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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`FALL LINE PATENTS, LLC
`Patent Owner
`__________________
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`Case IPR2018-00043
`Patent 9,454,748
`__________________
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`PATENT OWNER’S MOTION TO SEAL
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`Pursuant to the Protective Order requested by the parties, Patent Owner
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`respectfully moves to seal its RPI Observations (Paper 30) and the deposition
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`transcript of Petitioner’s witness, Kevin Jakel (Exhibit 2009). Good cause exists
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`because Petitioner has stated that these documents contain Petitioner’s confidential
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`information.
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`Exhibit 2009, the deposition transcript of Kevin Jakel, was designated as
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`confidential by Petitioners. The deposition transcript includes sensitive business
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`information that Petitioner asserts has not been published or otherwise made
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`public.
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`Paper 30, Patent Owner’s RPI Observations regarding Mr. Jakel’s testimony,
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`contains the same sensitive business information that Petitioner asserts has not
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`been published or otherwise made public.
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`For the above reasons, Patent Owner requests that Exhibit 2009 and Patent
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`Owner’s RPI Observations be placed under seal.
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`Dated: February 22, 2019
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`Respectfully submitted,
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`__/Michael D. Ellis/__
`Michael D. Ellis
`Reg. No. 72,628
`Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on February 22,
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`2019, the foregoing document was served via email on counsel for Petitioner:
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`HAYNES AND BOONE, LLP
`David O’Brien (David.obrien.ipr@haynesboone.com)
`Raghav Bajaj (Raghav.bajaj.ipr@haynesboone.com)
`David McCombs (David.mccombs.ipr@haynesboone.com)
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`UNIFIED PATENTS INC.
`Jonathan Stroud (jonathan@unifiedpatents.com)
`Roshan Mansinghani (roshan@unifiedpatents.com)
`Jonathan Bowser (jbowser@unifiedpatents.com)
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`__/Michael D. Ellis/___
`Michael D. Ellis
`Counsel for Patent Owner
`Reg. No. 72,628
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