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`DOCKET NO.: 2211726-00152US1
`Filed on behalf of Unified Patents Inc.
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Ellyar Y. Barazesh, Reg. No. 74,096
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`Roshan Mansinghani, Reg. No. 62,429
`Jonathan Stroud, Reg. No. 72,518
`Jonathan Bowser, Reg. No. 54,574
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
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`UNILOC LUXEMBOURG S.A. & UNILOC USA
`Patent Owner
`
`
`IPR2018-00199
`Patent 7,092,671
`
`
`MOTION TO SEAL PETITIONER’S REPLY AND EXHIBIT 1022
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`
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`I.
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`Introduction
`Petitioner requests that Petitioner’s Reply to Patent Owner’s Response, and
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`IPR2018-00199
`U.S. Patent 7,092,671
`
`Exhibit 1022, filed herewith, be sealed under 37 C.F.R. § 42.54 and the Default
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`Standing Protective Order (EX1017). Good cause to seal these documents exists
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`because they contain sensitive, non-public information.
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`II. Good Cause Exists for Sealing Certain Confidential Information
`The Office Patent Trial Practice Guide provides that “the rules aim to strike a
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`balance between the public’s interest in maintaining a complete and understandable
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`file history and the parties’ interest in protecting truly sensitive information.” 77
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`FED. REG. 48756, 48760 (Aug. 14, 2012). Further, those rules “identify confidential
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`information in a manner consistent with Federal Rule of Civil Procedure
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`26(c)(1)(G), which provides for protective orders for trade secret or other
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`confidential research, development, or commercial information.” Id. (citing 37
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`C.F.R. § 42.54).
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`Petitioner’s Reply and Exhibit 1022 contain information that Petitioner has
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`identified as confidential business information.
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`Petitioner’s Reply to Patent Owner’s Response references and describes
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`the content of certain confidential materials, that Petitioner requests by the present
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`motion to file under seal and has been marked “PROTECTIVE ORDER
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`MATERIAL” under the Protective Order in this case. A public version of
`2
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`
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`IPR2018-00199
`U.S. Patent 7,092,671
`Petitioner’s Reply, from which the confidential information has been redacted, has
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`
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`also been filed in this proceeding.
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`Exhibit 1022 is a Declaration of Kevin Jakel and has been marked
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`“PROTECTIVE ORDER MATERIAL” under the Protective Order in this case. This
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`declaration includes sensitive business information which Petitioner asserts has not
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`been published or otherwise been made public. A public version of Exhibit 1022,
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`from which the confidential information has been redacted, has also been filed in
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`this proceeding.
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`III. Conclusion
`
`
`For the above reasons, Petitioner requests that the unredacted and complete
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`versions of Petitioner’s Reply and Exhibit 1022 be placed under seal.
`
`Unified Patents Inc.
`
`By:/Daniel V. Williams/
`
`Daniel V. Williams
`Registration No. 45,221
`
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`3
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`IPR2018-00199
`2211726-00152US1
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on December 21, 2018, I caused a true and correct
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`copy of the foregoing Motion to Seal to be served via electronic mail to the
`
`attorneys of record at the following email addresses:
`
`Ryan Loveless
`Brett Mangrum
`James Etheridge
`Jeffrey Huang
`Sean D. Burdick
`
`Emails:
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`ryan@etheridgelaw.com
`brett@etheridgelaw.com
`jim@etheridgelaw.com
`jeff@etheridgelaw.com
`sean.burdick@unilocusa.com
`
`Respectfully submitted,
`
`/Christopher M. Cherry/
`
`Christopher M. Cherry, Reg. No. 65,356
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`1875 Pennsylvania Avenue NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Fax: (202) 663-6363
`
`i
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` ActiveUS 170979919v.1
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