`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`WEATHERFORD INTERNATIONAL, LLC;
`WEATHERFORD/LAMB, INC.; WEATHERFORD US, LP; and
`WEATHERFORD ARTIFICIAL LIFT SYSTEMS, LLC
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.,
`Patent Owner
`________________________
`
`Case IPR2016-01517
`Patent 7,134,505
`________________________
`
`MOTION TO SEAL AND FOR
`ENTRY OF DEFAULT PROTECTIVE ORDER
`
`
`
`IPR2016-01517
`
`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Petitioners, by and through its
`
`counsel of record, move to seal Exhibit 1029 that accompanies Petitioner’s Reply to
`
`the Patent Owner’s Preliminary Response. Petitioner further requests that the Board
`
`enter the Default Protective Order submitted herewith as Exhibit 1031. See also,
`
`Office Trial Practice Guide, Appendix B, pp. 48769-71.
`
`I. GOOD CAUSE EXISTS TO SEAL PETIONER’S EXHIBIT 1029
`Good cause exists for entering a document under seal if it constitutes
`
`confidential information of Petitioner as well as entities that are not parties to the
`
`subject proceeding. See, e.g., First Quality Baby Produces, LLC v. Kimberly-
`
`Clark Worldwide, Inc., IPR2014-01021, paper 42 at 11. Exhibit 1029 constitutes
`
`confidential information of Petitioner as well as co-defendants in a litigation
`
`involving the patents-at-issue in the present IPR proceeding, but who are not
`
`parties to the present IPR proceeding. Accordingly, good cause exists to enter
`
`Exhibit 1029 under seal.
`
`II. CERTIFICATION OF CONFERENCING WITH OPPOSING PARTY
`PURSUANT TO 37 C.F.R. § 42.54
`
`Petitioner certifies that it has conferred with Patent Owner, and the parties
`
`have agreed to the terms of the Default Protective Order.
`
`III. DEFAULT PROTECTIVE ORDER
`
`Petitioner respectfully requests entry of the Default Protective Order as set
`
`1
`
`
`
`IPR2016-01517
`
`forth in the Office Trial Practice Guide, Appendix B, pp. 48769-71, a copy of
`
`which is submitted herewith as Exhibit 1031.
`
`IV. CONCLUSION
`For the foregoing reasons, Petitioner respectively requests that the Board
`
`enter the Default Protective Order and further requests that Exhibit 1029 be entered
`
`under seal as confidential material under the Default Protective Order.
`
`Dated: December 19, 2016
`
`Respectfully submitted,
`/Jason Shapiro/
`Jason Shapiro, Counsel for Petitioners
`
`2
`
`
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