`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`STEADYMED LTD.,
`
`Petitioner,
`
`v.
`
`UNITED THERAPEUTICS CORPORATION
`
`Patent Owner.
`
`
`
`Case IPR2016-00006
`
`Patent No. 8,497,393
`
`____________
`
`PETITIONER’S MOTION TO SEAL
`
`
`
`
`
`Mail Stop "Patent Board"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`
`
`SteadyMed Ltd. (“Petitioner”) hereby submits this Motion to Seal certain
`
`portions of its Opposition to Patent Owner’s Motion to Exclude (“Opposition”).
`
`The exact words and numbers being redacted are shown in the redacted version of
`
`the Opposition filed concurrently herewith, on pp. 1 and 2.
`
`Pursuant to Patent Owner’s previous requests, Petitioner files this Motion to
`
`Seal these specific, limited portions of Petitioner’s Opposition because they cite
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`numeric purity information that Patent Owner contends is confidential.
`
`Notwithstanding the foregoing request, Petitioner: (1) makes this Motion pursuant
`
`to Patent Owner’s previous requests and Patent Owner’s contention that they are
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`confidential; (2) does not believe the requested portions are confidential, or that
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`they should remain under seal; and (3) further requests that the November 29 oral
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`hearing in this matter be made open to the public.
`
`I.
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`Good Cause Exists for Sealing Certain Confidential Information
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`Each of the proposed redactions contain information that Patent Owner
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`contends is confidential. Patent Owner asserts that good cause exists for sealing
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`this information. Petitioner disagrees, but does not wish to dispute this issue at this
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`time, but seeks to keep the oral argument open to the public.
`
`
`
`2
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`
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`II. Certification of Non-Publication
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`Based on Patent Owner’s previous representations, the undersigned counsel
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`certifies that, to the best of their knowledge the information sought to be sealed by
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`this Motion to Seal has not 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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`Petitioner and Patent Owner have previously conferred about the
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`information contained in this Motion to Seal and Patent Owner has no objection to
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`sealing the requested portions.
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`IV. Protective Order
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`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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`V. Conclusion
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`For the reasons stated above, based on Patent Owner’s request, Petitioner
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`files this Motion requesting that the portions indicated herein of its Opposition be
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`placed under seal for now, and only the redacted versions of its Opposition be
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`made available to the public.
`
`
`
`
`
`
`
`3
`
`
`
`
`
`Date: November 15, 2016
`
`
`/s Stuart E. Pollack /
`Stuart E. Pollack, J.D. Ph.D.
`Reg. No. 43,862
`DLA Piper LLP (US)
`
`
`
`Respectfully submitted,
`
`
`/s Lisa A. Haile /
`Lisa A. Haile, J.D., Ph.D.
` Reg. No. 38,347
`DLA Piper LLP (US)
`
`
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the attached Motion to Seal was
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`served via electronic mail to the following:
`
`Stephen B. Maebius
`George Quillin
`FOLEY & LARDNER LLP
`UT393-IPR@foley.com
`
`Shaun R. Snader
`UNITED THERAPEUTICS CORP.
`ssnader@unither.com
`
`Douglas Carsten
`Richard Torczon
`Robert Delafield
`WILSON, SONSINI, GOODRICH & ROSATI
`dcarsten@wsgr.com
`rtorczon@wsgr.com
`bdelafield@wsgr.com
`
`
`Date: November 15, 2016
`
`
`/s Stuart E. Pollack /
`Stuart E. Pollack, J.D., Ph.D.
`Reg. No. 43,862
`DLA Piper LLP (US)
`
`WEST\274320756.1
`
`Respectfully submitted,
`
`
`
`
`/s Lisa A. Haile /
`Lisa A. Haile, J.D., Ph.D.
` Reg. No. 38,347
`DLA Piper LLP (US)
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