`
`_______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`LUPIN LTD. and LUPIN PHARMACEUTICALS INC.
`Petitioners
`
`v.
`
`SENJU PHARMACEUTICAL CO., LTD., BAUSCH & LOMB, INC., and
`BAUSCH & LOMB PHARMA HOLDINGS CORP.
`Patent Owner
`
`____________________
`
`PETITIONERS’ MOTION TO SEAL
`
`
`
`1 The word-for-word identical paper is filed in each proceeding identified in the
`heading. IPR2016-00089 has been joined with IPR2015-01097; IPR2016-00091
`has been joined with IPR2015-01100; and IPR2016-00090 has been joined with
`IPR2015-01105. Each of these joined proceedings includes Petitioners
`InnoPharma Licensing, Inc., InnoPharma Licensing LLC, InnoPharma Inc., Mylan
`Pharmaceuticals Inc., and Mylan Inc. (collectively, “InnoPharma”) in addition to
`the parties identified above.
`
`
`
`
`
`IPR2015-01097 (US Patent No. 8,754,131)
`IPR2015-01099 (US Patent No. 8,669,290)
`IPR2015-01100 (US Patent No. 8,927,606)
`IPR2015-01105 (US Patent No. 8,871,813)1
`____________________
`
`
`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.55 and the Protective Orders entered
`
`in these proceedings, Petitioners hereby move to seal Exhibit 1181, the Deposition
`
`Transcript of Ivan T. Hofmann in IPR2015-00902 and IPR2015-00903, March 25,
`
`2016. It is Petitioners’ understanding that this document has been designated by
`
`Patent Owner as Protective Order Material or Fed. R. Evid. 615 Materials (see
`
`Paper 29 in IPR2015-01097; Paper 25 in IPR2015-01099; Paper 29 in IPR2015-
`
`01100; and Paper 29 in IPR2015-01105) (“Proposed Stipulated Protective
`
`Orders”).
`
`The record of an inter partes review proceeding, including documents and
`
`things, is made available to the public, except as otherwise ordered. 37 C.F.R. §
`
`42.14. Despite the default rule of public availability, the Board will seal
`
`confidential information for “good cause,” because it is necessary to “strike a
`
`balance between the public’s interest in maintaining a complete and
`
`understandable file history and the parties’ interest in protecting truly sensitive
`
`information.” 37 C.F.R. § 42.54(a); 77 Fed. Reg. 48756, 48760 (Aug. 14, 2012).
`
`Petitioners have no independent basis for this document to be sealed and
`
`thus make no assertion as to whether or not it may contain confidential
`
`
`
`information.
`
`
`
`
`
`
`
`
`May 18, 2016
`
`
`
`
`
`Respectfully submitted,
`
`
`
` /Deborah Yellin/
`Deborah H. Yellin
`Reg. No. 45,904
`CROWELL & MORING LLP
`Intellectual Property Group
`P.O. Box 14300
`Washington, DC 20044-4300
`
`
`
`
`
`
`
`
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the foregoing document entitled
`
`PETITIONERS’ MOTION TO SEAL was served electronically via email on May
`
`18, 2016 to Patent Owner’s counsel of record and counsel of record for Petitioners
`
`InnoPharma at the following:
`
`Patent Owner
`
`Bryan.Diner@finnegan.com
`
`Justin.Hasford@finnegan.com
`
`Joshua.Goldberg@finnegan.com
`
`Petitioners InnoPharma
`
`Jitty.malik@alston.com
`
`bryan.skelton@alston.com
`
`James.abe@alston.com
`
`Lance.soderstrom@alston.com
`
`Joe.janusz@alston.com
`
`
`May 18, 2016
`
`
`
`Respectfully submitted,
`
`
`
` /Shannon M. Lentz/
`Shannon M. Lentz
`Reg. No. 65,382
`CROWELL & MORING LLP
`Intellectual Property Group
`P.O. Box 14300
`Washington, DC 20044-4300
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