`U.S. Patent 8,577,813
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`UNIVERSAL SECURE REGISTRY LLC
`Patent Owner
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`____________
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`IPR2018-00067
`Patent 8,577,813
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`PETITIONER’S UNOPPOSED MOTION TO SEAL
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`I.
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`RELIEF REQUESTED
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`IPR2018-00067
`U.S. Patent No. 8,577,813
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`On August 21, 2018, the parties filed a “Joint Motion for Protective Order,”
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`as authorized by the Board. Paper 24. The Protective Order was filed as Exhibit
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`2002.
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`Petitioner is filing its Reply to Patent Owner’s Response, which includes the
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`Declaration of Kevin Jakel filed as Exhibit 1036 and Deposition Transcript of Kevin
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`Jakel filed as Exhibit 1037, both which Petitioner designates HIGHLY
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`CONFIDENTIAL – ATTORNEYS’ EYES ONLY under the Protective Order.
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`Specifically,
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`the Petitioner contends
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`that
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`these documents contain highly
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`confidential and sensitive business information regarding Petitioner’s internal
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`business operations, financial information, membership information, and other
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`sensitive business information that could cause competitive business injury to or
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`potential breach of contractual obligations by Petitioner if publicly disseminated.
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`Section 8 of the Protective Order instructs the Petitioner “shall file
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`confidential and non-confidential versions of its submissions, together with a Motion
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`to Seal.” Exhibit 2002 at 6-7. Accordingly, Petitioner has prepared a non-
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`confidential version of its Reply that redacts certain discussion of certain
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`confidential information from Exhibits 1036 and 1037, and Petitioner now
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`IPR2018-00067
`U.S. Patent No. 8,577,813
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`respectfully moves to seal Exhibits 1036, Exhibit 1037, and the confidential version
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`of Petitioner’s Reply brief.
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`Petitioner states that it has conferred with counsel for Patent Owner, who
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`indicated that Patent Owner does not oppose this Motion.
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`II. CONCLUSION
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`For the foregoing reasons, Petitioner respectfully requests that the Board grant
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`Petitioner’s Unopposed Motion to Seal.
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`Respectfully submitted,
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`BY: /s/ Jason R. Mudd
`Jason R. Mudd, Reg. No. 57,700
`Eric A. Buresh, Reg. No. 50,394
`Roshan Mansinghani, Reg. No. 62,429
`Jonathan Stroud, Reg. No. 72,518
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`ATTORNEYS FOR PETITIONER
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`2
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`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 certifies that on November 21,
`2018, Petitioner’s Motion to Seal was served via electronic service on the following
`counsel of record for Patent Owner:
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`• jimglass@quinnemanuel.com
`• nimahefazi@quinnemanuel.com
`• tigranguledjian@quinnemanuel.com
`• halbarza@quinnemanuel.com
`• jordankaericher@quinnemanuel.com
`• qe-usr-ipr@quinnemanuel.com
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`Dated: November 21, 2018
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`BY: /s/ Jason R. Mudd
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`Jason R. Mudd, Reg. No. 57,700
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`ATTORNEY FOR PETITIONER
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`3
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