`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`MYLAN PHARMACEUTICALS INC.,
`Petitioner,
`
`v.
`
`ASTRAZENECA AB,
`Patent Owner.
`
`____________________________________________
`
`Case: IPR2015-01340
`U.S. Patent No. RE 44,186
`____________________________________________
`
`
`
`STANDING PROTECTIVE ORDER
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`AstraZeneca Exhibit 2192
`Mylan v. AstraZeneca
`IPR2015-01340
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`Page 1 of 8
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`This standing protective order governs the treatment and filing of
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`confidential information, including documents and testimony.
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`1. Confidential information shall be clearly marked “PROTECTIVE
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`ORDER MATERIAL.”
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`2. Access to confidential information is limited to the following individuals
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`who have executed the acknowledgment appended to this order:
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`(A) Parties. Persons who are owners of a patent involved in the
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`proceeding and other persons who are named parties to the
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`proceeding.
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`(B) Party Representatives. Representatives of record for a party in the
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`proceeding.
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`(C) Experts. Retained experts of a party in the proceeding who
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`further certify in the Acknowledgement that they are not a competitor
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`to any party, or a consultant for, or employed by, such a competitor
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`with respect to the subject matter of the proceeding.
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`(D) In-house counsel. In-house counsel of a party.
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`(E) Other Employees of a Party. Employees, consultants or other
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`persons performing work for a party, other than in-house counsel and
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`in-house counsel’s support staff, who sign the Acknowledgement
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`shall be extended access to confidential information only upon
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`Page 2 of 8
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`agreement of the parties or by order of the Board upon a motion
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`brought by the party seeking to disclose confidential information to
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`that person. The party opposing disclosure to that person shall have
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`the burden of proving that such person should be restricted from
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`access to confidential information.
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`(F) The Office. Employees and representatives of the Office who
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`have a need for access to the confidential information shall have such
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`access without the requirement to sign an Acknowledgement. Such
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`employees and representatives shall include the Director, members of
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`the Board and their clerical staff, other support personnel, court
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`reporters, and other persons acting on behalf of the Office.
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`(G) Support Personnel. Administrative assistants, clerical staff, court
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`reporters and other support personnel of the foregoing persons who
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`are reasonably necessary to assist those persons in the proceeding
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`shall not be required to sign an Acknowledgement, but shall be
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`informed of the terms and requirements of the Protective Order by the
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`person they are supporting who receives confidential information.
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`3. Persons receiving confidential information shall use reasonable efforts to
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`maintain the confidentiality of the information, including:
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`Page 3 of 8
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`(A) Maintaining such information in a secure location to which
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`persons not authorized to receive the information shall not have
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`access;
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`(B) Otherwise using reasonable efforts to maintain the confidentiality
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`of the information, which efforts shall be no less rigorous than those
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`the recipient uses to maintain the confidentiality of information not
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`received from the disclosing party;
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`(C) Ensuring that support personnel of the recipient who have access
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`to the confidential information understand and abide by the obligation
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`to maintain the confidentiality of information received that is
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`designated as confidential; and
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`(D) Limiting the copying of confidential information to a reasonable
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`number of copies needed for conduct of the proceeding and
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`maintaining a record of the locations of such copies.
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`4. Persons receiving confidential information shall use the following
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`procedures to maintain the confidentiality of the information:
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`(A) Documents and Information Filed With the Board.
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`(i) A party may file documents or information with the Board
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`under seal, together with a non-confidential description of the
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`nature of the confidential information that is under seal and the
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`Page 4 of 8
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`reasons why the information is confidential and should not be
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`made available to the public. The submission shall be treated
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`as confidential and remain under seal, unless, upon motion of a
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`party and after a hearing on the issue, or sua sponte, the Board
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`determines that the documents or information do not to qualify
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`for confidential treatment.
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`(ii) Where confidentiality is alleged as to some but not all of the
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`information submitted to the Board, the submitting party shall
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`file confidential and nonconfidential versions of its submission,
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`together with a Motion to Seal the confidential version setting
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`forth the reasons why the information redacted from the non-
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`confidential version is confidential and should not be made
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`available to the public. The nonconfidential version of the
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`submission shall clearly indicate the locations of information
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`that has been redacted. The confidential version of the
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`submission shall be filed under seal. The redacted information
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`shall remain under seal unless, upon motion of a party and after
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`a hearing on the issue, or sua sponte, the Board determines that
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`some or all of the redacted information does not qualify for
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`confidential treatment.
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`Page 5 of 8
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`(B) Documents and Information Exchanged Among the Parties. Information
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`designated as confidential that is disclosed to another party during discovery
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`or other proceedings before the Board shall be clearly marked as
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`“PROTECTIVE ORDER MATERIAL” and shall be produced in a manner
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`that maintains its confidentiality.
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`Page 6 of 8
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`MYLAN PHARMACEUTICALS INC.,
`Petitioner,
`
`v.
`
`ASTRAZENECA AB,
`Patent Owner.
`
`____________________________________________
`
`Case: IPR2015-01340
`U.S. Patent No. RE 44,186
`____________________________________________
`
`
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`STANDARD ACKNOWLEDGMENT
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`FOR ACCESS TO PROTECTIVE ORDER MATERIAL
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`Page 7 of 8
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`I __________________________________________, affirm that I have
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`read the Protective Order; that I will abide by its terms; that I will use the
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`confidential information only in connection with this proceeding and for no other
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`purpose; that I will only allow access to support staff who are reasonably necessary
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`to assist me in this proceeding; that prior to any disclosure to such support staff I
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`informed or will inform them of the requirements of the Protective Order; that I am
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`personally responsible for the requirements of the terms of the Protective Order
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`and I agree to submit to the jurisdiction of the Office and the United States District
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`Court for the Eastern District of Virginia for purposes of enforcing the terms of the
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`Protective Order and providing remedies for its breach.
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`Date: __________
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`By:______________________
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`Page 8 of 8