`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Applicant:
`
`Dresti et al.
`
`Universal Remote Control, Inc.
`
`Case No.:
`
`IPR2014-01109
`
`v.
`
`Filing Date: November 6, 2002
`
`Universal Electronics, Inc.
`
`Patent No.:
`
`7,831,930
`
`Trial Paralegal: Cathy Underwood
`
`Attorney Doc.: 059489.143600
`
`Title:
`
`SYSTEM AND
`METHOD FOR
`DISPLAYING A USER
`INTERFACE FOR A
`REMOTE CONTROL
`APPLICATION
`
`
`
`
`
`
`
`
`[PROPOSED] PROTECTIVE ORDER
`
`This protective order governs the treatment and filing of confidential
`
`information in this proceeding, including documents and testimony.
`
`1. Confidential information shall be clearly marked “PROTECTIVE
`
`ORDER MATERIAL.”
`
`2. Access to confidential information is limited to the following
`
`individuals who have executed the acknowledgment appended to this order:
`
`(A) Party Representatives. Representatives of record for a
`
`party in the proceeding.
`
`(B) Experts. Retained experts of a party in the proceeding who further
`
`Universal Electronics Exhibit 2045, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
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`certify in the Acknowledgement that they are not a competitor to any
`
`party, or a consultant for, or employed by, such a competitor with
`
`respect to the subject matter of the proceeding.
`
`(C) The Office. Employees and representatives of the Office who have
`
`a need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees
`
`and representatives shall include the Director, members of the Board
`
`and their clerical staff, other support personnel, court reporters, and
`
`other persons acting on behalf of the Office.
`
`(D) Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons who are
`
`reasonably necessary to assist those persons in the proceeding shall not
`
`be required to sign an Acknowledgement, but shall be informed of the
`
`terms and requirements of the Protective Order by the person they are
`
`supporting who receives confidential information.
`
`
`
`
`
`3. Persons receiving confidential information shall use reasonable
`
`efforts to maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons
`
`not authorized to receive the information shall not have access;
`
`Universal Electronics Exhibit 2045, Page 2
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
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`(B) Otherwise using reasonable efforts to maintain the confidentiality of
`
`the information, which efforts shall be no less rigorous than those the
`
`recipient uses to maintain the confidentiality of information not received
`
`from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access to
`
`the confidential information understand and abide by the obligation to
`
`maintain the confidentiality of information received that is designated as
`
`confidential; and
`
`(D) Limiting the copying of confidential information to a reasonable
`
`number of copies needed for conduct of the proceeding and
`
`maintaining a record of the locations of such copies.
`
`
`
`
`
`
`
`4. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board under
`
`seal, together with a non-confidential description of the nature of the
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`confidential information that is under seal and the reasons why the
`
`information is confidential and should not be made available to the
`
`public. The submission shall be treated as confidential and remain
`
`Universal Electronics Exhibit 2045, Page 3
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
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`under seal, unless, upon motion of a party and after a hearing on the
`
`issue, or sua sponte, the Board determines that the documents or
`
`information do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non- confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`locations of information that has been redacted. The confidential version
`
`of the submission shall be filed under seal. The redacted information
`
`shall remain under seal unless, upon motion of a party and after a
`
`hearing on the issue, or sua sponte, the Board determines that some or all
`
`of the redacted information does not qualify for confidential treatment.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`Information designated as confidential that is disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” and shall
`
`be produced in a manner that maintains its confidentiality.
`
`Universal Electronics Exhibit 2045, Page 4
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
`
`
`
`
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`(j) Standard Acknowledgement of Protective Order. The following form may
`
`be used to acknowledge a protective order and gain access to information
`
`covered by the protective order:
`
`Universal Electronics Exhibit 2045, Page 5
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`Applicant:
`
`Dresti et al.
`
`Universal Remote Control, Inc.
`
`Case No.:
`
`IPR2014-01109
`
`v.
`
`Filing Date: November 6, 2002
`
`Universal Electronics, Inc.
`
`Patent No.:
`
`7,831,930
`
`Trial Paralegal: Cathy Underwood
`
`Attorney Doc.: 059489.143600
`
`Title:
`
`SYSTEM AND
`METHOD FOR
`DISPLAYING A USER
`INTERFACE FOR A
`REMOTE CONTROL
`APPLICATION
`
`
`
`
`
`
`
`
`Standard Acknowledgment for Access to Protective Order Material
`
`I
`
`, affirm that I
`
`have read the Protective Order; that I will abide by its terms; that I
`
`will use the confidential information only in connection with this
`
`proceeding and for no other purpose; that I will only allow access to
`
`support staff who are reasonably necessary to assist me in this
`
`proceeding; that prior to any disclosure to such support staff I
`
`informed or will inform them of the requirements of the Protective
`
`Order; that I am personally responsible for the requirements of the
`
`terms of the Protective Order and I agree to submit to the jurisdiction
`
`Universal Electronics Exhibit 2045, Page 6
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`
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`of the Office and the United States District Court for the Eastern
`
`District of Virginia for purposes of enforcing the terms of the
`
`Protective Order and providing remedies for its breach.
`
`
`
`
`
`
`
`
`[Signature]
`
`
`
`
`
`
`
`
`
`
`
`Universal Electronics Exhibit 2045, Page 7
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01109
`
`