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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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`APPLE INC.,
`Petitioner
`v.
`COREPHOTONICS, LTD.,
`Patent Owner
`———————
`
`IPR2020-00905
`U.S. Patent 10,225,479
`_______________
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`PETITIONER’S MOTION TO SEAL
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`I.
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`Petitioner’s Motion to Seal
` IPR2020-00905 (Patent No. 10,225,479)
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`Introduction
`In view of Patent Owner’s prior (and still pending) motion to seal certain
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`documents, and out of an abundance of caution, Petitioner respectfully moves to
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`seal the additional document(s) listed below pursuant to 37 C.F.R. §§ 42.14, 42.54.
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`The document(s) are being filed concurrently herewith as “Board and Parties
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`Only” documents and reference portions of documents that Patent Owner has itself
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`previously sought to seal. Good cause to seal exists in view of the provisionally
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`sealed status of the reference documents pending the outcome of a decision on
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`Patent Owner’s prior motion to seal.
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`Patent Owner has also requested (in Paper 17) entry of a Proposed Protective
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`Order, which it represents is substantively identical to the Board’s Default
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`Protective Order set forth in Appendix B to the Board’s July 2019 Trial Practice
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`Guide Update. This motion to seal below-listed additional document(s) is made
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`subject to, and incorporates, that Proposed Protective Order (paper 17, pp. 6-10).
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`Petitioner’s Motion to Seal
` IPR2020-00905 (Patent No. 10,225,479)
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`II. Additional Document(s) to be Sealed under the Previously Proposed
`Protective Order
`The following documents include sensitive information that has been
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`redacted (in a “Public” version) and for which a “Board and Parties Only” version
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`is to be sealed:
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`1. Petitioner’s Reply;
`2. Declaration of Fredo Durand, Ph.D. under 37 C.F.R. 1.68 in support
`of Petitioner’s Reply (APPL-1038); and
`3. Deposition Transcript of John Hart, Ph.D., April 29, 2021 (APPL-
`1037).
`All redactions are made consistent with Patent Owner’s representations in its
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`pending motion to seal that the material to be sealed and/or redacted reflects Patent
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`Owner’s confidential business information, include the identities of third parties
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`who have allegedly licensed Patent Owner’s technology (together with alleged
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`license grant dates) or include communications or documents in the course of
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`confidential business and licensing discussions between Petitioner and Patent
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`Owner.
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`- 2 -
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`Petitioner’s Motion to Seal
` IPR2020-00905 (Patent No. 10,225,479)
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`III. Conclusion
`For the above reasons, Petitioner requests that the above-listed additional
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`document(s) be placed under seal.
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`Respectfully submitted,
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`Dated: May 7, 2021
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`/Michael S. Parsons/
`Michael S. Parsons
`Lead Counsel for Petitioner
`Registration No. 58,767
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`Petitioner’s Motion to Seal
` IPR2020-00905 (Patent No. 10,225,479)
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
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`service was made on the Patent Owner as detailed below.
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`Date of service May 7, 2021
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`Manner of service Electronic Service by E-Mail
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`Persons served
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`Documents served PETITIONER’S MOTION TO SEAL
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`Neil A. Rubin (nrubin@raklaw.com)
`C. Jay Chung (jchung@raklaw.com)
`Marc A. Fenster (mfenster@raklaw.com)
`James S. Tsuei (jtsuei@raklaw.com)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Phone: (310) 826-7474
`Fax: (310) 826-6991
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`Jonathan Link (jlink@raklaw.com)
`RUSS AUGUST & KABAT
`800 Maine Ave SW, Suite 200
`Washington, DC. 20024
`Telephone: (202) 664-0623
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`/Michael S. Parsons/
`Michael S. Parsons
`Lead Counsel for Petitioner
`Registration No. 58,767
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