`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`WAVEMARKET, INC. D/B/A LOCATION LABS
`Petitioner
`
`v.
`
`LOCATIONET SYSTEMS, LTD.
`Patent Owner
`___________________
`
`Case No. IPR2014-00920
`U.S. Patent 6,771,970
`___________________
`
`
`PATENT OWNER LOCATIONET SYSTEMS, LTD.’S
`MOTION TO SEAL UNDER 37 C.F.R. 42.14 AND 42.55
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R § 42.14 and 42.55, Patent Owner LocatioNet Systems,
`
`Ltd. submits its Patent Owner’s Response under seal pursuant to Petitioner
`
`Wavemarket Inc. d/b/a Location Labs’ designation of confidential information and
`
`pending Motion to Seal, filed on March 2, 2015 (Paper 26).
`
`I.
`
`REASONS FOR SEALING PATENT OWNER’S RESPONSE
`
`On February 18, 2015, Patent Owner deposed Petitioner’s declarant, Dr.
`
`Scott Hotes. Following the deposition, Petitioner designated as confidential
`
`numerous portions of the deposition transcript. On March 2, 2015, Petitioner filed
`
`its Motion to Seal and for Entry of Protective Order Pursuant to 37 C.F.R. §§ 42.14
`
`and 42.54 regarding the sealing of the portions of the February 18, 2015 deposition
`
`transcript of Dr. Scott Hotes (Ex. 1119).
`
`In its Patent Owner’s Response, Patent Owner has relied upon and cited to
`
`excerpts from Ex. 1119 that Petitioner has designated as confidential information
`
`pursuant to its Motion to Seal and Entry of Protective Order. See Paper 26. Patent
`
`Owner submits that most, if not all, of the information Petitioner has sought to seal
`
`in Ex. 1119 is not confidential because it is publicly available information,
`
`including in Petitioner’s own press releases accessible via Petitioner’s website.
`
`Accordingly, out of an abundance of caution, and subject to the Board’s decision
`
`on Petitioner’s Motion to Seal, Patent Owner concurrently files its Patent Owner’s
`
`Response under seal to protect Petitioner’s designated “confidential” information.
`
`
`
`Dated: March 3, 2015
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 3rd day of March, 2015, a true and correct copy
`
`of the foregoing PATENT OWNER LOCATIONET SYSTEMS, LTD.’S
`
`MOTION TO SEAL UNDER 37 C.F.R. 42.14 AND 42.55 was served on the
`
`following counsel for Petitioner Wavemarket, Inc. d/b/a Location Labs via email:
`
`
`
`
`
`Mark L. Hogge
`Scott W. Cummings
`Dentons US LLP
`1301 K Street, N.W., Suite 600
`Washington DC 20005
`Tel: (202)408-6400
`Fax: (202)408-6399
`
`Dated: March 3, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`mark.hogge@dentons.com
`scott.cummings@dentons.com
`
`Respectfully submitted,
`By: /Thomas Engellenner/
`Thomas Engellenner, Reg. No. 28,711
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
`(617) 204-5100 (telephone)
`(617) 204-5150 (facsimile)
`Attorney for Patent Owner
`
`
`
`
`
`