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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`BMW OF NORTH AMERICA, LLC,
`Petitioner
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`v.
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`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.,
`Patent Owner
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`Inter Partes Review No.: IPR2016-00196
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`U.S. Patent No. 7,241,034 C1
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`___________________
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`JOINT REQUEST TO TREAT SETTLEMENT AGREEMENT AS
`CONFIDENTIAL BUSINESS INFORMATION AND KEEP IT SEPARATE
`UNDER 37 C.F.R. § 42.74(c)
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`IPR2016-00196
`U.S. Patent No. 7,241,034
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` Joint Request for Confidential Treatment
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`Concurrently with the filing of this Request, Petitioner BMW of North
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`America, LLC and Patent Owner Adaptive Headlamp Technologies, Inc. (“Patent
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`Owner”) are filing a Joint Motion to Terminate this inter partes review of U.S.
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`Patent No. 7,241,034 (“the ʼ034 patent”) due to settlement between the parties.
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`A true copy of the parties’ written settlement agreement is being filed as an
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`exhibit contemporaneously with this joint motion to terminate. (Ex. 1021,
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`Settlement Agreement). The settlement agreement has been filed for access by the
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`“Parties and Board Only.”
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` The settlement agreement contains business
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`confidential information, and the parties hereby request that the settlement be kept
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`separately, treated as business confidential information, and made available only
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`under the provisions of 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c).
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`The filing of this joint request was authorized by the Board in an e-mail
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`communication on April 5, 2016.
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`Date: April 6, 2016
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`Respectfully submitted,
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`/Jeffrey D. Sanok/
`Jeffrey D. Sanok, Reg. No. 32169
`Jonathan M. Lindsay, Reg. No. 45810
`Crowell & Moring LLP
`1001 Pennsylvania Avenue NW
`Washington, DC 20004-2595
`Tel.: (202) 624-2500
`Fax.: (202) 628-5116
`jsanok@crowell.com
`jlindsay@crowell.com
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`1
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`IPR2016-00196
`U.S. Patent No. 7,241,034
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` Joint Request for Confidential Treatment
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`Counsel for Petitioner
`BMW of North America, LLC
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`/Brett M. Pinkus/
`Brett M. Pinkus, Reg. No. 59980
`Friedman, Suder & Cooke
`604 E. Fourth Street, Suite 200
`Fort Worth, TX 76102
`Tel.: (817) 334-0400
`Fax.: (817) 334-0401
`pinkus@fsclaw.com
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`Counsel for Patent Owner
`Adaptive Headlamp Technologies,
`Inc.
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`Date: April 6, 2016
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`2
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`IPR2016-00196
`U.S. Patent No. 7,241,034
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` Joint Request for Confidential Treatment
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that, on this 6th day of April 2016, a true and
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`correct copy of the foregoing JOINT REQUEST TO TREAT SETTLEMENT
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`AGREEMENT AS CONFIDENTIAL BUSINESS INFORMATION AND KEEP
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`IT SEPARATE UNDER 37 C.F.R. § 42.74(c) was served by Petitioner via e-mail
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`on the attorney of record for the Patent Owner, who is also Patent Owner’s
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`attorney of record in the co-pending litigation, at the following address:
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`Attorney of Record
`for Patent Owner:
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`Brett M. Pinkus, Reg. No. 59980
`Friedman, Suder & Cooke
`604 E. Fourth Street, Suite 200
`Fort Worth, TX 76102
`Tel.: (817) 334-0400
`Fax.: (817) 334-0401
`pinkus@fsclaw.com
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`/Jonathan Lindsay /
`Jonathan M. Lindsay, Reg. No. 45810
`CROWELL & MORING LLP
`1001 Pennsylvania Avenue NW
`Washington, DC 20004-2595
`Tel.: (949) 263-8400
`Fax.: (949) 263-8414
`JLindsay@crowell.com
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`3