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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. and APPLE INC.,
`Petitioners,
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`v.
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`SOLAS OLED, LTD.,
`Patent Owner.
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`Case No. IPR2020-003201
`U.S. Patent No. 7,446,338
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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 IPR2020-01275, has been joined as a petitioner
`in this proceeding.
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`Case No. IPR2020-00320
`U.S. Patent 7,446,338
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`Patent Owner Solas OLED Ltd. and Petitioner Apple Inc. have reached an
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`agreement to terminate this IPR, Case No. IPR2020-00320, with respect to Petitioner
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`Apple. Solas and Apple jointly request that the Board treat the agreement as business
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`confidential information and keep it separate from the files of this proceeding and
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`the files of this IPR. The Board authorized Solas and Apple to file this joint request
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`to keep separate by e-mail on January 29, 2021.
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`I.
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`Statement of Precise Relief Requested
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`Solas and Apple request that the Board treat the settlement agreement as
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`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 agreement require the Solas and Apple to treat the agreement
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`as confidential information and prohibits disclosure to third parties. Solas and Apple
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`further agree the agreement should be accessible to the Board only. Thus, the
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`agreement has been filed for access by “Board Only.”
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`Date: March 2, 2021
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`/Neil Rubin/
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`Respectfully submitted,
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`Neil Rubin (Reg. No. 67,030)
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`Case No. IPR2020-00320
`U.S. Patent 7,446,338
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`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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`/Adam P. Seitz
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`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. IPR2020-00320
`U.S. Patent 7,446,338
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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 2, 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
`Grant Johnson, gjohnson@cov.com
`Peter Chen, pchen@cov.com
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`Counsel for Petitioners Samsung
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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 2, 2021
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