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`Paper _____
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`Trials@uspto.gov
`571-272-7822
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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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`________________
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`UNIFIED PATENTS INC.,
`Petitioner
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`v.
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`SYNKLOUD TECHNOLOGIES, LLC,
`Patent Owner
`________________
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`Case No. IPR 2019-01655
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`Patent No. 9,098,526
`________________
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`PATENT OWNER’S UNOPPOSED MOTION TO SEAL
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`37 C.F.R. §§ 42.54, 42.55
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`Supplementing Patent Owner’s Motion to Seal filed June 12, 2020, Patent
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`Owner reports that the parties engaged in earnest and concrete discussions and
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`have agreed on a modified protective order to which no party has objection. The
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`Modified Protective Order, submitted herewith as Exhibit 2013, provides for
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`somewhat more limited access to the confidential material submitted than the
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`Board’s Standing Order, but grants access to those most fundamentally involved.
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`The departures from the Standard Protective Order are confined to Sections A
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`through D of Section 2 of the Standard Protective Order.
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`For the benefit of clarity, a “redline” version of the Modified Protective
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`Order is submitted herewith as Exhibit 2014. Based on the revisions made to the
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`Modified Protective Order submitted herewith, Patent Owner is confident that the
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`confidentiality of the Confidential Information submitted with Patent Owner’s
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`Response will be protected. Undersigned counsel wishes to express his
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`appreciation to counsel for Petitioners for being open to discussion and responsive
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`to arrive at a suitable Modified Protective Order that will allow the Confidential
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`Information to be considered.
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`Accordingly, grant of this unopposed motion, and consideration of the
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`Confidential Information previously submitted, under seal, pursuant to the
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`Modified Protective Order submitted herewith, is respectfully requested.
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`Respectfully submitted,
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`/s/ Steven B. Kelber
`Steven B. Kelber
`Yeasun Yoon
`Capitol IP Law. PLLC
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`E-Mail:
`Steve. Kelber@capitoliplaw.com
`yoon@capitoliplaw.com
`Tel: (240)506-6702
`Tel: (434)906-2975
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`Attorneys for Patent Owner
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` certify that a copy of the foregoing Patent Owner’s Unopposed Motion to
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`Seal and Exhibits referred to therein were served on counsel for Petitioners, via
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`email on June 24, 2020, electronic service having been previously agreed upon.
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`/s/ Steven B. Kelber
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`Date: June 24, 2020
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