`U.S. Patent No. 8,577,813
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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,
`
`v.
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`UNIVERSAL SECURE REGISTRY LLC
`Patent Owner
`________________
`
`Case IPR2018-00067
`U.S. Patent No. 8,577,813
`________________
`
`JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER
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`
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`Joint Motion for Protective Order, Case No. IPR2018-00067
`U.S. Patent No. 8,577,813
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`I.
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`RELIEF REQUESTED.
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`Pursuant to the Board’s Scheduling Order in the above-captioned matter
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`(Paper 16 at 2), Petitioner Unified Patents, Inc. (“Unified”) and Patent Owner
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`Universal Secure Registry LLC (“USR”) hereby submit this Joint Motion for Entry
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`of Protective Order. The parties have agreed to the [Proposed] Stipulated Protective
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`Order (“Proposed SPO”) submitted herewith as Exhibit 2001. The Proposed SPO is
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`a slightly revised version of the Board’s Default Protective Order, as indicated by
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`the redlined comparison submitted as Exhibit 2002. The parties respectfully request
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`that the Board enter the Proposed SPO in this proceeding. The Board provided
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`authorization for filing this motion via e-mail dated August 20, 2018.
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`II. GOOD CAUSE EXISTS FOR THE BOARD TO ENTER THE
`PROPOSED PROTECTIVE ORDER.
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`The Proposed SPO is a revised version of the Board’s Default Protective
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`Order, containing a few small revisions.
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`First, it has been revised to include a “HIGHLY CONFIDENTIAL –
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`ATTORNEYS’ EYES ONLY,” such that competitively sensitive information will
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`be shielded from disclosure to the opposing party’s officers or employees.
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`Second, it provides that to the extent information is made available for
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`inspection, those items need not be marked with a confidentiality designation until
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`the item is copied. The default protective order does not include a provision
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`1
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`Joint Motion for Protective Order, Case No. IPR2018-00067
`U.S. Patent No. 8,577,813
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`specifically addressing materials made available for inspection, and the procedure
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`here provide an efficient manner of designation.
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`Third, it provides that the parties should meet and confer in good faith if there
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`is a disagreement on confidentiality designations, which will help ensure the parties
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`do not burden the Board unnecessarily.
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`Fourth, it provides small revisions to the provisions relating to who may view
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`confidential materials, including provisions relating to outside counsel being
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`permitted to view the materials and placing a limit on the number of employees of a
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`party that may view the materials. These small revisions are designed to avoid
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`inadvertent disclosure of confidential materials.
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`Fifth, it provides that privileged materials may be redacted from documents
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`that are produced and that confidential materials will only be used for this
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`proceeding, in order to protect confidential materials and privileged information.
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`To protect the parties’ confidential information and to promote efficiency in
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`the resolution of their dispute, the parties submit that good cause exists for the Board
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`to enter the proposed Protective Order.
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`III. CONCLUSION
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`
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`For the foregoing reasons, the parties respectfully request that the Board
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`grant this motion and enter the [Proposed] Stipulated Protective Order (Ex. 2001)
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`in this proceeding.
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`2
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`Joint Motion for Protective Order, Case No. IPR2018-00067
`U.S. Patent No. 8,577,813
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`Date: August 21, 2018
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` 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
`Tel: (212) 849-7000
`Fax: (212) 849-7100
`Email: jimglass@quinnemanuel.com
`
`Lead Attorney for Patent Owner –
`Universal Secure Registry LLC
`
`
`
`BY: /s/ Jason R. Mudd
`Jason R. Mudd, Reg. No. 57,700
`Roshan Mansinghani, Reg. No. 62,429
`Eric A. Buresh, Reg. No. 50,394
`Jonathan Stroud, Reg. No. 72,518
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`ATTORNEYS FOR PETITIONER
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`3
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`Joint Motion for Protective Order, Case No. IPR2018-00067
`U.S. Patent No. 8,577,813
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certify that this
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`JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER was served on August
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`21, 2018 by filing these documents through the Patent Review Processing System,
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`as well as by e-mailing copies to attorneys of record, including:
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`
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` jimglass@quinnemanuel.com
` nimahefazi@quinnemanuel.com
` chrismathews@quinnemanuel.com
` tigranguledjian@quinnemanuel.com
` richardlowry@quinnemanuel.com
` jason.mudd@eriseip.com
` eric.buresh@eriseip.com
` ptab@eriseip.com
` roshan@unifiedpatents.com
` jonathan@unifiedpatents.com
`
`Date: August 21, 2018
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`
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`By: _/s/ Nima Hefazi_________________
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`4
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