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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`STEADYMED LTD.
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`Petitioner
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`v.
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`UNITED THERAPEUTICS CORPORATION
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`Patent Owner
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`U.S. Patent No. 8,497,393
`Issue Date: Jul. 30, 2013
`Title: PROCESS TO PREPARE TREPROSTINIL, THE ACTIVE
`INGREDIENT IN REMODULIN®
`_______________
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`Case IPR2016-00006
`_______________
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`MOTION TO SEAL
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`4822-9938-5644.2
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`IPR2016-00006
`Patent 8,497,393
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`United Therapeutics Corporation (“Patent Owner”) hereby submits this
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`Motion to Seal certain portions of the deposition transcripts of Dr. Ruffolo (Ex.
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`2058) and Dr. Williams (Ex. 2059). The exact words and numbers being redacted
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`are shown in the attached, redacted versions of:
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`(1) Dr. Ruffolo’s deposition transcript (Ex. 2058): pp. 76-79, 81, 138-142,
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`159-161, 180, 182-184, 186-187, 194-196, 214, 216-218, 230, 232-233,
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`262-263, 265-267, 269-270, 274-277, 279-281, 303, 308-310, 316-318,
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`323-324, 330-333, 335-337, 339-343, 345-348, 350-351, and 355-358;
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`and
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`(2) Dr. Williams’ deposition transcript (Ex. 2059): pp. 28, 46, 48, 50, 60-62,
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`64-67, 76-78, 85, 90-96, 98, 100-102, 105-107, 113, 115-116, 119, 121-
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`127, 143, 150-151, 194, 196, 203, 217-219, 251-252, 258, 281-284, 286,
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`291, 297, 304, and 308-309.
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`Patent Owner has discussed the proposed redactions with Petitioner, who has
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`indicated that it has no objection if the sealed information follows the Board’s
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`earlier ruling in Paper No. 27. Pursuant to 37 C.F.R. § 42.12, Patent Owner seeks
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`to seal these limited portions of Ex. 2058 and Ex. 2059 because they discuss
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`information that the Board has already ruled upon and determined to be
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`confidential: “we agree with the parties that the disclosed numerical amounts and
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`ranges, identity of the impurities detected, and particulars of the FDA treprostinil
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`purity standard is confidential information concerning the manufacturing process
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`for Remodulin®, submitted and held in confidence to the FDA, and susceptible to
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`misuse by competitors seeking commercial advantage” (Paper No. 27 at p. 5).
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`I. Good Cause Exists for Sealing Certain Confidential Information
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`Each of the proposed redactions contains information that the Board has
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`already ruled upon and determined to be confidential in Paper No. 27, so good
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`cause has already been found by the Board for sealing this information.
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`II. Certification of Non-Publication
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`On behalf of Patent Owner, undersigned counsel certifies that, to the best of
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`their knowledge, the information sought to be sealed by this Motion to Seal has not
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`been published or otherwise made public.
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`III. Certification of Conference with Opposing Party Pursuant to 37
`C.F.R. § 42.54
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`Patent Owner and Petitioner have conferred about this Motion to Seal and
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`Petitioner has no objection.
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`IV. Protective Order
`The Board has entered a protective order in Paper No. 16, which the parties
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`have agreed will govern handling of information designated confidential in this
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`proceeding.
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`4822-9938-5644.2
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`IPR2016-00006
`Patent 8,497,393
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`V. Conclusion
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`For the reasons stated above, Patent Owner respectfully requests that the
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`portions indicated herein of Ex. 2058 and Ex. 2059 remain under seal and only the
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`accompanying redacted versions of Ex. 2058 and Ex. 2059 be made available to
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`the public.
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`Date: Sept. 22, 2016
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`Respectfully submitted,
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`/Stephen B. Maebius/
`Stephen B. Maebius
`Reg. No. 35,264
`Counsel for Patent Owner
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`4822-9938-5644.2
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`IPR2016-00006
`Patent 8,497,393
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Motion to Seal
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`and accompanying documents and exhibits were served on counsel of record for
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`Petitioner on Sept. 22, 2016 by delivering a copy via email to Stuart Pollack and Lisa
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`Haile (the counsel of record for the Petitioner) at the following address:
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`Steadymed-IPR@dlapiper.com
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`Date: Sept. 22, 2016
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`signature: /Stephen B. Maebius/
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`Stephen B. Maebius
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