`
`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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`UNIFIED PATENTS INC.
`
`Petitioner
`
`- vs. -
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`FALL LINE PATENTS, LLC
`
`Patent Owner
`———————
`
`IPR2018-00043
`
`U.S. Patent 9,454,748
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`PETITIONER’S MOTION TO SEAL
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`
`
`
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`
`
`
`
`
`
`
`
`Motion to Seal
`IPR2018-00043 (U.S. Patent 9,454,748)
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`I.
`
`Introduction.
`
`Petitioner
`
`requests
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`that Petitioner’s Response
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`to Patent Owner’s
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`Observations, and Exhibit 1028, filed herewith, be sealed under 37 C.F.R. § 42.54
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`and the Parties’ Agreed-Upon Default Protective Order (previously filed). Good
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`cause to seal these documents exists because they contain sensitive, non-public
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`information.
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`II. Good Cause Exists for Sealing Certain Confidential Information.
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`The Office Patent Trial Practice Guide provides that “the rules aim to strike
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`a balance between
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`the public’s
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`interest
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`in maintaining a complete and
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`understandable file history and the parties’ interest in protecting truly sensitive
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`information.” 77 Fed. Reg. 48756, 48760 (Aug. 14, 2012). Further, those rules
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`“identify confidential information in a manner consistent with Federal Rule of
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`Civil Procedure 26(c)(1)(G), which provides for protective orders for trade secret
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`or other confidential research, development, or commercial information.” Id.
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`(citing 37 C.F.R. § 42.54).
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`Petitioner’s Response to Patent Owner’s Observations and Exhibit 1028
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`contain information that Petitioner has identified as confidential business
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`information.
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`Petitioner’s Response to Patent Owner’s Observations references and
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`describes the content of the deposition of Kevin Jakel (transcript previously filed
`
`2
`
`
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`Motion to Seal
`IPR2018-00043 (U.S. Patent 9,454,748)
`as Exhibit 2009), Petitioner’s CEO, in which sensitive business information that
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`has not been published or otherwise made public was discussed. A Motion to Seal
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`was previously filed for Exhibit 2009 by Patent Owner.
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`Exhibit 1028 is an errata sheet for the transcript of Mr. Jakel’s deposition,
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`which was filed as Exhibit 2009, designated as confidential, and likewise contains
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`sensitive business information that has not been published or otherwise made
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`public.
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`III. Conclusion
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`For the above reasons, Petitioner requests that Petitioner’s Response to
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`Patent Owner’s Observations and Exhibit 1028 be placed under seal.
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`March 1, 2019
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`
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`
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`Respectfully submitted,
`
`
`/David W. OBrien/
`David W. O’Brien
`Counsel for Petitioner
`Registration No. 40,107
`HAYNES AND BOONE, LLP
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`3
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