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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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`SAMSUNG DISPLAY CO., LTD., DELL, INC., and APPLE INC.,
`Petitioners,
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`v.
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`SOLAS OLED, LTD.,
`Patent Owner.
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`Case No. IPR2020-001401
`U.S. Patent No. 6,072,450
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`JOINT REQUEST TO FILE AGREEMENT
`AS BUSINESS CONFIDENTIAL INFORMATION
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`1 Apple Inc., who filed a petition in IPR2020-01059, has been joined as a petitioner
`in this proceeding.
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`Case No. IPR2020-00140
`U.S. Patent 6,072,450
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`Patent Owner Solas OLED Ltd. and Petitioners Dell Inc., and Apple Inc. have
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`reached agreements to terminate this IPR, Case No. IPR2020-00140, with respect to
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`Petitioners Dell and Apple. Solas, Dell, and Apple jointly request that the Board treat
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`the agreements as business confidential information and keep it separate from the
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`files of this proceeding and the files of this IPR. The Board authorized Solas and
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`Apple to file this joint request to keep separate by e-mail on January 29, 2021 and
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`February 12, 2021.
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`I.
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`Statement of Precise Relief Requested
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`Solas, Dell, and Apple request that the Board treat the settlement agreements
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`as business confidential information and keep it separate from the files of this
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`proceeding. Thus, the agreement should “be made available only to Federal
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`Government agencies on written request, or to any person on a showing of good
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`cause.” See 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74.
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`II. Reasons Why Relief Is Appropriate
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`The terms of the agreements require that Solas, Dell, and Apple to treat the
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`agreements as confidential information and prohibits disclosure to third parties.
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`Solas, Dell, and Apple further agree the agreements should be accessible to the
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`Board only. Thus, the agreements have been filed for access by “Board Only.”
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`Case No. IPR2020-00140
`U.S. Patent 6,072,450
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`Respectfully submitted,
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`Date: March 3, 2021
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`/Neil Rubin/
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`Neil Rubin (Reg. No. 67,030)
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`nrubin@raklaw.com
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`Counsel for Patent Owner
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`/David A. Garr/
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`David A. Garr (Reg. No. 74,932)
`COVINGTON & BURLING LLP
`One CityCenter, 850 Tenth Street, NW
`Washington, DC 20001
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`Peter P. Chen (Reg. No. 39,631)
`COVINGTON & BURLING LLP
`3000 El Camino Real
`5 Palo Alto Square, 10th Floor
`Palo Alto, CA 94306
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`Counsel for Petitioner Dell
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`/Adam P. Seitz/
`Adam P. Seitz (Reg. No. 52,206)
`ERISE IP, P.A.
`7015 College Blvd., Ste. 700
`Overland Park, Kansas 66211
`Phone: (913) 777-5600
`Adam.Seitz@eriseip.com
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`Counsel for Petitioner Apple
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`2
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`Case No. IPR2020-00140
`U.S. Patent 6,072,450
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`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
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`The undersigned hereby certifies that the above document was served on
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`March 3, 2021, by filing this document through the Patent Trial and Appeal Board
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`End to End system as well as delivering a copy via electronic mail upon the
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`following attorneys of record for the Petitioners:
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`David Garr, dgarr@cov.com
`Peter Chen, pchen@cov.com
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`Counsel for Petitioners Dell and Samsung Display Co.
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`Adam Seitz, adam.seitz@eriseip.com
`Paul Hart, paul.hart@eriseip.com
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`Counsel for Petitioner Apple
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`/Neil Rubin/
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`Neil Rubin (Reg. No. 67,030)
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
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`Counsel for Patent Owner
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`Date: March 3, 2021
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