`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`ZTE (USA), INC., SAMSUNG ELECTRONICS CO., LTD., AND SAMSUNG
`ELECTRONICS AMERICA, INC.,
`Petitioner,
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner.
`___________________
`
`Case IPR2018-00276
`Patent No. 7,239,111
`___________________
`
`JOINT REQUEST TO FILE AGREEMENT AS BUSINESS
`CONFIDENTIAL INFORMATION AND KEEP IT SEPARATE FROM
`FILE OF US PATENT NO. 7,239,111 UNDER 37 C.F.R. § 42.74
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Case IPR2018-00276
`Patent No. 7,239,111
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioners
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`
`(collectively, “Samsung”), and Patent Owner, Fundamental Innovation Systems
`
`International LLC, jointly request to file the settlement agreement between the
`
`parties (Exhibit 2015), as referenced in the Joint Motion to Dismiss Samsung, filed
`
`concurrently herewith, as business confidential information, and that the Board and
`
`the Office keep the settlement agreement separate from the file of the involved
`
`patent. In view of that request, the agreement has been filed for access “Only to
`
`Board.”
`
`The Board authorized this request in an email dated July 13, 2018.
`
`- 1 -
`
`
`
`Case IPR2018-00276
`Patent No. 7,239,111
`
`Dated: July 13, 2018
`
`Respectfully submitted,
`
`/s/ Greg Arovas
`
`/s/ Hong Zhong
`
`Michael R. Fleming (Reg. No. 67,933)
`H. Annita Zhong (Reg. No. 66,530)
`Irell & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067
`Tel: (310) 277-1010
`Fax: (310) 203-7199
`Email: MFleming@irell.com
`Email: HZhong@irell.com
`
`Gregory S. Arovas (Reg. 38,818)
`greg.arovas@kirkland.com
`Robert A. Appleby (Reg. 40,897)
`robert.appleby@kirkland.com
`Todd M. Friedman (Reg. 42,559)
`todd.friedman@kirkland.com
`Alan Rabinowitz (Reg. 66,217)
`arabinowitz@kirkland.com
`KIRKLAND & ELLIS LLP
`601 Lexington Avenue
`New York, NY 10028
`T: 212-446-4800
`F: 212-446-6460
`
`Eugene Goryunov (Reg. 61,579)
`eugene.goryunov@kirkland.com
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, IL 60654
`T: 312-862-2000
`F: 312-862-2200
`
`- 2 -
`
`
`
`Case IPR2018-00276
`Patent No. 7,239,111
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. section 42.6, that on July 13, 2018, a
`
`complete copy of the foregoing document, Joint Motion to Dismiss Samsung from
`
`Proceeding Pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. § 42.05(a), and Exhibit
`
`2015 were served upon the following, by electronic mail:
`
`KIRKLAND & ELLIS LLP
`
`Gregory S. Arovas
`greg.arovas@kirkland.com
`Robert A. Appleby
`robert.appleby@kirkland.com
`Todd M. Friedman
`todd.friedman@kirkland.com
`Alan Rabinowitz
`alan.rabinowitz@kirkland.com
`Eugene Goryunov
`eugene.goryunov@kirkland.com
`
`I further certify, pursuant to 37 C.F.R. section 42.6, that on July 13, 2018, a
`
`complete copy of the foregoing document and Joint Motion to Dismiss Samsung
`
`from Proceeding Pursuant to 35 U.S.C. § 317(a) and 37 C.F.R. § 42.05(a) were
`
`served upon the following, by electronic mail:
`
`MCDERMOTT WILL & EMERY
`Charles M. McMahon
`cmcmahon@mwe.com
`Hersh H. Mehta
`hmehta@mwe.com
`
`/Susan M. Langworthy/
` Susan M. Langworthy
`
`- 3 -
`
`
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