`Case IPR2018-00883
`PATENT OWNER’S MOTION TO SEAL
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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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`REALTIME ADAPTIVE STREAMING LLC,
`Patent Owner.
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`Case IPR2018-00883
`Patent No. 8,934,535
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`PATENT OWNER’S MOTION TO SEAL
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`Case IPR2018-00883
`PATENT OWNER’S MOTION TO SEAL
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`Pursuant to the Protective Order entered by the Board on August 21, 2018
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`(Paper 19), Patent Owner respectfully moves to seal Exhibits 2003, 2004, 2005,
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`2006, 2007, 2008, 2009, 2010, and 2012, and the portions of Patent Owner’s
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`Supplemental Brief that reference those exhibits, which contain information
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`marked “Confidential” by Petitioner as described below. A Protective Order has
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`been previously submitted in this proceeding and the Board has entered that
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`Protective Order. See Paper 19.
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`In accordance with Section 8.a.i of the Protective Order, Patent Owner
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`provides the following non-confidential descriptions the exhibits and reasons
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`Patent Owner is moving to seal those exhibits.
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`Exhibit 2003 is a copy of Petitioner’s Voluntary Interrogatory Responses.
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`Petitioner has marked these responses “HIGHLY CONFIDENTIAL—
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`ATTORNEYS’ EYES ONLY” under the Protective Order in this case.
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`Exhibit 2004 is an excerpt of the transcript of the deposition of Kevin Jakel
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`taken in IPR2014-01252. Petitioner has marked the deposition “HIGHLY
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`CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the Protective Order in
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`this case.
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`Exhibit 2005 is a presentation distributed to a Unified member describing
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`Unified’s spending and business activities that Petitioner has marked “HIGHLY
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`CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the Protective Order in
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`PATENT OWNER’S MOTION TO SEAL
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`this case.
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`Exhibit 2006 is a presentation distributed by Unified to one of its members
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`describing its business strategy that Petitioner has marked “HIGHLY
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`CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the Protective Order in
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`this case.
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`Exhibit 2007 is an email between Google and Petitioner that Petitioner has
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`marked “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the
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`Protective Order in this case.
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`Exhibit 2008 is a Presentation Unified sent to Google describing Unified’s
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`spending and business activities which Petitioner has marked “HIGHLY
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`CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the Protective Order in
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`this case.
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`Exhibit 2009 is an email and attached presentation describing Unified’s
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`business model sent by a Unified member. Petitioner has marked Exhibit 2009
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`“HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the
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` Case IPR2018-00883
`PATENT OWNER’S MOTION TO SEAL
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`Protective Order in this case.1
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`Exhibit 2010 is a Presentation Unified sent to a Unified member describing
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`Unified’s spending and business activities. Petitioner has marked Exhibit 2010
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`“HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the
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`Protective Order in this case.
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`Exhibit 2012 is a written agreement between Google and Petitioner that
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`Petitioner has marked “HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES
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`ONLY” under the Protective Order in this case.
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`In accordance with Section 8.a.ii of the Protective Order, Patent Owner has
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`provided attached confidential and non-confidential versions of its Supplemental
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`Brief. The redacted portions of Patent Owner’s Supplemental brief refer to
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`information from the above-described exhibits, which Petitioner has marked
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`“HIGHLY CONFIDENTIAL—ATTORNEYS’ EYES ONLY” under the
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`Protective Order in this case.
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`1 Patent Owner takes no position on whether Exhibit 2009 is confidential
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`and notes that the email describing the presentation indicates that the exhibit is not
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`confidential.
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`PATENT OWNER’S MOTION TO SEAL
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`For the foregoing reasons, Patent Owner requests that the Board seal
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`Exhibits 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, and 2012 and the
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`portions of Patent Owner’s Preliminary Response referencing those exhibits.
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`Respectfully submitted,
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`/s/ William P. Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Kayvan B. Noroozi, Pro Hac Vice Pending
`NOROOZI PC
`1299 Ocean Ave., Suite 450
`Santa Monica, CA 90401
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`Attorneys for the Patent Owner
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`Date: August 30, 2018
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that the foregoing PATENT OWNER’S
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`MOTION TO SEAL was served electronically via e-mail on August 30, 2018, on
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`the following counsel of record for Petitioner:
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`Lionel Lavenue (Lead Counsel)
`Ashraf Fawzy (Back-up Counsel)
`Jonathan Stroud (Back-up Counsel)
`C. Brandon Rash (Back-up Counsel)
`James Stein (Back-up Counsel)
`Service Email
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`lionel.lavenue@finnegan.com
`afawzy@unifiedpatents.com
`jonathan@unifiedpatents.com
`brandon.rash@finnegan.com
`james.stein@finnegan.com
`UnifiedPatents-IPR2018-
`00883@finnegan.com
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`/s/ William P. Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Attorney for the Patent Owner
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`Date: August 30, 2018
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