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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
`Petitioner
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`v.
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`WESTERNGECO, LLC
`Patent Owner
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`Case IPR2014-014781
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`U.S. Patent No. 7,293,520
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`PETITIONER’S MOTION TO SEAL
`PORTIONS OF ITS REPLY IN SUPPORT OF MOTION TO EXCLUDE
`UNDER 37 CFR § 42.14
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`1 Case IPR2014-00689 is a related proceeding
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`Pursuant to 37 CFR § 42.14, Petitioner Petroleum Geo-Services Inc. (PGS)
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`respectfully submits this Motion to Seal Portions of its Reply in Support of Motion
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`to Exclude, which is being filed concurrently with this Motion.
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`I.
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`Reasons for Redacting Portions of the Reply
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`The standard governing the Board’s determination of whether to grant a
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`motion to seal is “good cause.” Garmin v. Cuozzo, IPR2012-0001, Paper 36 (April
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`5, 2013). The board aims to “strike a balance between the public’s interest in
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`maintaining a complete and understandable file history and the parties’ interest in
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`protecting truly sensitive information.” Id. PGS’s Reply discusses exhibits (1114,
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`1119, and 2099) that have been designated by WesternGeco as containing business
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`confidential information. These exhibits—including the declaration and deposition
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`transcripts of Mr. Robin Walker in this proceeding—have been designated as
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`confidential by WesternGeco.
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`Pursuant to Section 4(A)(ii) of the Board’s default protective order applicable
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`in this proceeding, PGS has filed a confidential, non-redacted version of its Reply
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`as well as a redacted version of its Reply to remove references and citations to the
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`sealed information and exhibits. Because the redacted portions of the Reply are
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`subject to WesternGeco’s confidentiality designations, Petitioner brings this motion
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`to seal with good cause.
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`II. Conclusion
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`For the foregoing reasons, Petitioner requests that the Board grant
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`Petitioner’s Motion to Seal. Petitioner understands that the documents filed
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`concurrently with this motion will remain sealed pending the outcome of the
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`decision on this motion. See 37 C.F.R. § 42.14. Should the Board require it before
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`deciding this motion, PGS is prepared to meet and confer with WesternGeco to
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`prepare any Joint Motion to Seal that may be required to further clarify the bases
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`for sealing the above documents.
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`Dated: November 4, 2015
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`Respectfully Submitted,
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`_/Jessamyn Berniker/________
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Telephone: 202-434-5000
`Facsimile: 202-434-5957
`Email: jberniker@wc.com
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`Attorney for Petitioner
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Petroleum Geo-
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`Service Inc.’s “Motion to Seal Portions of Its Reply in Support of Motion to
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`Exclude Under 35 C.F.R. § 42.55” was served to the Patent Owner by delivering a
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`copy via electronic mail upon the following attorneys of record.
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`__/Jessamyn Berniker/______
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Telephone: 202-434-5000
`Facsimile: 202-434-5957
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`Michael L. Kiklis
`CPDocketKiklis@oblon.com
`Scott McKeown
`CPDocketMcKeown@oblon.com
`Kevin Laurence
`CPDocketLaurence@oblon.com
`Katherine Cappaert
`CPDocketCappaert@oblon.com
`Christopher Ricciuti
`CPDocketRicciuti@oblon.com
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`Oblon
`1940 Duke Street
`Alexandria, Virginia 22314
`703-413-3000
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`Dated: November 4, 2015.
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`Email: jberniker@wc.com
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`Attorney for Petitioner
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