Paper No. ___
`Date Filed: September 11, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`LUPIN LIMITED
`Petitioner
`
`v.
`
`JANSSEN SCIENCES IRELAND UC
`Patent Owner
`
`_______________________________
`
`CASE No. IPR2015-01030
`U.S. Patent No. 8,518,987 B2
`_______________________________
`
`
`
`JOINT MOTION TO SEAL AND FOR ENTRY OF
`PROTECTIVE ORDER UNDER 37 C.F.R. §§ 42.14 AND 42.54
`
`
`
`
`Date Filed: September 11, 2015
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
`
`LUPIN LIMITED
`Petitioner
`
`v.
`
`JANSSEN SCIENCES IRELAND UC
`Patent Owner
`
`_______________________________
`
`CASE No. IPR2015-01030
`U.S. Patent No. 8,518,987 B2
`_______________________________
`
`
`
`JOINT MOTION TO SEAL AND FOR ENTRY OF
`PROTECTIVE ORDER UNDER 37 C.F.R. §§ 42.14 AND 42.54
`
`
`
`
`
`Case IPR2015-01030
`Motion to Seal and for Entry of Protective Order
`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner Janssen Sciences
`
`Ireland UC (“Patent Owner”) and Petitioner Lupin Limited (“Petitioner”) (collec-
`
`tively, the “Parties”) jointly submit this motion to seal Exhibits 2048, 2049, and
`
`2051 and PATENT OWNER’S REPLY ON THE REAL PARTY-IN-INTEREST
`
`ISSUE, which Patent Owner filed on September 11, 2015. The Parties also move
`
`for entry of the Board’s Default Protective Order contained in Appendix B to the
`
`Patent Trial Practice Guide. Pursuant to paragraph 4(A)(ii) of the Board’s Default
`
`Protective Order, Patent Owner is also concurrently filing non-confidential ver-
`
`sions of each of the documents referenced above with the confidential portions re-
`
`dacted.
`
`I. Reasons for Sealing Certain Confidential Information
`
`With respect to Exhibits 2048, 2049, and 2051, Petitioner states that these
`
`exhibits contain (i) confidential Lupin Ltd. commercial and business information
`
`and (ii) private employment status of individuals from India that is preserved as
`
`confidential under, inter alia, Indian law. Therefore, good cause exists for filing
`
`Exhibits 2048, 2049, and 2051 under seal.
`
`With respect to PATENT OWNER’S REPLY ON THE REAL PARTY-IN-
`
`INTEREST ISSUE, Patent Owner states that the confidential version of this reply
`
`brief was filed under seal because it cites to material contained in Exhibits 2048,
`
`2049, and 2051 that Petitioner has designated as confidential. To the extent good
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`
`
`
`
`Case IPR2015-01030
`Motion to Seal and for Entry of Protective Order
`
`cause has been shown by Petitioner with respect to portions of the above-
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`referenced exhibits, good cause also exists for sealing the portions of the reply
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`brief referencing the sealed portions of those exhibits.
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`II. Certification of Non-Publication Status
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`The Parties’ undersigned counsel certify that with respect to the exhibits as
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`to which Petitioner has provided a showing of good cause in Section I above, the
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`information sought to be sealed by this motion has not, to the best of their
`
`knowledge, been published or otherwise made public.
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`III. Certification of Conference of the Parties Pursuant to 37 C.F.R. §
`42.54
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`The Parties have conferred in good faith and have agreed to the terms of the
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`Board’s Default Protective Order and to seal the exhibits and reply brief discussed
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`above. The proposed Protective Order submitted herewith as Exhibit 2052 is exe-
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`cuted by counsel for both Parties.
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`IV. Proposed Protective Order
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`The Proposed Protective Order submitted herewith as Exhibit 2052 is the
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`Board’s Default Protective Order to which the Parties agree to be bound in this
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`matter.
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`***
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`For the foregoing reasons, the Parties respectfully request that the Board en-
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`ter an Order sealing the confidential versions of Exhibits 2048, 2049, and 2051 and
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`2
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`Case IPR2015-01030
`Motion to Seal and for Entry of Protective Order
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`the confidential version of PATENT OWNER’S REPLY ON THE REAL PAR-
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`TY-IN-INTEREST ISSUE, and requiring the parties to abide by the Protective Or-
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`der submitted herewith.
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`Dated: September 11, 2015
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`
`
`Lupin Limited
`Petitioner
`
`By: /s/ Deanne M. Mazzochi
`Deanne M. Mazzochi
`(Reg. No. 50,158)
`dmazzochi@rmmslegal.com
`
`Tara M. Raghavan
`(Reg. No. 55,557)
`traghavan@rmmslegal.com
`
`RAKOCZY MOLINO MAZZOCHI
`SIWIK LLP
`6 West Hubbard Street, Suite 500
`Chicago, IL 60654
`Tel.: 312-222-6305
`Fax: 312-222-6325
`
`Dated: September 11, 2015
`
`Respectfully submitted,
`
`
`Janssen Ireland Science UC
`Patent Owner
`
`By: /s/ Dianne B. Elderkin
`Dianne B. Elderkin
`(Reg. No. 28,598)
`delderkin@akingump.com
`
`Barbara L. Mullin
`(Reg. No. 38,250)
`bmullin@akingump.com
`
`Ruben H. Munoz
`(Reg. No. 66,998)
`rmunoz@akingump.com
`
`AKIN GUMP STRAUSS HAUER
`& FELD LLP
`Two Commerce Square
`2001 Market Street, Suite 4100
`Philadelphia, PA 19103
`Tel: (215) 965-1200
`Fax: (215) 965-1210
`
`Irena Royzman
`(Reg. No. 73,354)
`iroyzman@pbtw.com
`PATTERSON BELKNAP WEBB
`& TYLER LLP
`
`3
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`
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`Case IPR2015-01030
`Motion to Seal and for Entry of Protective Order
`
`1133 Avenue of the Americas
`New York, NY 10036
`Tel.: (212) 336-2081
`Fax: (212) 336-2222
`
`Dated: September 11, 2015
`
`
`4
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`Case IPR2015-01030
`Motion to Seal and for Entry of Protective Order
`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that a copy of the foregoing JOINT MO-
`
`TION TO SEAL AND FOR ENTRY OF PROTECTIVE ORDER UNDER 37
`
`C.F.R. §§ 42.14 AND 42.54 (including Exhibit 2052) was served upon counsel of
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`record on September 11, 2015 by filing this document through the Patent Review
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`Processing System, as well as delivering a copy via email to counsel of record for
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`Petitioner at the following address:
`
`
`Deanne M. Mazzochi
`DMazzochi@rmmslegal.com
`Tara M. Raghavan
`traghavan@rmmslegal.com
`RAKOCZY MOLINO MAZZOCHI SIWIK LLP
`6 West Hubbard Street, Suite 500
`Chicago, IL 60654
`
`
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`Dated: September 11, 2015
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`/Dianne B. Elderkin /
`Dianne B. Elderkin
`Registration No. 28,598
`Counsel for Patent Owner
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