`U.S. Patent No. 7,337,241
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`INTEL CORP. and CAVIUM, INC.,
`Petitioners,
`
`v.
`
`ALACRITECH, INC.,
`Patent Owner
`________________
`
`Case IPR2017-013921
`U.S. Patent No. 7,337,241
`________________
`
`
`
`
`
`JOINT MOTION TO ENTER STIPULATED PROTECTIVE ORDER
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1 Cavium, Inc., which filed a Petition in Case IPR2017-01728, has been joined as
`a petitioner in this proceeding.
`
`06973-00001/9916177.1
`
`1
`
`
`
`Case No. IPR2017-01392
`U.S. Patent No. 7,337,241
`
`Patent Owner Alacritech,
`
`Inc.
`
`(“PO”) and Petitioner
`
`Intel Corp.
`
`(“Petitioner”) submit this Joint Motion to enter a Stipulated Protective Order
`
`pursuant to the Board’s email dated March 9, 2018.
`
`In the email, the Board authorized the parties to file a joint motion to enter a
`
`Stipulated Protective Order. The Board also ordered PO to submit with the Joint
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`Motion both the Stipulated Protective Order and a marked-up comparison between
`
`the Stipulated Protective Order and Default Protective Order showing differences
`
`if the parties’ proposed Stipulated Protective Order deviated from the Default
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`Protective Order.
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`Since the Default Protective Order does not include an outside Attorneys’
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`Eyes Only designation that is necessary in this case to protect sensitive commercial
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`information, the parties have added an Attorneys’ Eyes Only designation to the
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`Default Protective Order. The parties also adapted the Default Protective order in
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`certain minor ways so that it is consistent with the protective order entered in the
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`corresponding District Court case.
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`Accordingly, PO hereby submits the Stipulated Protective Order as Exhibit
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`2400 and a marked-up comparison of the Stipulated and Default Protective Orders
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`showing differences as Exhibit 2401. PO respectfully requests that the Board enter
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`the Stipulated Protective Order. Petitioner does not oppose this request and joins
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`in the present Motion.
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`06973-00001/9916177.1
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`2
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`
`
`Date: March 15, 2018
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`
`
`
`
`
`
`Case No. IPR2017-01392
`U.S. Patent No. 7,337,241
`
`By:
`
`
`
`By:
`
`Respectfully submitted,
`
`/s/ James M. Glass, Reg. No. 46,729
`James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`Tel: (212) 849-7000
`Fax: (212) 849-7100
`Email: jimglass@quinnemanuel.com
`
`Lead Attorney for Patent Owner –
`Alacritech, Inc.
`
`
`/s/ Garland T. Stephens
`Garland T. Stephens, Reg. No. 37,242
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, TX 77002
`Tel: (713) 546-5000
`Fax: (713) 224-9511
`Email: garland.stephens@weil.com
`
`Attorneys for Petitioner Intel
`Corporation
`
`
`06973-00001/9916177.1
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`3
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`
`
`Case No. IPR2017-01392
`U.S. Patent No. 7,337,241
`
`
`
`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certify that JOINT
`
`MOTION TO ENTER STIPULATED PROTECTIVE ORDER, and all exhibits
`
`and other documents filed together with the preliminary response, were served on
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`March 15, 2018 by filing these documents through the Patent Review Processing
`
`System, as well as by e-mailing copies to:
`
`
`
`Garland T. Stephens (Reg. No. 37,242)
`garland.stephens@weil.com
`intel.alacritech.ipr@weil.com
`WEIL, GOTSHAL & MANGES LLP
`700 LOUISIANA, SUITE 1700
`HOUSTON, TX 77002-2784
`
`Anne M. Cappella (Reg. No. 43,217)
`Adrian Percer (Reg. No. 46,986)
`Jeremy Jason Lang (Reg. No. 73,604)
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Tel: (650) 802-3141
`Fax: (650) 802-3100
`anne.cappella@weil.com
`adrian.percer@weil.com
`jason.lang@weil.com
`
`Patrick D. McPherson
`David T. Xue
`Karineh Khachatourian
`DUANE MORRIS LLP
`PDMcPherson@duanemorris.com
`DTXue@duanemorris.com
`karinehk@duanemorris.com
`
`06973-00001/9916177.1
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`4
`
`
`
`
`Date: March 15, 2018
`
`
`
`Case No. IPR2017-01392
`U.S. Patent No. 7,337,241
`
`Respectfully submitted,
`
`By: /s/ James M. Glass, Reg. No. 46,729
` James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`51 Madison Avenue, 22nd Floor
`New York, NY 10010
`jimglass@quinnemanuel.com
`
`
`Lead Attorney for Patent Owner –
`Alacritech, Inc.
`
`
`
`06973-00001/9916177.1
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`5
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`
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