`Motion to Seal
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`RUBICON COMMUNICATIONS, LP
`Petitioner,
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`v.
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`LEGO A/S
`Patent Owner.
`____________
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`Case IPR2016-01187
`Patent 8,894,066
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`MOTION TO SEAL CERTAIN PORTIONS OF PATENT
`OWNER’S MOTION TO VACATE INSTITUTION DECISION
`AND TERMINATE PROCEEDING AND EXHIBIT THEREOF
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`I.
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`STATEMENT OF RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.14, Patent Owner respectfully requests the Board
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`U.S. Patent No. 8,894,066
`Motion to Seal
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`seal certain portions of Motion to Vacate Institution Decision and Terminate
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`Proceeding (“Motion to Terminate”) and its Exhibit, the transcript of James
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`Thompson deposition.
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`II.
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`STATEMENT OF REASONS FOR THE RELIEF REQUESTED
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`Patent Owner respectfully requests the Board seal certain portions of the
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`Motion to Terminate and its Exhibit, the transcript of James Thompson deposition
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`and submits redacted, non-confidential versions for the public. Paper 56; Ex.
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`2022. Patent Owner believes seeking the Board’s prior authorization to file this
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`Motion to Seal would be impractical and, as a result, submits this Motion to Seal
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`without the Board’s authorization. See Office Patent Trial Practice Guide, 77 Fed.
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`Reg. 48,755, 48,762 (Aug. 14, 2012) (“Motions where it is not practical to seek
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`prior Board authorization include motions to seal . . . .”).
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`Petitioners have informed Patent Owner that parts of the Motion to
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`Terminate and the transcript of James Thompson deposition contain confidential
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`information and business strategy. See Paper 52. Accordingly, Patent Owner
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`respectfully requests certain redacted portions to remain sealed under the Board’s
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`default protective order, or alternatively, Petitioners’ newly proposed protective
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`U.S. Patent No. 8,894,066
`Motion to Seal
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`order. Ex. 1035.
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`III. CONCLUSION
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`For the foregoing reason, Patent Owner respectfully requests that the
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`unredacted version of the Motion to Terminate and its Exhibit, transcript of James
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`Thompson deposition be sealed from the public.
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` Respectfully submitted,
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`/ Elizabeth A. Alquist/
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`Andrew M. Riddles
`Registration No. 31,657
`ariddles@daypitney.com
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`Elizabeth A. Alquist
`Admitted Pro Hac Vice
`eaalquist@daypitney.com
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`
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`Day Pitney LLP
`7 Times Square
`New York, NY 10036
`Tel: (212) 297-5855
`Fax: (203) 202-3896
`Counsel for Patent Owner
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`-3-
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`Dated: March 3, 2017
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`U.S. Patent No. 8,894,066
`Motion to Seal
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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 March 3,
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`2017, a true and correct copy of Motion to Seal, via UPS Overnight, was served on
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`/ Elizabeth A. Alquist/
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`Andrew M. Riddles
`Registration No. 31,657
`ariddles@daypitney.com
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`Elizabeth A. Alquist
`Admitted Pro Hac Vice
`eaalquist@daypitney.com
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`Day Pitney LLP
`7 Times Square
`New York, NY 10036
`Tel: (212) 297-5855
`Fax: (203) 202-3896
`Counsel for Patent Owner
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`the following counsel of record:
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`Dean M. Munyon
`Anthony M. Petro
`Ryan T. Beard
`Geoffrey W. Heaven
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
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`-4-
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