`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IPR2015-00806
`U.S. 7,765,482
`
`
`
`
`GOOGLE INC.,
`Petitioner
`
`v.
`
`SUMMIT 6 LLC,
`Patent Owner
`
`
`
`
`Case: IPR2015-00806
`Patent 7,765,482
`
`PETITIONER’S UNOPPOSED MOTION TO SEAL
`PURSUANT TO 37 C.F.R. § 42.54
`
`
`
`
`
`
`
`
`
`
`
`Petitioner Google Inc. (“Petitioner”) hereby moves under the Standing
`
`IPR2015-00806
`U.S. 7,765,482
`
`
`
`
`Protective Order to seal (1) Petitioner’s Reply to Patent Owner’s Response
`
`(“Reply”) and (2) Exhibits 1015, 1016, and 1018 submitted with the Reply. The
`
`Standing Protective Order was filed June 15, 2015, by the Patent Owner and
`
`agreed upon by both parties. Paper 15. Petitioner met and conferred with Patent
`
`Owner Summit 6 LLC (“Patent Owner”), who does not oppose this motion to seal.
`
`
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`Petitioner submits its Reply concurrently with this motion. In support of its
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`Reply, Petitioner submits two deposition transcripts that Patent Owner has
`
`requested Petitioner designate as PROTECTIVE ORDER MATERIAL (Exhibits
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`1015 and 1016) as well as an expert declaration that relies upon documents that
`
`Patent Owner has designated as PROTECTIVE ORDER MATERIAL (Exhibit
`
`1018).
`
`Petitioner is filing a redacted version of its Reply as a public document. A
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`full version of the Reply is also filed as “Parties and Board Only.” Exhibits 1015,
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`1016, and 1018 are filed as Parties and Board Only. Petitioner has served Patent
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`Owner with both a full version and a redacted version of the Reply and with full
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`versions of Exhibits 1015, 1016, and 1018.
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`
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`The Parties have agreed that Patent Owner will provide redacted versions of
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`Exhibits 1015, 1016, and 1018 within a reasonable period of time subsequent to the
`
`1
`
`
`
`
`filing of this Motion. These redacted versions will be filed as publicly available
`
`IPR2015-00806
`U.S. 7,765,482
`
`exhibits.
`
`
`
`For the foregoing reasons, Petitioner respectfully requests that the Board
`
`grant this unopposed motion to seal.
`
`
`
`Respectfully submitted,
`
`
`By:
`John Alemanni (Registration No. 47,384)
`Lead Counsel for Petitioner
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`IPR2015-00806
`U.S. 7,765,482
`
`The undersigned hereby certifies that a copy of PETITIONER’S UNOPPOSED
`MOTION TO SEAL PURSUANT TO 37 C.F.R. § 42.54 has been served via
`email upon the following:
`
`
`Peter J. Ayers
`peter@leehayes.com
`John Shumaker
`jshumaker@leehayes.com
`Brian Mangum
`brianm@leehayes.com
`
`LEE & HAYES, PLLC
`11501 Alterra Parkway, Suite 450
`Austin, TX 78758
`
`
` Dated: March 9, 2016
`
`By:
`John Alemanni
`Registration No. 47,384
`John Alemanni
`Michael Morlock
`Registration No. 47,384
`Registration No. 62,245
`JAlemanni@kilpatricktownsend.com
`MMorlock@kilpatricktownsend.com
`Postal and Hand-Delivery Address:
` Postal and Hand-Delivery Address:
`Kilpatrick Townsend & Stockton LLP
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`1001 West Fourth Street
`Winston-Salem, NC 27101-2400
`Winston-Salem, NC 27101-2400
`Telephone: (336) 607-7311
`Telephone: (336) 607-7391
`Fax: (336) 607-7500
`Fax: (336) 607-7500
`
`
`
`Lead Counsel
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`
`
`Back-Up Counsel
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`
`
`3
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