`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`TRACBEAM, LLC,
`Patent Owner.
`
`Patent No. 7,525,484
`
`
`Inter Partes Review No. IPR2015-01697
`
`
`JOINT REQUEST THAT THE SETTLEMENT AND LICENSE
`AGREEMENT FILED SEPARATELY AS EXHIBIT 1011 BE
`TREATED AS BUSINESS CONFIDENTIAL INFORMATION
`AND BE KEPT SEPARATE FROM THE FILES
`
`
`
`
`
`
`IPR2015-01697
`
`Patent Owner TracBeam, LLC and Petitioner Apple Inc. hereby request that
`
`the Settlement and License Agreement filed separately as Exhibit 1011, and
`
`referenced in Patent Owner’s and Petitioner’s concurrently-filed Joint Motion to
`
`Terminate Proceeding, shall be treated as business confidential information, shall
`
`be kept separate from the file of the involved patent, and shall be made available
`
`only to Federal Government agencies on written request, or to any person on a
`
`showing of good cause pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c).
`
`It is believed that no fee is due with this filing. If necessary, however, the
`
`Commissioner is hereby authorized to charge any additional fees which may be
`
`required, or credit any overpayment to Petitioner’s counsel’s Deposit Account No.
`
`03-1952.
`
`
`
`
`
`1
`
`
`
`Dated: April 5, 2016
`
`
`
`Dated: April 5, 2016
`
`
`
`
`
`IPR2015-01697
`
`
`
`
`
`Respectfully submitted,
`
`By /Sean Luner /
`Sean Luner
`Registration No. 36,588
`DOVEL & LUNER
`201 Santa Monica Blvd, Suite 600
`Santa Monica, CA 90401
`Telephone (310) 656-7066
`sean@dovel.com
`
`Attorneys for Patent Owner TracBeam,
`LLC
`
`Respectfully submitted,
`
`By /David L. Fehrman/
`David L. Fehrman
`Registration No.: 28,600
`Martin M. Noonen
`Registration No.: 44,264
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, California 90017-3543
`P: (213) 892-5601
`F: (213) 892-5454
`
`Attorneys for Petitioner Apple Inc.
`
`
`2
`
`
`
`IPR2015-01697
`
`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the attached JOINT REQUEST THAT THE
`
`SETTLEMENT AND LICENSE AGREEMENT FILED SEPARATELY AS
`
`EXHIBIT
`
`1011 BE TREATED AS BUSINESS CONFIDENTIAL
`
`INFORMATION AND BE KEPT SEPARATE FROM THE FILES was served as
`
`of the below date by electronic mail, on the Petitioner at the following
`
`correspondence address:
`
`David L. Fehrman
`dfehrman@mofo.com
`Martin M. Noonen
`mnoonen@mofo.com
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, California 90017-3543
`
`By /Sean Luner/
`Sean Luner
`
`
`
`3
`
`
`
`Dated: April 5, 2016