IPR2019-00614
`U.S. Patent No. 9,779,419
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`APPLE INC.,
`
`Petitioner,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00614
`
`U.S. Patent No. 9,779,419
`
`____________
`
`PETITIONER APPLE INC.’S MOTION TO SEAL
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`U.S. Patent No. 9,779,419
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`APPLE INC.,
`
`Petitioner,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00614
`
`U.S. Patent No. 9,779,419
`
`____________
`
`PETITIONER APPLE INC.’S MOTION TO SEAL
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`STATEMENT OF PRECISE RELIEF REQUESTED
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Petitioner Apple Inc. (“Apple”)
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`I.
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`respectfully submits this Motion to Seal (“Motion”) the Declaration of Michael
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`Hulse (Ex. 1004) and the Declaration of Yosh Moriarty (Ex. 1031) (collectively,
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`“the Declarations”), filed January 23, 2019 in publicly-available versions (redacted)
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`and versions under seal (not-redacted; for Board viewing only). The Parties have
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`agreed to the provisions of the Standing Protective Order, attached as Appendix A,
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`which is a modified version of the Default Protective Order. Good cause exists for
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`sealing the identified documents in accordance with the Standing Protective Order
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`and standards governing sealing.
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`II. GOOD CAUSE EXISTS FOR SEALING CERTAIN CONFIDENTIAL
`INFORMATION
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`Although “the default rule is that all papers filed in an inter partes review are
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`open and available for access by the public,” a party may file a motion with the
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`Board to seal confidential information that is protected from disclosure. Garmin v.
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`Cuozzo, IPR2012-00001, Paper No. 36. “The standard for granting a motion to seal
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`is ‘for good cause.’” Id. (quoting 37 C.F.R § 42.54). The Office Patent Trial Practice
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`Guide, 77 Fed. Reg. 48756, 48760 (Aug. 14, 2012), states that the “rules identify
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`confidential information in a manner consistent with Federal Rule of Civil Procedure
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`1
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`(‘FRCP’) 26(c)(1)(G), which provides for protective orders for trade secret or other
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`confidential research, development, or commercial information.”
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`The Declarations include confidential and commercially sensitive business
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`information. In particular, the Declarations include confidential information
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`regarding at least (1) Apple’s internal systems for managing and tracking documents
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`and information, including an identification of those systems and/or their histories
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`of use within Apple, (2) Apple’s internal document naming conventions, (3) Apple’s
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`internal workflow for publishing documents, and (4) internal metadata and/or
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`properties assigned to Apple documents. This information originated from Apple’s
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`internal systems (as shown and described in the Declarations), is not publicly
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`available, and has been and continues to be intended to remain confidential.
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`Apple faces concrete harm if its confidential information is released to the
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`public. As described above, the confidential information includes details about how
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`Apple operates, providing specific insight into Apple’s operations with respect to
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`internal systems, documentation, and information. If this information were subject
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`to public access, Apple’s processes would be subject to copying by competitors. In
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`addition, the public identification of Apple’s internal systems would create security
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`risks. For example, public disclosure of the confidential information would allow
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`would-be attackers to gain insight into the structure of Apple’s internal file systems,
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`2
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`databases, and servers, thereby putting at risk additional confidential information
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`including, e.g., Apple’s technical, financial, and customer information.
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`There exists a genuine need to rely on the Declarations in this proceeding. The
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`Petition cites to the Declarations to support the date of public availability of iPhone
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`User Guide For iPhone OS 3.1 Software (Ex. 1007) and iPhone 3G Finger Tips (Ex.
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`1032), which are used in grounds of unpatentability.
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`On balance, the harm faced by Apple in making the redacted information
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`available outweighs any interest in releasing it to the public. The Declarations have
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`not been excessively redacted, and the non-redacted (i.e., public) portions of the
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`Declarations include detailed information about the identity and employment of the
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`declarant, non-confidential details about the contents and history of Exhibits 1007
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`and 1032, and identification of the dates of public availability of Exhibits 1007 and
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`1032. Thus, any public interest in having access to the redacted portions is minimal,
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`and does not outweigh the harm faced by Apple.
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`Accordingly, good cause exists for sealing portions of the Declarations. Apple
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`respectfully moves to file under seal the portions of the Declaration of Michael Hulse
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`(Ex. 1004) and the Declaration of Yosh Moriarty (Ex. 1031) containing Apple’s
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`confidential information.
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`3
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`III. PROTECTIVE ORDER
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`Apple respectfully requests that the Board enter the Standing Protective Order
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`attached as Appendix A to protect the sensitive and confidential information
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`contained in Exhibits 1004 and 1031. The Parties agree to adopt and be bound by a
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`modified version of the Default Protective Order (77 FED. REG. 48756, 48771
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`(Aug. 14, 2012)). In comparison to the Default Protective Order, the Standing
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`Protective Order in Appendix A contains an additional designation “PROTECTIVE
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`ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY” for confidential
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`material and restricts the material to Outside Counsel, Experts, Office Staff and
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`Support Personnel. In addition, the Standing Protective Order provides that Support
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`Personnel shall also include support personnel of outside counsel of record for a
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`party in the proceeding. See Appendix B (redline version showing changes to the
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`Default Protective Order).
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`Good cause exists for these restrictions as the Board has recognized a
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`necessity for similar designations on confidential material in other IPR proceedings.
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`See Xactware v. Sols., Inc. v. Eagle View Techs., Inc., Case IPR2016-00589, slip op.
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`at 2-3 (PTAB Nov. 23, 2016) (Paper 33); VIZIO, Inc. v. Nichia Corp., IPR2017-
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`01623, slip op. at 5 (PTAB Jan. 9, 2019) (Paper 73). Here, the more limited access
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`provided by
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`the “PROTECTIVE ORDER MATERIAL – OUTSIDE
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`4
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`ATTORNEYS’ EYES ONLY” designation is necessary to minimize security risks
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`and protect Apple’s confidential information from competitors.
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`IV. CERTIFICATION OF CONFERENCE WITH AFFECTED PARTIES
`PURSUANT TO 37 C.F.R. § 42.54
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`Apple and Patent Owner FirstFace Co., Ltd. (“Patent Owner”) conferred
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`regarding this Motion and the attached Standing Protective Order (Appendix A). The
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`parties agreed to the provisions of the Standing Protective Order. Patent Owner
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`indicated that it does not oppose this Motion.
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`Dated: March 7, 2019
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`Respectfully submitted,
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`By: /Gabrielle E. Higgins/
`
`Gabrielle E. Higgins
`Reg. No. 38,916
`Christopher M. Bonny
`Reg. No. 63,307
`ROPES & GRAY LLP
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`Phone: +1-650-617-4015
`Fax: +1-617-235-9492
`gabrielle.higgins@ropesgray.com
`christopher.bonny@ropesgray.com
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`Attorneys for Petitioner Apple Inc.
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`5
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing PETITIONER APPLE
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`INC.’S MOTION TO SEAL was served by filing this document through the Patent
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`Trial and Appeal Board End to End (PTAB E2E) as well as providing a courtesy
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`copy via electronic mail to the following attorneys of record for the Patent Owner
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`listed below:
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`Barry J. Bumgardner
`barry@nbafirm.com
`Matthew C. Juren
`matthew@nbafirm.com
`Thomas C. Cecil
`tom@nbafirm.com
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`NELSON BUMGARDNER ALBRITTON P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3494
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`By: /Crena Pacheco/
`Name: Crena Pacheco
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`ROPES & GRAY LLP
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`Dated: March 7, 2019
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`IPR2019-00614
`U.S. Patent No. 9,779,419
`US. Patent No. 9,779,419
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`IPR2019-00614
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`APPENDIX A
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`APPENDIX A
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`APPLE INC.,
`
`Petitioner,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00614
`
`U.S. Patent No. 9,779,419
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`____________
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`
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`STANDING PROTECTIVE ORDER
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`A-1
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`This standing protective order governs the treatment and filing of
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`confidential information in this proceeding, including documents and testimony.
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`1.
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`Confidential information shall be clearly marked “PROTECTIVE
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`ORDER MATERIAL – CONFIDENTIAL” or “PROTECTIVE ORDER
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`MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY.”
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`2.
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`Access to confidential information marked “PROTECTIVE ORDER
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`MATERIAL – CONFIDENTIAL” is limited to the following individuals who have
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`executed the acknowledgment appended to this order:
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`(A)
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`Parties. Persons who are owners of a patent involved in the
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`proceeding and other persons who are named parties to the proceeding.
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`(B)
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`Party Representatives. Representatives of record for a party in the
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`proceeding.
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`(C)
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`Experts. Retained experts of a party in the proceeding who further
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`certify in the Acknowledgement that they are not a competitor to any party,
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`or a consultant for, or employed by, such a competitor with respect to the
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`subject matter of the proceeding.
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`(D)
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`In-house counsel. In-house counsel of a party.
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`(E) Other Employees of a Party. Employees, consultants or other
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`persons performing work for a party, other than in-house counsel and in-
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`house counsel’s support staff, who sign the Acknowledgement shall be
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`A-2
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`extended access to confidential information only upon agreement of the
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`parties or by order of the Board upon a motion brought by the party seeking
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`to disclose confidential information to that person. The party opposing
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`disclosure to that person shall have the burden of proving that such person
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`should be restricted from access to confidential information.
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`(F)
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`The Office. Employees and representatives of the Office who have a
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`need for access to the confidential information shall have such access
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`without the requirement to sign an Acknowledgement. Such employees and
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`representatives shall include the Director, members of the Board and their
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`clerical staff, other support personnel, court reporters, and other persons
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`acting on behalf of the Office.
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`(G)
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`Support Personnel. Administrative assistants, clerical staff, court
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`reporters and other support personnel of the foregoing persons and outside
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`counsel of record for a party in the proceeding who are reasonably necessary
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`to assist those persons in the proceeding shall not be required to sign an
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`Acknowledgement, but shall be informed of the terms and requirements of
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`the Protective Order by the person they are supporting who receives
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`confidential information.
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`3.
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`A party may designate confidential information as “PROTECTIVE
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`ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY.” The
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`A-3
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`“PROTECTIVE ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES
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`ONLY” designation is reserved for confidential information that the designating
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`party reasonably believes to be sensitive business information, the disclosure of
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`which is likely to cause significant harm to the business or competitive position of
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`the designating party or would violate confidentiality agreements with third parties.
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`Access to confidential information marked “PROTECTIVE ORDER MATERIAL
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`– OUTSIDE ATTORNEYS’ EYES ONLY” is limited to the following individuals
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`who have executed the acknowledgement appended to this order: outside counsel
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`of record in the proceeding and individuals identified above in Sections 2(C), 2(F),
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`and 2(G).
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`4.
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`Persons receiving confidential information shall use reasonable efforts to
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`maintain the confidentiality of the information, including:
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`(A) Maintaining such information in a secure location to which persons
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`not authorized to receive the information shall not have access;
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`(B) Otherwise using reasonable efforts to maintain the confidentiality of
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`the information, which efforts shall be no less rigorous than those the
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`recipient uses to maintain the confidentiality of information not received
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`from the disclosing party;
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`(C)
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`Ensuring that support personnel of the recipient who have access to
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`the confidential information understand and abide by the obligation to
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`A-4
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`maintain the confidentiality of information received that is designated as
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`confidential; and
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`(D)
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`Limiting the copying of confidential information to a reasonable
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`number of copies needed for conduct of the proceeding and maintaining a
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`record of the locations of such copies.
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`5.
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`Persons receiving confidential information shall use the following
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`procedures to maintain the confidentiality of the information:
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`(A) Documents and Information Filed With the Board.
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`(i) A party may file documents or information with the Board under
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`seal, together with a non-confidential description of the nature of the
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`confidential information that is under seal and the reasons why the
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`information is confidential and should not be made available to the
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`public. The submission shall be treated as confidential and remain
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`under seal, unless, upon motion of a party and after a hearing on the
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`issue, or sua sponte, the Board determines that the documents or
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`information do not to qualify for confidential treatment.
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`(ii) Where confidentiality is alleged as to some but not all of the
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`information submitted to the Board, the submitting party shall file
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`confidential and non-confidential versions of its submission, together
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`with a Motion to Seal the confidential version setting forth the reasons
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`A-5
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`why the information redacted from the non-confidential version is
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`confidential and should not be made available to the public. The
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`nonconfidential version of the submission shall clearly indicate the
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`locations of information that has been redacted. The confidential
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`version of the submission shall be filed under seal. The redacted
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`information shall remain under seal unless, upon motion of a party
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`and after a hearing on the issue, or sua sponte, the Board determines
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`that some or all of the redacted information does not qualify for
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`confidential treatment.
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`(B) Documents and Information Exchanged Among the Parties.
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`Information designated as confidential that is disclosed to another party during
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`discovery or other proceedings before the Board shall be clearly marked as
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`“PROTECTIVE ORDER MATERIAL – CONFIDENTIAL” or PROTECTIVE
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`ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY” and shall be
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`produced in a manner that maintains its confidentiality.
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`A-6
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`APPLE INC.,
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`Petitioner,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`______________________
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`Case IPR2019-00614
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`U.S. Patent No. 9,779,419
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`______________________
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`ACKNOWLEDGMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
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`
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`I
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`, affirm that I have read the
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`Protective Order; that I will abide by its terms; that I will use the confidential
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`information only in connection with this proceeding and for no other purpose;
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`that I will only allow access to support staff who are reasonably necessary to
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`assist me in this proceeding; that prior to any disclosure to such support staff I
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`A-7
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`informed or will inform them of the requirements of the Protective Order; that I
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`am personally responsible for the requirements of the terms of the Protective
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`Order and I agree to submit to the jurisdiction of the Office and the United States
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`District Court for the Eastern District of Virginia for purposes of enforcing the
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`terms of the Protective Order and providing remedies for its breach.
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`[Signature]
`By:
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`Date:
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`A-8
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`IPR2019-00614
`U.S. Patent No. 9,779,419
`US. Patent No. 9,779,419
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`IPR2019-00614
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`APPENDIX B
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`APPENDIX B
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`APPLE INC.,
`
`Petitioner,
`
`v.
`
`FIRSTFACE CO., LTD.,
`
`Patent Owner.
`
`____________
`
`Case IPR2019-00614
`
`U.S. Patent No. 9,779,419
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`____________
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`DEFAULT PROTECTIVE ORDER
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`The following Standing Protective Order will be automatically entered into
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`the proceeding upon the filing of a petition for review or institution of a derivation:
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`Standing Protective Order
`
`This standing protective order governs the treatment and filing of
`
`confidential information in this proceeding, including documents and testimony.
`
`1.
`
`Confidential information shall be clearly marked “PROTECTIVE
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`
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`B-1
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`ORDER MATERIAL – CONFIDENTIAL” or “PROTECTIVE ORDER
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`MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY.”
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`2.
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`Access to confidential information marked “PROTECTIVE ORDER
`
`MATERIAL – CONFIDENTIAL” is limited to the following individuals who have
`
`executed the acknowledgment appended to this order:
`
`(A)
`
`Parties. Persons who are owners of a patent involved in the
`
`proceeding and other persons who are named parties to the proceeding.
`
`(B)
`
`Party Representatives. Representatives of record for a party in the
`
`proceeding.
`
`(C)
`
`Experts. Retained experts of a party in the proceeding who further
`
`certify in the Acknowledgement that they are not a competitor to any party,
`
`or a consultant for, or employed by, such a competitor with respect to the
`
`subject matter of the proceeding.
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`(D)
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`In-house counsel. In-house counsel of a party.
`
`(E) Other Employees of a Party. Employees, consultants or other
`
`persons performing work for a party, other than in-house counsel and in-
`
`house counsel’s support staff, who sign the Acknowledgement shall be
`
`extended access to confidential information only upon agreement of the
`
`parties or by order of the Board upon a motion brought by the party seeking
`
`to disclose confidential information to that person. The party opposing
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`B-2
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`disclosure to that person shall have the burden of proving that such person
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`should be restricted from access to confidential information.
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`(F)
`
`The Office. Employees and representatives of the Office who have a
`
`need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees and
`
`representatives shall include the Director, members of the Board and their
`
`clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
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`(G)
`
`Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons and outside
`
`counsel of record for a party in the proceeding who are reasonably necessary
`
`to assist those persons in the proceeding shall not be required to sign an
`
`Acknowledgement, but shall be informed of the terms and requirements of
`
`the Protective Order by the person they are supporting who receives
`
`confidential information.
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`3.
`
`A party may designate confidential information as “PROTECTIVE
`
`ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY.” The
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`“PROTECTIVE ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES
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`ONLY” designation is reserved for confidential information that the designating
`
`party reasonably believes to be sensitive business information, the disclosure of
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`
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`B-3
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`which is likely to cause significant harm to the business or competitive position of
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`the designating party or would violate confidentiality agreements with third parties.
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`Access to confidential information marked “PROTECTIVE ORDER MATERIAL
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`– OUTSIDE ATTORNEYS’ EYES ONLY” is limited to the following individuals
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`who have executed the acknowledgement appended to this order: outside counsel
`
`of record in the proceeding and individuals identified above in Sections 2(C), 2(F),
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`and 2(G).
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`3.4.
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`Persons receiving confidential information shall use reasonable efforts to
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`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons
`
`not authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality of
`
`the information, which efforts shall be no less rigorous than those the
`
`recipient uses to maintain the confidentiality of information not received
`
`from the disclosing party;
`
`(C)
`
`Ensuring that support personnel of the recipient who have access to
`
`the confidential information understand and abide by the obligation to
`
`maintain the confidentiality of information received that is designated as
`
`confidential; and
`
`(D)
`
`Limiting the copying of confidential information to a reasonable
`
`
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`B-4
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`number of copies needed for conduct of the proceeding and maintaining a
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`record of the locations of such copies.
`
`4.5.
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`Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board under
`
`seal, together with a non-confidential description of the nature of the
`
`confidential information that is under seal and the reasons why the
`
`information is confidential and should not be made available to the
`
`public. The submission shall be treated as confidential and remain
`
`under seal, unless, upon motion of a party and after a hearing on the
`
`issue, or sua sponte, the Board determines that the documents or
`
`information do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`
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`B-5
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`locations of information that has been redacted. The confidential
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`version of the submission shall be filed under seal. The redacted
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`information shall remain under seal unless, upon motion of a party
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`and after a hearing on the issue, or sua sponte, the Board determines
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`that some or all of the redacted information does not qualify for
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`confidential treatment.
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`(B) Documents and Information Exchanged Among the Parties.
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`Information designated as confidential that is disclosed to another party during
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`discovery or other proceedings before the Board shall be clearly marked as
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`“PROTECTIVE ORDER MATERIAL – CONFIDENTIAL” or PROTECTIVE
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`ORDER MATERIAL – OUTSIDE ATTORNEYS’ EYES ONLY” and shall be
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`produced in a manner that maintains its confidentiality.
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`B-6
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`IPR2019-00614
`U.S. Patent No. 9,779,419
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`[CAPTION]
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
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`APPLE INC.,
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`Petitioner,
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`v.
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`FIRSTFACE CO., LTD.,
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`Patent Owner.
`______________________
`
`Case IPR2019-00614
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`U.S. Patent No. 9,779,419
`
`______________________
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`Standard Acknowledgment for Access to Protective Order Material
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`ACKNOWLEDGMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
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`I
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`, affirm that I have read the
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`Protective Order; that I will abide by its terms; that I will use the confidential
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`information only in connection with this proceeding and for no other purpose;
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`that I will only allow access to support staff who are reasonably necessary to
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`assist me in this proceeding; that prior to any disclosure to such support staff I
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`B-7
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`IPR2019-00614
`U.S. Patent No. 9,779,419
`
`
`informed or will inform them of the requirements of the Protective Order; that I
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`am personally responsible for the requirements of the terms of the Protective
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`Order and I agree to submit to the jurisdiction of the Office and the United States
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`District Court for the Eastern District of Virginia for purposes of enforcing the
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`terms of the Protective Order and providing remedies for its breach.
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`[Signature]
`By:
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`Date:
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`B-8
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