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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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`WEATHERFORD INTERNATIONAL, LLC;
`WEATHERFORD/LAMB, INC.; WEATHERFORD US, LP; and
`WEATHERFORD ARTIFICIAL LIFT SYSTEMS, LLC
`Petitioners
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`v.
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`PACKERS PLUS ENERGY SERVICES, INC.,
`Patent Owner
`________________________
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`Case IPR2016-01509
`Patent 7,861,774
`________________________
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`MOTION TO SEAL AND FOR
`ENTRY OF DEFAULT PROTECTIVE ORDER
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`
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`IPR2016-01509
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Petitioners, by and through its
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`counsel of record, move to seal Exhibit 1029 that accompanies Petitioner’s Reply to
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`the Patent Owner’s Preliminary Response. Petitioner further requests that the Board
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`enter the Default Protective Order submitted herewith as Exhibit 1031. See also,
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`Office Trial Practice Guide, Appendix B, pp. 48769-71.
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`I. GOOD CAUSE EXISTS TO SEAL PETIONER’S EXHIBIT 1029
`Good cause exists for entering a document under seal if it constitutes
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`confidential information of Petitioner as well as entities that are not parties to the
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`subject proceeding. See, e.g., First Quality Baby Produces, LLC v. Kimberly-
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`Clark Worldwide, Inc., IPR2014-01021, paper 42 at 11. Exhibit 1029 constitutes
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`confidential information of Petitioner as well as co-defendants in a litigation
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`involving the patents-at-issue in the present IPR proceeding, but who are not
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`parties to the present IPR proceeding. Accordingly, good cause exists to enter
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`Exhibit 1029 under seal.
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`II. CERTIFICATION OF CONFERENCING WITH OPPOSING PARTY
`PURSUANT TO 37 C.F.R. § 42.54
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`Petitioner certifies that it has conferred with Patent Owner, and the parties
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`have agreed to the terms of the Default Protective Order.
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`III. DEFAULT PROTECTIVE ORDER
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`Petitioner respectfully requests entry of the Default Protective Order as set
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`1
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`IPR2016-01509
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`forth in the Office Trial Practice Guide, Appendix B, pp. 48769-71, a copy of
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`which is submitted herewith as Exhibit 1031.
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`IV. CONCLUSION
`For the foregoing reasons, Petitioner respectively requests that the Board
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`enter the Default Protective Order and further requests that Exhibit 1029 be entered
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`under seal as confidential material under the Default Protective Order.
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`Dated: December 19, 2016
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`Respectfully submitted,
`/Jason Shapiro/
`Jason Shapiro, Counsel for Petitioners
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