`OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Universal Remote Control, Inc.
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`v.
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`Universal Electronics, Inc.
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`Trial Paralegal: Cathy Underwood
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`Applicant: Darbee
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`Case No.: IPR2014-01104
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`Filing Date: October 8, 1993
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`Patent No.: 5,414,761
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`Title: REMOTE CONTROL Attorney Doc.: 059489.144300
`SYSTEM
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`[PROPOSED] PROTECTIVE ORDER
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`The following Standing Protective Order will be automatically entered into
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`the proceeding upon the filing of a petition for review or institution of a
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`derivation:
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`Standing Protective Order
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`This standing protective order governs the treatment and filing of confidential
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`information in this proceeding, including documents and testimony.
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` 1. Confidential information shall be clearly marked "PROTECTIVE ORDER
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`MATERIAL."
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` 2. Access to confidential information is limited to the following individuals
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`who have executed the acknowledgment appended to this order:
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`Universal Electronics Exhibit 2066, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`(A) Parties. Persons who are owners of a patent involved in the
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`proceeding and other persons who are named parties to the
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`proceeding.(B) Party Representatives. Representatives of record for a party
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`in the proceeding.
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`(C(B) Experts. Retained experts of a party in the proceeding who further
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`certify in the Acknowledgement that they are not a competitor to any party,
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`or a consultant for, or employed by, such a competitor with respect to the
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`subject matter of the proceeding.
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`(D) In-house counsel. In-house counsel of a party.
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`(E) Other Employees of a Party. Employees, consultants or other
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`persons performing work for a party, other than in-house counsel and
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`in-house counsel's support staff, who sign the Acknowledgement shall
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`be extended access to confidential information only upon agreement of
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`the parties or by order of the Board upon a motion brought by the party
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`seeking to disclose confidential information to that person. The party
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`opposing disclosure to that person shall have the burden of proving that
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`such person should be restricted from access to confidential
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`information.
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`(F(C) The Office. Employees and representatives of the Office who have a
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`need for access to the confidential information shall have such access
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`Universal Electronics Exhibit 2066, Page 2
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`without the requirement to sign an Acknowledgement. Such employees and
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`representatives shall include the Director, members of the Board and their
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`clerical staff, other support personnel, court reporters, and other persons
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`acting on behalf of the Office.
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`(G(D) Support Personnel. Administrative assistants, clerical staff, court
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`reporters and other support personnel of the foregoing persons who are
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`reasonably necessary to assist those persons in the proceeding shall not be
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`required to sign an Acknowledgement, but shall be informed of the terms
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`and requirements of the Protective Order by the person they are supporting
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`who receives confidential information.
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` 3. Persons receiving confidential information shall use reasonable efforts to
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`maintain the confidentiality of the information, including:
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`(A) Maintaining such information in a secure location to which persons not
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`authorized to receive the information shall not have access;
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`(B) Otherwise using reasonable efforts to maintain the confidentiality of the
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`information, which efforts shall be no less rigorous than those the recipient
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`uses to maintain the confidentiality of information not received from the
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`disclosing party;
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`Universal Electronics Exhibit 2066, Page 3
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`(C) Ensuring that support personnel of the recipient who have access to the
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`confidential information understand and abide by the obligation to maintain
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`the confidentiality of information received that is designated as confidential;
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`and
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`(D) Limiting the copying of confidential information to a reasonable number
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`of copies needed for conduct of the proceeding and maintaining a record of
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`the locations of such copies.
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` 4. Persons receiving confidential information shall use the following
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`procedures to maintain the confidentiality of the information:
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`(A) Documents and Information Filed With the Board.
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`(i) A party may file documents or information with the Board under seal,
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`together with a non-confidential description of the nature of the confidential
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`information that is under seal and the reasons why the information is
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`confidential and should not be made available to the public. The submission
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`shall be treated as confidential and remain under seal, unless, upon motion
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`of a party and after a hearing on the issue, or sua sponte, the Board
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`determines that the documents or information do not to qualify for
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`confidential treatment.
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`Universal Electronics Exhibit 2066, Page 4
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`(ii) Where confidentiality is alleged as to some but not all of the information
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`submitted to the Board, the submitting party shall file confidential and non-
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`confidential versions of its submission, together with a Motion to Seal the
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`confidential version setting forth the reasons why the information redacted
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`from the non-confidential version is confidential and should not be made
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`available to the public. The nonconfidential version of the submission shall
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`clearly indicate the locations of information that has been redacted. The
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`confidential version of the submission shall be filed under seal. The redacted
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`information shall remain under seal unless, upon motion of a party and after
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`a hearing on the issue, or sua sponte, the Board determines that some or all
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`of the redacted information does not qualify for confidential treatment.
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`(B) Documents and Information Exchanged Among the Parties. Information
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`designated as confidential that is disclosed to another party during discovery
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`or other proceedings before the Board shall be clearly marked as
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`"PROTECTIVE ORDER MATERIAL" and shall be produced in a manner
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`that maintains its confidentiality.
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`(j) Standard Acknowledgement of Protective Order. The following form may be
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`used to acknowledge a protective order and gain access to information covered by
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`the protective order:
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`Universal Electronics Exhibit 2066, Page 5
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`[CAPTION]IN THE UNITED STATES PATENT AND TRADEMARK
`OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Universal Remote Control, Inc.
`
`
`
`
`
`v.
`
`Universal Electronics, Inc.
`
`Trial Paralegal: Cathy Underwood
`
`
`
`
`
`
`
`
`Applicant: Darbee
`
`Case No.: IPR2014-01104
`
`Filing Date: October 8, 1993
`
`Patent No.: 5,414,761
`
`Title: REMOTE CONTROL Attorney Doc.: 059489.144300
`SYSTEM
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`Standard Acknowledgment for Access to Protective Order Material
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`I
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`, affirm that I
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`have read the Protective Order; that I will abide by its terms; that I
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`will use the confidential information only in connection with this
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`proceeding and for no other purpose; that I will only allow access to
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`support staff who are reasonably necessary to assist me in this
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`proceeding; that prior to any disclosure to such support staff I
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`informed or will inform them of the requirements of the Protective
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`Order; that I am personally responsible for the requirements of the
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`terms of the Protective Order and I agree to submit to the jurisdiction
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`of the Office and the United States District Court for the Eastern
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`Universal Electronics Exhibit 2066, Page 6
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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`District of Virginia for purposes of enforcing the terms of the
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`Protective Order and providing remedies for its breach.
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`[Signature]
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`Universal Electronics Exhibit 2066, Page 7
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01104
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