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`_________________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________
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`NATUS MEDICAL INC., NATUS NEUROLOGY INC.
`EMBLA SYSTEMS LLC AND EMBLA SYSTEMS LTD.
`Petitioners,
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`
`v.
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`
`
`NOX MEDICAL EHF.
`Patent Owner.
`________________________
`
`
`Case IPR2016-01822
`Patent 9,059,532
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`PETITIONERS’ MOTION TO SEAL
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`Pursuant to 37 C.F.R. § 42.14 and the Protective Order entered in this
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`proceeding on May 25, 2017 (see Paper Nos. 17 & 18), Petitioners hereby
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`move to seal their Petitioners’ Reply (dated October 9, 2017) and Exhibits
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`1054-61, 1063-67, 1069-71, 1073-75, and 1077-78, all filed concurrently with
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`and in support of the Petitioners’ Reply.
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`
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`There is good cause to seal these exhibits because these documents
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`were produced and/or designated by Petitioners, Patent Owner, or a third party
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`as “HIGHLY CONFIDENTIAL—ATTORNEY’S EYES ONLY” or
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`“CONFIDENTIAL” in accordance with the protective order issued by the
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`U.S. District Court for the District of Delaware (Nox Medical Ehf v. Natus
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`Neurology, Inc., Case No. 15-cv-00709-RGA (D. Del), Dkt Nos. 23 & 129)
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`and making such documents available to the public would violate that
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`protective order.
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`There is good cause to seal Petitioners’ Reply because it contains
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`information from many of the foregoing exhibits. As a result, it contains
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`information that was produced and/or designated by Petitioner, Patent Owner
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`or a third party as “HIGHLY CONFIDENTIAL—ATTORNEY’S EYES
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`ONLY” in accordance with the protective order issued by the U.S. District
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`Court for the District of Delaware (Nox Medical Ehf v. Natus Neurology, Inc.,
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`Case No. 15-cv-00709-RGA (D. Del), Dkt Nos. 23 & 129) and making such
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`
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`documents available to the public would violate that protective order.
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`Pursuant to the protective order entered in this proceeding, Petitioners are
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`providing a proposed nonconfidential redacted version of Petitioners’ Reply
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`to counsel for the parties who produced and/or designated the confidential
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`information contained therein, and, absent their objection, intend to file a
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`nonconfidential redacted version of Petitioners’ Reply up to a week after the
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`filing of the confidential version.
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`
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`For the foregoing reasons, Petitioners respectfully request that the
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`Board grant this Motion to Seal their Petitioners’ Reply (dated October 9,
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`2017) and Exhibits 1054-61, 1063-67, 1069-71, and 1073-78.
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`DATED this 9th day of October, 2017.
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`Respectfully submitted,
`
`By: s/ Marlee A. Jansen
`
`Thomas S. Reynolds, Reg. No. 45,262
`Marlee A. Jansen, Reg. No. 64,677
`Jeremy Adelson, Admitted Pro Hac Vice
`HANSEN REYNOLDS LLC
`316 N. Milwaukee St., Suite 200
`Milwaukee, WI 53202
`Telephone: (414) 273-8470
`Facsimile: (414) 273-8476
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6, I hereby certify that on this 9th day of
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`October, 2017, the foregoing PETITIONERS’ MOTION TO SEAL was
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`served via email, on the following counsel of record for Patent Owner:
`
`Chad E. Nydegger
`David R. Todd
`Brittany Frandsen
`Workman Nydegger
`60 East South Temple, Suite 1000
`Salt Lake City, UT 84111
`cnydegger@wnlaw.com
`dtodd@wnlaw.com
`bfrandsen@wnlaw.com
`
`
`s/ Marlee A. Jansen
`Marlee A. Jansen
`(Registration No. 64,677)
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