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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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`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.
`Petitioners,
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`v.
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`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
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`Case IPR2020-00134
`Patent RE 45,760E
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`PATENT OWNER’S UNOPPOSED MOTION TO FILE UNDER SEAL
`PURSUANT TO 37 C.F.R. §§ 42.14 AND 42.54
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Patent Owner respectfully
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`submits this Patent Owner’s Unopposed Motion to File Under Seal, requesting that
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`the following document remain under seal: Exhibit 2221. This document is being
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`filed concurrently with this motion.
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`Patent Owner has conferred with the Petitioner, and the Petitioner does not
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`oppose this motion to seal.
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`In conjunction with the Patent Owner’s Preliminary Responses, the Patent
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`Owner and Petitioner agreed to and submitted a stipulated Joint Protective Order.
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`Patent Owner respectfully requests that the Board enter that stipulated Joint
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`Protective order in the above captioned case to govern treatment of the documents
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`and information identified herein.
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`I.
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`Good Cause
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`For good cause, the Board may “issue an order to protect a party or person
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`from disclosing confidential information.” 37 C.F.R. § 42.54. The rules “identify
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`confidential information in a manner consistent with Federal Rule of Civil
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`Procedure 26(c)(1)(G), which provides for protective orders for trade secret or
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`other confidential research, development, or commercial information.” Office
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`Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48760 (Aug. 14, 2012).
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`Exhibit 2221 meets this standard as it has been designated as confidential in
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`the parallel District of Minnesota litigation (Vascular Sols. LLC v. Medtronic, Inc.,
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`2
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`0:19-cv-1760-PJS-TNL, (D. Minn.)). The unredacted portions of this document
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`contain confidential information concerning Patent Owner’s business, pricing, and
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`marketing strategy. Irrelevant information has been redacted. The redacted
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`portions also contain confidential business information. Publicly revealing this
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`sensitive, competitive information would put Patent Owner at a disadvantage in the
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`marketplace.
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`II. Certification of Conference
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`Pursuant to 37 C.F.R. §§ 42.54(a), Patent Owner certifies that it has in good
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`faith conferred with Petitioners’ counsel. Petitioners’ counsel does not oppose this
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`motion to seal.
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`III. Request for Conference Call with the Board
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`Should the Board not be inclined to grant the present Unopposed Motion to
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`File Under Seal, Patent Owner hereby requests a conference call with the Board to
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`discuss any concerns prior to the Board issuing a decision on the Motion.
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`IV. Conclusion
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`Patent Owner respectfully requests that the Board grant this Unopposed
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`Motion to File Under Seal, and keep the following document under seal: Exhibit
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`2221.
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`3
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`Dated: November 24, 2020.
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`Respectfully submitted,
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`/ J. Derek Vandenburgh /
`J. Derek Vandenburgh (Lead Counsel)
`Registration No. 32,179
`Carlson, Caspers, Vandenburgh
` & Lindquist, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, MN 55402
`Telephone: (612) 436-9600
`Facsimile: (612) 436-9650
`Email:
`DVandenburgh@carlsoncaspers.com
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`Lead Counsel for Patent Owner
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`4
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`CERTIFICATION OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e) and the agreement of the parties, the
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`undersigned certifies that on November 24, 2020, a true and correct copy of the
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`foregoing PATENT OWNER’S UNOPPOSED MOTION TO FILE UNDER SEAL
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`PURSUANT TO 37 C.F.R. §§ 42.14 AND 42.54 was served via electronic mail
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`upon the following:
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`Cyrus A. Morton (Reg. No. 44,954)
`Sharon Roberg-Perez (Reg. No. 69,600)
`Christopher A. Pinahs (Reg. No. 76,375)
`William E. Manske
`Emily J. Tremblay
`Robins Kaplan LLP
`800 LaSalle Avenue, Suite 2800
`Minneapolis, MN 55401
`Phone: 349-8500
`Fax: 612-339-4181
`Email: Cmorton@robinskaplan.com
`Email: Sroberg-perez@robinskaplan.com
`Email: Cpinahs@robinskaplan.com
`Email: WManske@RobinsKaplan.com
`Email: ETremblay@RobinsKaplan.com
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`/J. Derek Vandenburgh/
`J. Derek Vandenburgh (Lead Counsel)
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`5
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