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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`BMW OF NORTH AMERICA, LLC,
`Petitioner
`
`v.
`
`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.,
`Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`Inter Partes Review No.: IPR2016-00196
`
`U.S. Patent No. 7,241,034 C1
`
`___________________
`
`
`JOINT REQUEST TO TREAT SETTLEMENT AGREEMENT AS
`CONFIDENTIAL BUSINESS INFORMATION AND KEEP IT SEPARATE
`UNDER 37 C.F.R. § 42.74(c)
`
`

`
`IPR2016-00196
`U.S. Patent No. 7,241,034
`
`
` Joint Request for Confidential Treatment
`
`Concurrently with the filing of this Request, Petitioner BMW of North
`
`America, LLC and Patent Owner Adaptive Headlamp Technologies, Inc. (“Patent
`
`Owner”) are filing a Joint Motion to Terminate this inter partes review of U.S.
`
`Patent No. 7,241,034 (“the ʼ034 patent”) due to settlement between the parties.
`
`A true copy of the parties’ written settlement agreement is being filed as an
`
`exhibit contemporaneously with this joint motion to terminate. (Ex. 1021,
`
`Settlement Agreement). The settlement agreement has been filed for access by the
`
`“Parties and Board Only.”
`
` The settlement agreement contains business
`
`confidential information, and the parties hereby request that the settlement be kept
`
`separately, treated as business confidential information, and made available only
`
`under the provisions of 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c).
`
`The filing of this joint request was authorized by the Board in an e-mail
`
`communication on April 5, 2016.
`
`
`
`
`
`
`
`
`
`
`
`Date: April 6, 2016
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/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
`
`1
`
`

`
`IPR2016-00196
`U.S. Patent No. 7,241,034
`
`
` Joint Request for Confidential Treatment
`
`
`Counsel for Petitioner
`BMW of North America, LLC
`
`
`
`
`/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
`
`Counsel for Patent Owner
`Adaptive Headlamp Technologies,
`Inc.
`
`Date: April 6, 2016
`
`
`
`
`
`
`
`2
`
`

`
`IPR2016-00196
`U.S. Patent No. 7,241,034
`
`
` Joint Request for Confidential Treatment
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that, on this 6th day of April 2016, a true and
`
`correct copy of the foregoing JOINT REQUEST TO TREAT SETTLEMENT
`
`AGREEMENT AS CONFIDENTIAL BUSINESS INFORMATION AND KEEP
`
`IT SEPARATE UNDER 37 C.F.R. § 42.74(c) was served by Petitioner via e-mail
`
`on the attorney of record for the Patent Owner, who is also Patent Owner’s
`
`attorney of record in the co-pending litigation, at the following address:
`
`
`
`Attorney of Record
`for Patent Owner:
`
`
`
`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
`
`
`/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
`
`
`
`3

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