`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`BMW OF NORTH AMERICA, LLC and
`BMW MANUFACTURING CO., LLC,
`
`
`Petitioners,
`
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`
`
`Patent Owner.
`
`
`
`Inter Partes Review of U.S. Patent No. 6,886,956
`IPR2015-00934
`
`
`
`
`
`
`
`
`
`
`
`JOINT REQUEST TO TREAT SETTLEMENT AGREEMENT AS
`CONFIDENTIAL BUSINESS INFORMATION AND KEEP IT SEPARATE
`UNDER 37 C.F.R. § 42.74(c)
`
`
`
`
`
`
`
`
`
`
`
`IPR2015-00934
`U.S. Patent No. 6,886,956
`
`
` Joint Request for Confidential Treatment
`
`Concurrently with the filing of this Request, Petitioners BMW of North
`
`America, LLC and BMW Manufacturing Co., LLC (“Petitioners”) and Patent
`
`Owner Innovative Display Technologies LLC (“Patent Owner”) are filing a Joint
`
`Motion to Terminate this inter partes review of U.S. Patent No. 6,886,956 (“the
`
`ʼ956 patent”) due to settlement between the parties.
`
`A true copy of the parties’ written settlement agreement is being filed as an
`
`exhibit contemporaneously with this joint motion to terminate. (Ex. 1007,
`
`Settlement Agreement). The settlement agreement has been filed for access by the
`
`“Parties and Board Only.”
`
` The settlement agreement contains business
`
`confidential information, and the parties hereby request that the settlement be kept
`
`separately, treated as business confidential information, and made available only
`
`under the provisions of 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c).
`
`The filing of this joint request was authorized by the Board in an e-mail
`
`communication on July 8, 2015.
`
`
`
`
`
`
`
`
`
`
`
`Date: July 9, 2015
`
`
`
`
`
`
`
`
`
`1
`
`Respectfully submitted,
`
`
`
`
`
`/Jeffrey D. Sanok/
`Jeffrey D. Sanok
`Reg. No. 32169
`Jonathan M. Lindsay
`Reg. No. 45810
`Crowell & Moring LLP
`1001 Pennsylvania Avenue NW
`
`
`
`IPR2015-00934
`U.S. Patent No. 6,886,956
`
`
` Joint Request for Confidential Treatment
`
`
`
`
`
`Washington, DC 20004-2595
`Tel.: (202) 624-2500
`Fax.: (202) 628-5116
`jsanok@crowell.com
`jlindsay@crowell.com
`
`Counsel for Petitioners
`BMW of North America, LLC and
`BMW Manufacturing Co., LLC
`
`/George W. Webb/
`George W. Webb III
`Reg. No. 60737
`Amir Alavi
`Pending Pro Hac Vice Motion
`Brian Simmons
`Pending Pro Hac Vice Motion
`Ahmad, Zavitsanos, Anaipakos, Alavi
`& Mensing P.C.
`1221 McKinney, Suite 3460
`Houston, TX 77010
`Tel.: (713) 655-1101
`Fax.: (713) 655-0062
`gwebb@azalaw.com
`aalavi@azalaw.com
`bsimmons@azalaw.com
`
`Counsel for Patent Owner
`Innovative Display Technologies LLC
`
`Date: July 9, 2015
`
`
`
`
`
`
`
`2
`
`
`
`IPR2015-00934
`U.S. Patent No. 6,886,956
`
`
` Joint Request for Confidential Treatment
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that, on this 9th day of July, 2015, true and correct
`
`copies of
`
`the foregoing JOINT REQUEST TO TREAT SETTLEMENT
`
`AGREEMENT AS CONFIDENTIAL BUSINESS INFORMATION AND KEEP
`
`IT SEPARATE UNDER 37 C.F.R. § 42.74(c) were served by Petitioners via
`
`Federal Express™ on the attorney of record for the patent owner, with a courtesy
`
`copy being sent by electronic e-mail to the attorneys of record in the co-pending
`
`litigation, at the following addresses:
`
`Attorney of Record
`for Patent Owner:
`
`
`Attorneys of Record
`in Co-Pending
`Litigation:
`
`George W. Webb III
`Reg. No. 60,797
`E-mail: gwebb@azalaw.com
`Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing PC
`1221 McKinney, Suite 3460
`Houston, TX 77010
`Tel: (713) 655-1101
`Facsimile: (713) 655-0062
`
`Demetrios Anaipakos
`Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing PC
`1221 McKinney, Suite 3460
`Houston, Texas 77010-2009
`
`/Jonathan Lindsay /
`Jonathan M. Lindsay
`Reg. No. 45,810
`CROWELL & MORING LLP
`1001 Pennsylvania Avenue NW
`Washington, DC 20004-2595
`Tel.: (949) 263-8400
`Fax.: (949) 263-8414
`JLindsay@crowell.com
`
`
`
`
`
`3
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