`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`THE GILLETTE COMPANY, TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD., TSMC NORTH AMERICA CORP.,
`FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU SEMICONDUCTOR
`AMERICA, INC.
`
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`__________________
`
`Case IPR2014-005781
`Patent 6,896,775 B2
`__________________
`
`
`
`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`PURSUANT TO 35 U.S.C. § 327(b) AND 37 C.F.R. § 42.74
`
`
`
`
`
`
`
`1 Case IPR2014-01494 has been joined with the instant proceeding.
`
`
`
`IPR2014-00578
`U.S. Patent No. 6,896,775
`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`
`
`INTRODUCTION
`
`I.
`
`ZOND LLC (“Patent Owner”) and Petitioners TAIWAN
`
`SEMICONDUCTOR MANUFACTURING COMPANY, LTD. and TSMC
`
`NORTH AMERICA CORP (jointly, “TSMC”) (collectively, “the Parties” or
`
`“Petitioner”) have executed a Settlement Agreement regarding U.S. Patent No.
`
`6,896,775. Pursuant to 35 U.S.C. § 327(b), the Parties jointly request that the
`
`Board treat the Settlement Agreement as business confidential information and
`
`keep it separate from the file of the involved patent.
`
`II. STATEMENT OF PRECISE RELIEF REQUESTED
`The Parties jointly request that the Board treat the Settlement Agreement
`
`(Exhibit 2011) as business confidential information and keep it separate from the
`
`file of the involved patent. The Parties further request the Board to not make the
`
`Settlement Agreement available to any third-party, except as provided for in 35
`
`U.S.C. § 327(b) and 37 C.F.R. § 42.74.
`
`III. STATEMENT OF REASONS FOR THE RELIEF REQUESTED
`
`The Parties have settled all of their disputes involving U.S. Patents Nos.
`
`6,805,779 (the “‘779 patent”), 6,806,652 (the “‘652 patent”), 6,853,142 (the “‘142
`
`patent”), 6,896,773 (the “’773 patent”), 6,896,775 (the “’775 patent”), 7,147,759
`
`(the “‘759 patent”), 7,604,716 (the “‘716 patent”), 7,808,184 (the “‘184 patent”),
`
`
`
`2
`
`
`
`IPR2014-00578
`U.S. Patent No. 6,896,775
`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`
`
`and 7,811,421 B2 (the “‘421 patent”) (collectively, the “Patents”). The Settlement
`
`Agreement provides that its terms are confidential and the Parties have treated
`
`them as such. The Parties have filed, concurrently herewith, a true and correct copy
`
`of the Settlement Agreement (Exhibit 2013), as required by 35 U.S.C. § 327(b) and
`
`37 C.F.R. § 42.74. The Exhibit was filed via the PRPS system to provide
`
`availability to “Board Only.” The Parties jointly request that the Settlement
`
`Agreement be treated as business confidential information and be kept separate
`
`from the file of the involved patent, pursuant to 35 U.S.C. § 327(b) and 37 C.F.R. §
`
`42.74(c).
`
`For Patent Owner:
`ZOND, LLC
`
`
`
`
`
`/Gregory J. Gonsalves/
`Dr. Gregory J. Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`gonsalves@gonsalveslawfirm.com
`
`
`
`
`Dated: March 10, 2015
`
`
`
`
` For Petitioner:
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY LTD,
`and TSMC NORTH AMERICA CORP.
`
`
`/David L. McCombs/
` David L. McCombs, Reg. No. 32,271
`David M. O’Dell, Reg. No. 42,044
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`david.mccombs.ipr@haynesboone.com;
`david.odell.ipr@haynesboone.com
`
`
`
`
`3
`
`
`
`IPR2014-00578
`U.S. Patent No. 6,896,775
`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I caused to be served a
`
`true and correct copy of the foregoing “JOINT REQUEST TO MAINTAIN
`
`CONFIDENTIALITY AND TO KEEP SEPARATE PURSUANT TO 35 U.S.C. §
`
`327(b) AND 37 C.F.R. § 42.74” as detailed below:
`
`Date of service March 10, 2015
`
`Manner of service email
`
`Documents served JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE PURSUANT TO 35 U.S.C. §
`327(b) AND 37 C.F.R. § 42.74
`
`
`Persons Served
`
` David L. McCombs
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`david.mccombs.ipr@haynesboone.com
`USPTO Reg. No. 32,271
`
`David O’Dell
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`david.odell.ipr@haynesboone.com
`USPTO Reg. No. 42,044
`
`
`
`
`/Gregory J. Gonsalves/
`Gregory J. Gonsalves, Reg. No. 43,639
`
`4
`
`
`
`
`
`
`
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