`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`
`RPX CORPORATION,
`Petitioner
`
`v.
`
`APPLICATIONS IN INTERNET TIME LLC,
`Patent Owner
`____________________
`
`Case IPR2015-01750
`US Patent No. 8,484,111
`
`Case IPR2015-01751
`Case IPR2015-01752
`Patent 7,356,482 B21
`____________________
`
`________________________________________________________________
`
`PATENT OWNER’S MOTION FOR ENTRY OF PROTECTIVE ORDER,
`MOTION TO SEAL, AND MOTION TO REDACT
`
`
`
`
`
`
`1 The word-for-word identical paper is filed in each proceeding identified in the
`heading.
`
`
`
`Patent owner Applications in Internet Time LLC respectfully submits this
`
`Motion for Entry of Protective Order, Motion to Seal, and Motion to Redact.
`
`Pursuant to 37 C.F.R. § 42.54, patent owner moves for entry of the Default
`
`Protective Order set forth in the Office Patent Trial Practice Guide. See The Office
`
`Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48771 (Aug. 14, 2012).
`
`Pursuant to 37 C.F.R. § 42.14, patent owner moves to seal Exhibits 2018,
`
`2019 and 2022 for the sole reason that these exhibits are documents designated
`
`“PROTECTIVE ORDER MATERIAL” by petitioner. Petitioner produced these
`
`documents to patent owner in response to patent owner’s request for additional
`
`discovery, which itself was ordered by the Board in Paper 11.
`
`Pursuant to 37 C.F.R. § 42.14, patent owner moves to seal its preliminary
`
`response for the sole reason that it refers to and discusses the three sealed exhibits.
`
`Concurrently with the unredacted version of its preliminary response, patent owner
`
`is filing a redacted version that will be available to the public.
`
`Patent owner has in good faith attempted to confer with petitioner’s counsel
`
`regarding this motion. Petitioner’s counsel has not responded to patent owner’s
`
`request, most likely due to the Thanksgiving holiday.
`
`
`
`
`
`
`
`1
`
`
`
`
`
`Respectfully submitted,
`
`By: /Steven C. Sereboff/
`Steven C. Sereboff (Reg. No. 37,035)
`ssereboff@socalip.com
`M. Kala Sarvaiya (Reg. No. 58,912)
`ksarvaiya@socalip.com
`SoCal IP Law Group LLP
`310 N. Westlake Boulevard, Suite 120
`Westlake Village, CA 91362
`Telephone: (805) 230-1350
`Fax: (805) 230-1355
`Attorneys for Applications in Internet Time
`LLC
`
`
`
`Date: November 27, 2015
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of this PATENT OWNER’S
`
`MOTION FOR ENTRY OF PROTECTIVE ORDER, MOTION TO SEAL, AND
`MOTION TO REDACT has been served via email on November 27, 2015, upon
`the following:
`
`Richard F. Giunta
`Elisabeth H. Hunt
`Randy J. Pritzker
`
`Rgiunta-PTAB@wolfgreenfield.com
`EHunt-PTAB@wolfgreenfield.com
`
`Dated: November 27, 2015
`
`
`
`
`
`
`
`
`
`By: /Steven C. Sereboff/
`
`Steven C. Sereboff
`
`SoCal IP Law Group LLP
`
`
`
`
`
`2
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