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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`COALITION FOR AFFORDABLE DRUGS V LLC;
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`HAYMAN CREDES MASTER FUND, L.P.;
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`HAYMAN ORANGE FUND SPC — PORTFOLIO A;
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`I-IAYMAN CAPITAL MASTER FUND, L.P.;
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`HAYMAN CAPITAL MANAGEMENT, L.P.;
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`HAYMAN OFFSHORE MANAGEMENT, INC.;
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`HAYMAN INVESTMENTS, LLC;
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`NXN PARTNERS, LLC;
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`IP NAVIGATION GROUP, LLC;
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`J KYLE BASS; and ERICH SPANGENBERG,
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`Petitioner,
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`V.
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`BIOGEN MA INC.,
`Patent Owner.
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`Case IPR2015—O1993
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`Patent 8,399,514 B2
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`STANDING PROTECTIVE ORDER
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`Page 1 05
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`Biogen Exhibit 2084
`Coalition v. Biogen
`IPR2015-01993
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`Page 1 of 5
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`Biogen Exhibit 2084
`Coalition v. Biogen
`IPR2015-01993
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`U.S. Patent No. 8,399,514
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`Case: IPR2015—01993
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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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`l.
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`Confidential information shall be clearly marked “PROTECTIVE
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`ORDER MATERIAL.”
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`2.
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`Access to confidential information is limited to the following
`individuals who have executed the acknowledgment appended to this order:
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`(A)
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`(B)
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`(C)
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`(D)
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`(E)
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`Parties. Persons who are owners of a patent involved in the
`proceeding and other persons who are named parties to the
`proceeding.
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`Party Representanives. Representatives of record for a party in the
`proceeding.
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`Experts. Retained experts of a party in the proceeding who fiirther
`certify in the Acknowledgement that they are not a competitor to any
`party, or a consultant for, or employed by, such a competitor with
`respect to the subject matter of the proceeding.
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`In—house counsel.
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`In—house counsel of a party.
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`Other Employees ofa Party. Employees, consultants or other persons
`performing work for a party, other than in—house counsel and in-house
`counsel’s support staff, who sign the Acknowledgement shall be
`extended access to confidential information only upon agreement of
`the parties or by order of the Board upon a motion brought by the
`party seeking to disclose confidential to that person. The party
`opposing disclosure to that person shall have the burden of proving
`that such person should be restricted from access to confidential
`information.
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`(F)
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`The Oflice. Employees and representatives of the Office who have a
`need for access to the confidential information shall have such access
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`without the requirement to sign an Acknowledgement. Such
`employees and representatives shall include the Director, members of
`the Board and their clerical staff, other support personnel, court
`reporters, and other persons acting on behalf of the Office.
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`Page 2 of 5
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`U.S. Patent No. 8,399,514
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`Case: IPR2015-01993
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`(G)
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`Support‘ Personnel. Administrative assistants, clerical staff, court
`reporters and other support personnel of the foregoing persons who
`are reasonably necessary to assist those persons in the proceeding
`shall not be required to sign an Acknowledgement, but shall be
`informed of the terms and requirements of the Protective Order by the
`person they are supporting who receives confidential information.
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`Persons receiving confidential information shall use reasonable efforts
`3.
`to maintain the confidentiality of the information, including:
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`(A)
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`(B)
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`(C)
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`(D)
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`Maintaining such information in a secure location to which persons
`not authorized to receive the information shall not have access;
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`Otherwise using reasonable efforts to maintain the confidentiality of
`the information, which efforts shall be no less rigorous than those the
`recipient uses to maintain the confidentiality of information not
`received from the disclosing party;
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`Ensuring that support personnel of the recipient who have access to
`the confidential information understand and abide by the obligation to
`maintain the confidentiality of information received that is designated
`as confidential; and
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`Limiting the copying of confidential information to a reasonable
`number of copies needed for conduct of the proceeding and
`maintaining a record of the locations of such copies.
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`4.
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`Persons receiving confidential information shall use the following
`procedures to maintain the confidentiality of the information:
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`(A)
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`Documents and Information Ftied With the Board.
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`(i)
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`A party may file documents or information with the Board
`under seal, together with a non-confidential description of the
`nature of the confidential information that is under seal and the
`reasons why the information is confidential and should not be
`made available to the public. The submission shall be treated
`as confidential and remain under seal, unless, upon motion of a
`party and after a hearing on the issue, or two sporzte, the Board
`determines that the documents or information do not to qualify
`for confidential treatment.
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`Page 3 of 5
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`U.S. Patent No. 8,399,514
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`Case: IPR20l5—0l993
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`(ii) Where confidentiality is alleged as to some but not all of the
`information submitted to the Board, the submitting party shall
`file confidential and non-confidential versions of its
`submission, together with a Motion to Seal the confidential
`version setting forth the reasons why the information redacted
`from the non—confidential version is confidential and should not
`be made available to the public. The non-confidential version
`of the submission shall clearly indicate the locations of
`information that has been redacted. The confidential version of
`the submission shall be filed under seal. The redacted
`information shall remain under seal unless, upon motion of a
`party and after a hearing on the issue, or sun sponre, the Board
`determines that some or all of the redacted information does not
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`qualify for confidential treatment.
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`(B) Documents and Information Exchanged Among the Parties.
`Information designated as confidential that is disclosed to another
`party during discovery or other proceedings before the Board shall be
`clearly marked as “PROTECTIVE ORDER MATERIAL” and shall
`be produced in a manner that maintains its confidentiality.
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`Standard Acknowledgment‘ ofProtective Order. The following form may be
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`used to acknowledge a protective order and gain access to information covered by
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`the protective order:
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`U.S. Patent No. 8,399,514
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`Case: IPR20l5-01993
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`1, _Carol A. Spiegel
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`, affirm that I have read the
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`Protective Order; that I will abide by its terms; that I will use the confidential
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`information only in connection with this proceeding and for no other purpose; that
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`I will only allow access to support staff who are reasonably necessary to assist me
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`in this proceeding; that prior to any disclosure to such support staff I informed or
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`will inform them of the requirements of the Protective Order; that I am personally
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`responsible for the requirements of the terms of the Protective Order and I agree to
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`submit to the jurisdiction of the Office and the United States District Court for the
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`Eastern District of Virginia for purposes of enforcing the terms of the Protective
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`Order and providing remedies for its breach.
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`Dated: 21 June 2016
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`By: @ %5?5é
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`Carol A. Spiegel
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