`To:
`Cc:
`
`Subject:
`Date:
`
`john harrop
`Trials
`Cecil Key; jay jaykesan.com; McCombs, David L.; O"Dell, David M.; Kelton, Thomas; "Jonathan Stroud
`(jonathan@unifiedpatents.com)"
`Request for Entry of Default Protective Order
`Thursday, February 14, 2019 4:44:16 PM
`
`Your Honors:
`
`Pursuant to the Board’s Order dated February 8, 2019 (Paper 65), Patent Owner and
`Petitioner hereby jointly request entry of a protective order governing the submission of
`certain materials designated as confidential and filed in this proceeding (see Paper 59).
`Specifically, the Parties jointly request automatic entry of the Default Protective Order set
`forth in Appendix B to the Trial Practice Guide, 77 Fed. Reg. 157, 48769-48771 (Aug. 4, 2012).
`The Parties further jointly request that Paper 59 be treated as confidential pursuant to the
`Default Protective Order.
`
`The Parties believe that the requested entry of the Default Protective Order adequately
`addresses the issues raised in the Board’s Order regarding the scope and precision of the
`Protective Order language in this proceeding. However, the Parties remain available to submit
`a formal motion through the E2E system should the Board desire and/or to provide any
`additional information the Board may request. The Parties are also available for a call at any
`time on Tuesday or Wednesday of next week (February 19 or 20) should the Board desire to
`speak with the Parties.
`
`Respectfully submitted,
`
`
`John Harrop
`Attorney for Patent Owner
`PO Box 320171
`Alexandria, VA 22320
`1-202-230-6480
`
`
`
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