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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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`HP INC., MICROSOFT CORPORATION, DELL INC., DELL PRODUCTS LP,
`LENOVO (UNITED STATES) INC, AND MOTOROLA MOBILITY LLC.
`Petitioners,
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`v.
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`NEODRON LTD.,
`Patent Owner.
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` Case No. IPR2020-00459
`U.S. Patent No. 8,946,574
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`JOINT REQUEST TO KEEP SEPARATE PURSUANT TO 35 U.S.C.
`§ 317(b) AND 37 C.F.R. § 42.74(c)
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`Case No. IPR2020-00459
`U.S. Patent No. 8,946,574
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`Patent Owner Neodron Ltd. and Petitioners HP Inc., Microsoft Corporation,
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`Dell Inc., Dell Products LP, (collectively “Dell”), Lenovo (United States) Inc., and
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`Motorola Mobility LLC have reached a settlement. The settlement agreements
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`resolve the disputes in the above-captioned inter partes review relating to U.S.
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`Patent No. 8,946,574 (“Patent-in-Suit”). The parties jointly request that the Board
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`treat the settlement agreements as business confidential information and keep them
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`separate from the files of this proceeding and the files of the Patent-in-Suit. The
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`parties were authorized to file this Joint Motion by the Board (via email) on February
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`1, 2021.
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`I.
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`Statement of Precise Relief Requested
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`The parties jointly request that the Board treat the settlement agreements as
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`business confidential information and keep them separate from the files of this
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`proceeding and the files of the Patent-in-Suit. The parties request that the settlement
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`agreements “be made available only to Federal Government agencies on written
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`request, or to any person on a showing of good cause” in accordance with 35 U.S.C.
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`§ 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 settlement agreements require the parties to treat the
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`settlement agreements as confidential information and limit their ability to share the
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`settlement agreements or disclose their content with third parties. The parties have
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`Case No. IPR2020-00459
`U.S. Patent No. 8,946,574
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`filed copies of the settlement agreements with the Board, as required by 35 U.S.C.
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`§ 317(b) and 37 C.F.R. § 42.74. The confidential settlement agreements were filed
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`in the PTAB E2E system to provide availability only to the Board.
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`Date: February 5, 2021
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` /Neil Rubin /
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`Respectfully submitted,
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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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` /James M. Heintz/
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`James M. Heintz (Reg. No. 41,828)
`DLA Piper LLP (US)
`11911 Freedom Dr., Suite 300
`Reston VA 20190
`Phone: (703) 773-4000
`jim.heintz@dlapiper.com
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`Counsel for Petitioners
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`Case No. IPR2020-00459
`U.S. Patent No. 8,946,574
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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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`February 5, 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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`James Heintz, jim.heintz@dlapiper.com
`Robert Buergi, robert.buergi@dlapiper.com
`Robert High, robert.high@finnegan.com
`Philip Eklem, philip.eklem@finnegan.com
`Aliza Carrano, aliza.carrano@finnegan.com
`Christopher Douglas, christopher.douglas@alston.com
`Caleb Bean, caleb.bean@alston.com
`DLA_Neodron_WDTX_IPR@us.dlapiper.com
`Finnegan_Lenovo_IPRs@finnegan.com
`Dell-Neodron-ITC@alston.com
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`Date: February 5, 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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