`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BAKER HUGHES, A GE COMPANY, LLC
`and
`BAKER HUGHES OILFIELD OPERATIONS LLC
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.
`Patent Owner
`
`______________
`
`Case IPR2016-01496
`Patent 7,134,505
`______________
`
`
`PETITIONERS’ MOTION TO SEAL
`
`
`
`
`
`
`Case IPR2016-01496
`Patent 7,134,505
`
`Petitioners move to:
`
` seal Exhibit 1130 that was filed under seal as “Board and Parties
`
`Only” and designated as “Protective Order Material” pursuant to the
`
`Agreed Proposed Protective Order (Paper 54).
`
` redact certain testimony from Ex. 1132, Transcript of Harold E.
`
`McGowen III’s July 27, 2017 Deposition that was filed under seal as
`
`“Board and Parties Only.”
`
`Exhibit 1130 contains Petitioners’ proprietary financial data regarding sales
`
`of certain of its sleeves and packers, which is sensitive and confidential
`
`commercial information for which the seal should be maintained.
`
`The testimony redacted in Exhibit 1132, in addition to having been
`
`contemporaneously designated by Petitioners’ counsel as “subject to the protective
`
`order” (Transcript at 134:25-135:1) pursuant to the Agreed Proposed Protective
`
`Order, is based on and contains Petitioners’ highly-sensitive commercial
`
`information that was produced by Petitioners during litigation subject to a district
`
`court protective order, for which the seal should be maintained. Two versions of
`
`the Transcript have been filed: (1) a confidential, unredacted version (Ex. 1132),
`
`which Petitioners request be sealed in its entirety; and (2) a non-confidential,
`
`redacted version (Ex. 1133), for which Petitioners request that the redacted
`
`
`
`
`
`Case IPR2016-01496
`Patent 7,134,505
`testimony remain redacted. The redacted testimony can be found on page 134,
`
`from line 18 through line 24.
`
`Dated: August 17, 2017
`
`Respectfully submitted,
`
`/Mark T. Garrett/
`Mark T. Garrett, Lead Counsel
`Reg. No. 44,699
`Tel: 512.536.3031; Fax: 512.536.4598
`mark.garrett@nortonrosefulbright.com
`NORTON ROSE FULBRIGHT US LLP
`98 San Jacinto Boulevard, Suite 1100
`Austin, TX 78701
`
`Counsel for Petitioners
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-01496
`Patent 7,134,505
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on August
`
`17, 2017, a copy of this PETITIONERS’ MOTION TO SEAL was served on Lead
`
`and Backup Counsel for Patent Owner via e-mail (by consent) to:
`
`Lead Counsel:
`
`Backup Counsel:
`
`
`
`
`
`
`
`Hamad M. Hamad (Reg. No. 64,641)
`hhamad@caldwellcc.com
`Dr. Gregory J. Gonsalves (Reg. No. 43,639)
`gonsalves@gonsalveslawfirm.com
`Bradley W. Caldwell
`bcaldwell@caldwellcc.com
`Justin T. Nemunaitis
`jnemunaitis@caldwellcc.com
`
`
`
`Respectfully submitted,
`
`/Mark T. Garrett/
`Mark T. Garrett (Reg. No. 44,699)
`
`
`
`
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