`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION,
`FUJITSU SEMICONDUCTOR LIMITED,
`FUJITSU SEMICONDUCTOR AMERICA, INC.,
`ADVANCED MICRO DEVICES, INC., RENESAS ELECTRONICS
`CORPORATION, RENESAS ELECTRONICS AMERICA, INC.,
`GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA
`AMERICA INFORMATION SYSTEMS, INC.,
`TOSHIBA CORPORATION, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`v.
`
`ZOND, LLC
`Patent Owner
`__________________
`
`Case IPR2014-008281
`Patent 6,805,779 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 Cases IPR 2014-00856, IPR2014-01022, and IPR2014-01070 have been joined
`with the instant proceeding.
`
`
`
`IPR2014-00828
`U.S. Patent No. 6,805,779
`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.
`
`6,805,779. 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 1219) 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
`
`
`
`1
`
`
`
`IPR2014-00828
`U.S. Patent No. 6,805,779
`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`
`
`patent”), 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 1219), 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
`
` For Petitioner:
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY LTD,
`and TSMC NORTH AMERICA CORP.
`
`
` /
`
` David M. O’Dell /
` David M. O’Dell, Reg. No. 42,044
`David L. McCombs, Reg. No. 32,271
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`david.odell.ipr@haynesboone.com;
`david.mccombs.ipr@haynesboone.com.
`
`C.F.R. § 42.74(c).
`
`Respectfully submitted,
`
`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 11, 2015
`
`
`
`
`
`
`
`2
`
`
`
`IPR2014-00828
`U.S. Patent No. 6,805,779
`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 11, 2015
`
`Manner of service Email: gonsalves@gonsalveslawfirm.com;
`bbarker@chsblaw.com;
`
`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 Dr. Gregory J. Gonsalves
`2216 Beacon Lane
`Falls Church, Virginia 22043
`
`Bruce Barker
`Chao Hadidi Stark & Barker LLP
`176 East Mail Street, Suite 6
`Westborough, MA 01581
`
`/David M. O’Dell/
`David M. O’Dell
`Lead Counsel for Petitioner TSMC
`Registration No. 42,044
`
`
`
`
`3
`
`
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