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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`KVK-TECH, INC.,
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`Petitioner,
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`v.
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`SHIRE PLC,
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`Patent Owner.
`____________________
`Case IPR2018-00293
`US Patent No. 9,173,857
`____________
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`PATENT OWNER’S MOTION TO SEAL AND MOTION FOR ENTRY OF
`PROTECTIVE ORDER
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`34838434v1
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`IPR2018-00293
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`Pursuant to 37 C.F.R. § 42.54, Patent Owner Shire PLC (“Shire”) moves to
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`file certain Exhibits filed with its Patent Owner’s Response under seal. As detailed
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`below, these Exhibits contain highly confidential and extremely sensitive
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`information related to financial matters pertaining to Patent Owner’s core business.
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`The parties have conferred and Petitioner KVK-Tech, Inc. does not object to the
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`instant motion. Further, as set forth below, Patent Owner also requests entry of the
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`Protective Order filed with this Motion as Ex. 2057.
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`Accordingly, Patent Owner requests that: (1) the Protective Order attached
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`as Ex. 2057 be entered in this case, (2) Exhibits 2054 and 2055 and the subject
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`matter thereof be deemed “Protective Order Material” of Shire; and (3) Patent
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`Owner’s Preliminary Response be deemed “Protective Order Material” of Shire, to
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`the extent it contains subject matter of Exhibit 2054 or 2055. A non-confidential
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`version of the Patent Owner’s Response is also being submitted.
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`Dated: April 10, 2018
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`Respectfully submitted,
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`/Joseph R. Robinson/
`Joseph R. Robinson, PTO Reg. No. 33,448
`Robert Schaffer, PTO Reg. No. 31,194
`Dustin B. Weeks, PTO Reg. No. 67,466
`Attorneys for Patent Owner
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`34838434v1
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`1
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`IPR2018-00293
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Patent
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`Owner’s Response, Patent Owner’s Motion to Seal and Motion for Entry of
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`Protective Order, and associated exhibits were served via electronic mail on April
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`10, 208 on attorney for Petitioner:
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`Jonathan A. Harris, Esq.
`jharris@axinn.com
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`James T. Evans, Esq.
`jevans@axin.comm
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`Respectfully submitted,
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`Dated: April 10, 2018
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`
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`/Grace Yang /
`Grace Yang
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`34838434v1
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