23, 2014
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`Respectfully submitted,
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` By: __/Joseph P. Meara/_______
`Joseph P. Meara
`Registration No. 44,932
`Counsel for Petitioner
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`3
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`Inter Partes Review No. IPR2013-00509
`Motion to Seal
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`CERTIFICATE OF SERVICE
`I hereby certify that a true and correct copy of the foregoing
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`PETITIONER’S MOTION TO SEAL is being served by electronic mail
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`September 23, 2014 on counsel for Patent Owner as follows:
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`David M. Maiorana
`John V. Biernacki
`Michael S. Weinstein
`JONES DAY
`North Point
`901 Lakeside Avenue
`Cleveland, Ohio 44114
`Telephone (216) 586-3939
`Facsimile (216) 579-0212
`dmaiorana@jonesday.com
`jvbiernacki@jonesday.com
`msweinstein@jonesday.com
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`Dated: September 23, 2014
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`Steven W. Miller
`Kim W. Zerby
`Carl J. Roof
`Angela K. Haughey
`THE PROCTOR &
`GAMBLE COMPANY
`299 E. Sixth Street
`Cincinnati, Ohio 45202
`Telephone (513) 983-1246
`Facsimile (513) 945-2729
`miller.sw@pg.com
`zerby.kw@pg.com
`roof.cj@pg.com
`haughey.a@pg.com
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`Respectfully submitted,
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`By: __/Joseph P. Meara/_______
`Joseph P. Meara
`Reg. No. 44,932
`Foley & Lardner LLP
`Counsel for Petitioner
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`1
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