`
`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 IPR2016-01506
`Patent 7,861,774
`______________
`
`
`PETITIONERS’ MOTION TO SEAL
`
`
`
`
`28620283.1
`
`
`
`Case IPR2016-01506
`Patent 7,861,774
`
`Petitioners move to:
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` seal Exhibit 1129 that was filed under seal as “Board and Parties
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`Only” and designated as “Protective Order Material” pursuant to the
`
`Agreed Proposed Protective Order (Paper 50).
`
` redact certain testimony from Ex. 1133, Transcript of Harold E.
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`McGowen III’s July 27, 2017 Deposition that was filed under seal as
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`“Board and Parties Only.”
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`Exhibit 1129 contains Petitioners’ proprietary financial data regarding sales
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`of certain of its sleeves and packers, which is sensitive and confidential
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`commercial information for which the seal should be maintained.
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`The testimony redacted in Exhibit 1133, in addition to having been
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`contemporaneously designated by Petitioners’ counsel as “subject to the protective
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`order” (Transcript at 134:25-135:1) pursuant to the Agreed Proposed Protective
`
`Order, is based on and contains Petitioners’ highly-sensitive commercial
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`information that was produced by Petitioners during litigation subject to a district
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`court protective order, for which the seal should be maintained. Two versions of
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`the Transcript have been filed: (1) a confidential, unredacted version (Ex. 1133),
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`which Petitioners request be sealed in its entirety; and (2) a non-confidential,
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`redacted version (Ex. 1138), for which Petitioners request that the redacted
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`28620283.1
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`- 1 -
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`
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`Case IPR2016-01506
`Patent 7,861,774
`testimony remain redacted. The redacted testimony can be found on page 134,
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`from line 18 through line 24.
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`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
`
`
`
`
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`28620283.1
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`- 2 -
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`
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`Case IPR2016-01506
`Patent 7,861,774
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on August
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`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)
`
`28620283.1
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