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Paper No. __
`Filed: August 1, 2016
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`LUPIN LTD. and LUPIN PHARMACEUTICALS INC., INNOPHARMA
`LICENSING, INC., INNOPHARMA LICENSING LLC, INNOPHARMA
`INC., INNOPHARMA LLC, MYLAN PHARMACEUTICALS INC., and
`MYLAN INC.
`Petitioner
`v.
`
` SENJU PHARMACEUTICAL CO., LTD.,
`Patent Owner
`__________________
`
`Case IPR2015-01097 (Patent 8,754,131 B2) 1
`Case IPR2015-01100 (Patent 8,927,606 B1) 2
` Case IPR2015-01105 (Patent 8,871,813 B2) 3, 4
`__________________
`
`SECOND RENEWED MOTION TO SEAL
`
`
`1 Case IPR2016-00089 has been joined with this proceeding.
`
`2 Case IPR2016-00091 has been joined with this proceeding.
`
`3 Case IPR2016-00090 has been joined with this proceeding.
`
`4 A word-for-word identical paper has been filed in each proceeding identified in
`
`the heading.
`
`
`
`

`
`
`
`
`I.
`
`
`IPR2015-01097 (Patent 8,754,131 B2)
`IPR2015-01100 (Patent 8,927,606 B1)
`IPR2015-01105 (Patent 8,871,813 B2)
`
`Introduction
`
`Through this Second Renewed Motion to Seal, Patent Owner requests that
`
`certain confidential information belonging to Patent Owner and third party
`
`BioScience found in certain Petitioner’s exhibits be sealed. To the best of Patent
`
`Owner’s knowledge, the Patent Owner certifies that the information identified as
`
`confidential in this motion has not been published or otherwise made public.
`
`Petitioner Lupin does not oppose sealing this information.
`
`
`
`The Board has denied Petitioner’s requests to seal certain Patent Owner
`
`confidential information found in certain Petitioner’s exhibits. (IPR2015-Paper 59.
`
`On July 18, 2016, the parties filed a modified Stipulated Protective Order. Paper
`
`64. On July 29, 2016, Patent Owner filed a Renewed Motion to Seal requesting,
`
`among other things, that certain Patent Owner confidential information, related to
`
`Patent Owner’s New Drug Application (“NDA”) (Exs. 2096, 2102, 2103, 2110,
`
`2251, 2291-2293) and certain third-party confidential information, belonging to
`
`BioScience (Exs. 2267-2278, 2294), be sealed and explaining there was good
`
`cause for sealing this confidential information under 37 C.F.R. § 42.54.
`
`
`
`Patent Owner hereby requests that certain additional exhibits, citing to or
`
`substantially describing the information contained in the above-listed exhibits, also
`
`be sealed, specifically:
`
`
`
`1
`
`

`
`
`
`
`
`IPR2015-01097 (Patent 8,754,131 B2)
`IPR2015-01100 (Patent 8,927,606 B1)
`IPR2015-01105 (Patent 8,871,813 B2)
`
` Transcript of Dr. Paulson (Ex. 1123) - 71:13-74:11, 105:13-106:13,
`
`107:4-11, 108:19-109:4, 109:11-16, 113:1-7, 113:16-116:22, 118:7-123:14,
`
`124:11-22, 125:5-6, 125:12-20, 126:2-8, 126:12-22, 127:6-128:3, 128:17-19,
`
`131:5-132:6, 132:9, 132:12-133:21, 134:8-135:1, 137-142:12, 143:21-144:1,
`
`144:7-22, 145:14-146:7, 146:13-15, 146:19-147:9, 147:15-22, 148:12-18, 149:3-7,
`
`149:12-14, 149:17-151:19, 152:15-153:4, 156:10-157:12, 159:7-160:9, 170:19-
`
`172:7, 180:9-12, 181:13-19, 182:6-183:9, 183:19-184:19, 187:13-188:15, 191:16-
`
`312:10;
`
` Transcript of Dr. Trattler (Ex. 1120) - 111:10-12;
`
` Transcript of Dr. Williams (Ex. 1099) - 121:5-18, 122:7-20, 123:1-
`
`125:16, 126:4-127:2; and
`
` Hoffman Declaration (Ex. 1122) - paragraph 19, pg 18, paragraphs 33, 35-38,
`
`40-41, 60, 62, 68-72, 76-77, 81, 85, 89, 91, 102-105, 108-109, 112-113.
`
`Because public disclosure of the contents of these documents, or
`
`descriptions of those contents, would disclose confidential business methods of
`
`Patent Owner or a third party, Patent Owner requests that the portions of the
`
`
`
`2
`
`

`
`
`
`
`above-listed exhibits be sealed, as “PROTECTIVE ORDER MATERIAL”, for the
`
`IPR2015-01097 (Patent 8,754,131 B2)
`IPR2015-01100 (Patent 8,927,606 B1)
`IPR2015-01105 (Patent 8,871,813 B2)
`
`duration of this proceeding.
`
`II. Conclusion
`For the reasons set forth above, Patent Owner respectfully requests that the
`
`Board grant this motion to seal.
`
`Respectfully,
`
`
` /Joshua L. Goldberg/
`By:
`Joshua L. Goldberg, Backup Counsel
`Reg. No. 59,369
`
`Counsel for Patent Owner
`
`
`
`
`
`3
`
`
`
`
`
`

`
`
`
`
`
`IPR2015-01097 (Patent 8,754,131 B2)
`IPR2015-01100 (Patent 8,927,606 B1)
`IPR2015-01105 (Patent 8,871,813 B2)
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Second
`
`Renewed Motion to Seal was served on August 1, 2016, via email directed to
`
`counsel of record for the Petitioner at the following:
`
`Deborah Yellin
`DYellin@crowell.com
`
`Jonathan Lindsay
`JLindsay@crowell.com
`
`Teresa Stanek Rea
`TRea@crowell.com
`
`Chiemi Suzuki
`CSuzuki@crowell.com
`
`Shannon Lentz
`SLentz@crowell.com
`
`Jitendra Malik
`jitty.malik@alston.com
`
`Bryan Skelton
`Bryan.skelton@alston.com
`
`Lance Soderstrom
`lance.soderstrom@alston.com
`
`Hidetada James Abe
`james.abe@alston.com
`
`Joseph M. Janusz
`Joe.janusz@alston.com
`
`4
`
`
`
`

`
`IPR2015-01097 (Patent 8,754,131 B2)
`IPR2015-01100 (Patent 8,927,606 B1)
`IPR2015-01105 (Patent 8,871,813 B2)
`
`
`
`
`
`
`
`/Ashley F. Cheung/
`Ashley F. Cheung
`Case Manager
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, LLP
`
`5
`
`
`
`
`
`
`Date: August 1, 2016

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