`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`MICROSOFT CORPORATION,
`Petitioner
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`v.
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`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`____________________
`
`CASE IPR2016-00449
`Patent 8,924,506 B2
`____________________
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`PATENT OWNER’S UNOPPOSED MOTION TO SEAL
`PURSUANT TO 37 C.F.R. § 42.14
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54 Patent Owner Bradium
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`Technologies LLC (“Patent Owner”) respectfully requests that the Board seal
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`portions of Patent Owner’s Reply in Support of Patent Owner’s Motion to Exclude
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`and Exhibit 2082, a November 23, 2016 Letter to Isaac Levanon of 3-D-V-U Israel
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`(2000) Ltd. (“3DVU Israel”) from DENSO Corp.
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`The Parties have conferred regarding this motion and Petitioner Microsoft
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`Corporation does not oppose the Motion.
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`I.
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`PATENT OWNER’S MOTION TO SEAL
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`The Office Patent Trial Practice Guide provides that “the rules aim to strike
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`a balance between the public’s interest in maintaining a complete and
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`understandable file history and the parties’ interest in protecting truly sensitive
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`information.” 77 Fed. Reg. 48,756, 48,760 (Aug. 14, 2012). Those rules “identify
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`confidential information in a manner consistent with Federal Rule of Civil
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`Procedure 26(c)(1)(G), which provides for protective orders for trade secret or
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`other confidential research, development, or commercial information.” Id. (citing
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`37 C.F.R. § 42.54).
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`Patent Owner Bradium has good cause to seal portions of its Reply to
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`Petitioner’s Opposition to Patent Owner’s Motion to Exclude because the portions
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`in question reference material for which 3-D-V-U Israel (2000) Ltd. is under a
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`confidentiality obligation pursuant to Exhibit 2029. As explained in Bradium’s
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`1
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`
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`November 11, 2016 Motion to Seal (Paper 15), Exhibit 2029 is a confidential
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`License Agreement signed by Mr. Isaac Levanon. The agreement imposes a
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`confidentiality requirement. Exhibit 2029 at 7 (Section 11). DENSO Corporation
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`has requested that Patent Owner Bradium maintain Exhibit 2029 as confidential
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`pursuant to a protective order.
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`Exhibit 2082 is a confidential letter from DENSO to 3-D-V-U Israel (2000)
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`Ltd. that relates to information for which 3-D-V-U Israel (2000) Ltd. and Bradium
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`are under a confidentiality obligation pursuant to Exhibit 2029.
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`In accordance with the Protective Order (Paper 15, Exhibit A) § 4(A)(ii), the
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`non-confidential version of the Patent Owner’s Reply to Petitioner’s Opposition to
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`Patent Owner’s Motion to Exclude is concurrently being filed by Patent Owner
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`with confidential information redacted.
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`II.
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`CONCLUSION
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`For the foregoing reasons, Patent Owner respectfully requests that the Board
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`seal the portions of Patent Owner’s Reply in Support of Patent Owner’s Motion to
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`Exclude and Exhibit 2082.
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`
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`2
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`Dated: April 7, 2017
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`
`
`/s/ Chris J. Coulson
`Chris J. Coulson (Reg. No. 61,771)
`Lead Counsel for Patent Owner
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
`
`Michael Zachary (pro hac vice)
`michaelzachary@andrewskurthkenyon.com
`Clifford Ulrich (Reg. No. 42,194)
`cliffordulrich@andrewskurthkenyon.com
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`3
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on April 7,
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`2017, the foregoing Patent Owner’s Motion to Seal is being served via electronic
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`mail upon the following counsel of record for Petitioner:
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`Chun M. Ng (Reg. No. 36,878)
`Matthew Bernstein (pro hac vice)
`Vinay Sathe (Reg. No. 55,595)
`Patrick McKeever (Reg. No. 66,019)
`Evan Day (pro hac vice)
`PerkinsServiceBradiumIPR@perkinscoie.com
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`/s/ Chris J. Coulson
`Chris J. Coulson
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
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