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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES, LLC
`Patent Owner
`
`____________________
`
`Case IPR2017-01190
`Patent No. 6,717,518
`____________________
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`REVISED UNOPPOSED MOTION TO SEAL
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`
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`Patent No. 6,717,518
`IPR2017-01190
`This Revised Unopposed Motion to Seal replaces prior filed motion Paper
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`No. 7, which is hereby withdrawn. The present Motion was authorized by the
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`Board via email sent September 10, 2018 at 2:49 PM EDT. In that email, the
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`Board also authorized the filing of a public redacted version of Exhibit 1012,
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`which is filed concurrently herewith. The confidential unredacted version of
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`Exhibit 1012 was previously lodged with the Board.
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`Petitioner moves to seal Exhibit 1012, which is an excerpt from Patent
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`Owner’s infringement expert report filed in a parallel district court proceeding.
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`Exhibit 1012 discusses the operation of Petitioner’s highly confidential, nonpublic
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`source code in Petitioner’s products, which are accused of infringing U.S. Patent
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`No. 6,717,518 in the related district court proceeding. It discloses function names,
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`file names, and descriptions of Samsung’s highly confidential source code, the
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`public disclosure of which would cause irreparable harm.
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`Exhibit 1012 also includes expert opinion, photographs, and figures created
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`by Patent Owner that are not confidential. Only non-confidential portions of
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`Exhibit 1012 authored by Patent Owner were disclosed in Petitioner’s public
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`filings, i.e., Paper 19, Reply at 11 and Ex. 1020, Demonstratives at 23. None of
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`the previously disclosed material is redacted in the public redacted version of
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`Exhibit 1012.
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`1
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`Patent No. 6,717,518
`IPR2017-01190
`NOTICE OF CONSENT TO ENTRY OF THE
`DEFAULT PROTECTIVE ORDER
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`Petitioner consents to entry of the Default Protective Order. The
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`undersigned certifies that Petitioner met and conferred with Patent Owner and that
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`(1) Patent Owner does not oppose this motion and (2) Patent Owner does not
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`oppose entry of the Default Protective Order.
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`
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`Dated: September 17, 2018
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`
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`
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`By: /s/ Nicholas Whilt
` Nicholas Whilt (Reg. No. 72,081)
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`2
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`
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`Patent No. 6,717,518
`IPR2017-01190
`
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`CERTIFICATE OF SERVICE
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`The undersigned certifies pursuant to 37 C.F.R. § 42.6(e) and § 42.105 that
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`on September 17, 2018, a true and correct copy of Petitioner’s Revised
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`Unopposed Motion to Seal was served via electronic mail upon the following
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`counsel of record for Patent Owner:
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`Michael N. Zachary (pro hac vice)
`Bunsow De Mory LLP
`701 El Camino Real
`Redwood City, CA 94063
`Telephone: 650-351-7248
`Facsimile: 415-426-4744
`mzachary@bdiplaw.com com
`
`Lauren N. Robinson (Reg. No. 74,404)
`BUNSOW DE MORY LLP
`701 El Camino Real
`Redwood City, CA 94063
`lrobinson@bdiplaw.com
`
`
`Chris J. Coulson Registration No. 61,771
`Bunsow De Mory LLP
`101 Brambach Rd.
`Scarsdale, NY 10583
`Telephone: 646-502-6973
` Facsimile: 415-426-4744
`ccoulson@bdiplaw.com
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`Craig Y. Allison (Reg. No. 38,067)
`BUNSOW DE MORY LLP
`701 El Camino Real
`Redwood City, CA 94063
`callison@bdiplaw.com
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`Respectfully submitted,
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`/s/ Nicholas J. Whilt .
`Nicholas J. Whilt (Reg. No. 72,081)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`Telephone: (213) 430-6000
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`Attorney for Petitioner
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`3
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