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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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`YITA LLC,
`Petitioner
`
`v.
`
`MACNEIL IP LLC,
`Patent Owner
`
`
`
`Case IPR2020-01139
`U.S. Patent No. 8,382,186
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`PETITIONER’S OPPOSITION TO
`PATENT OWNER’S MOTION FOR ENTRY OF MODIFIED
`PROTECTIVE ORDER
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`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
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`
`
`
`IPR2020-01139
`U.S. Patent No. 8,382,186
`PETITIONER’S UPDATED EXHIBIT LIST
`
`Description
`U.S. Patent No. 8,382,186 to MacNeil et al., issued February 26,
`2013 (“’186 Patent”)
`File History of U.S. Patent No. 8,382,186 (“’186 Patent File
`History”)
`Declaration of Paul E. Koch, Ph.D.
`U.S. Patent No. 7,444,748 to MacNeil, issued November 4, 2008
`(“MacNeil”)
`French Patent Application Pre-Grant Publication No. 2547252 to
`Rabbe, published December 14, 1984, with attached certified
`English-language translation (“Rabbe”)
`U.S. Patent Application Pre–Grant Publication No.
`2002/0045029 A1 to Yung, published April 18, 2002 (“Yung”)
`Gruenwald, G., Thermoforming: A Plastics Processing Guide,
`CRC Press, 2nd Edition, 1998 (“Gruenwald”)
`Throne, J., Technology of Thermoforming, Hanser, 1996
`(“Throne I”)
`Throne, J., Understanding Thermoforming, Hanser, 2nd Edition,
`2008 (“Throne II”)
`U.S. Patent No. 2,057,873 to Atwood, issued October 20, 1936
`(“Atwood”)
`U.S. Patent No. 2,657,948 to Sturtevant, issued November 3,
`1953 (“Sturtevant”)
`U.S. Patent No. 6,793,872 to Buss, issued September 21, 2004
`(“Buss”)
`U.S. Patent No. 6,361,099 to McIntosh, issued March 26, 2002
`(“McIntosh”)
`U.S. Patent No. 4,568,581 to Peoples, issued February 4, 1986
`(“Peoples”)
`U.S. Patent No. 5,298,319 to Donahue, issued March 29, 1994
`(“Donahue”)
`DOW HDPE DGDA-5004 NT 7 Data Sheet, published October
`10, 2003
`Black Armor Web Advertisement
`Husky Liner Advertisement, August 24, 2000
`
`Exhibit No.
`1001
`
`1002
`1003
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`1017
`1018
`
`i
`
`
`
`IPR2020-01139
`U.S. Patent No. 8,382,186
`
`Description
`U.S. Patent No. 4,420,180 to Dupont et al., issued December 13,
`1983 (“Dupont”)
`U.S. Patent No. 4,280,729 to Morawski, issued July 28, 1981
`(“Morawski”)
`European Patent Application Publication No. 0379630 to
`Sagona, published August 1, 1990 (“Sagona”)
`File History of U.S. Patent No. 8,267,459 (“’459 Prosecution
`History”)
`U.S. Patent No. 3,390,912 to Stata, issued July 2, 1968 (“Stata”)
`German Patent Application Publication No. 4000877 to
`Weitbrecht et al., published July 18, 1991
`U.S. Patent No. 6,027,782 to Sherman, issued February 22, 2000
`Japanese Patent Application No. H11-268570 to Suzuki,
`published October 5, 1999, with attached certified English-
`language translation (“Suzuki”)
`Word Comparison of the ’703 Application as filed to the ’899
`Application as filed
`U.S. Patent No. 8,833,834 to MacNeil et al., issued September
`16, 2014 (“’834 Patent”)
`Plastic Extrusion Tolerance Guide
`Merriam-Webster's Collegiate Dictionary, Eleventh Edition,
`2003
`Oxford Compact English Dictionary, First Edition, 2000
`Curriculum Vitae of Paul E. Koch, Ph.D. (“Koch CV”)
`Declaration of Sylvia Hall-Ellis, Ph.D. (“Hall-Ellis Decl.”)
`U.S. Patent No. 8,910,995 to MacNeil et al. (“’995 Patent”)
`U.S. Patent No. 6,058,618 to Hemmelgarn et al.
`(“Hemmelgarn”)
`Webster’s Third New International Dictionary, 1961
`Transcript of Teleconference between Board and Parties,
`November 13, 2020
`Communications between MacNeil and Yita regarding the
`proposed modifications to the protective order
`
`Exhibit No.
`1019
`
`1020
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`1021
`
`1022
`1023
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`1024
`
`1025
`
`1026
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`1027
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`1028
`1029
`1030
`1031
`1032
`1033
`1034
`1035
`1036
`1037
`
`1038
`
`
`ii
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`
`
`IPR2020-01139
`U.S. Patent No. 8,382,186
`MacNeil seeks to enter a protective order that significantly alters the Board’s
`
`default protective order. MacNeil’s restrictions would deny access to all
`
`individuals at Petitioner Yita, including in-house counsel, and create a special class
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`of confidential information designated “PROTECTIVE ORDER MATERIAL –
`
`ATTORNEYS’ EYES ONLY” (“Attorneys’ Eyes Only”). See Paper 27, Motion
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`for Entry of Protective Order, Appendix B (redline comparison to Board’s default
`
`protective order). MacNeil seeks to prohibit everyone at Yita, including in-house
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`counsel, from accessing material that MacNeil self-designates as “Attorneys’ Eyes
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`Only.” Id.
`
`But the Board’s default protective order is sufficient here, and MacNeil has
`
`not shown otherwise. MacNeil’s modified protective order imposes unduly
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`prejudicial restrictions that are inconsistent with the integrity of this proceeding
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`and run afoul of the careful balance struck by the Board’s default protective order.
`
`MacNeil should not be able to argue that certain evidence demonstrates
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`patentability on the one hand, while simultaneously arguing that the very same
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`evidence cannot be seen by Yita on the other. Accordingly, the Board should deny
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`MacNeil’s Motion.
`
`I. Without agreement between the parties over a modified protective order,
`the Board’s default protective order should be entered.
`Because the parties have not agreed on the entry of a protective order,
`
`according to the Trial Practice Guide, the Board should enter the default protective
`
`1
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`order. The Office Patent Trial Practice Guide encourages parties “to agree on the
`
`entry of a stipulated protective order.” Office Patent Trial Practice Guide,
`
`Appendix B, 77 Fed. Reg. 48756, 48769 (Aug. 14, 2012). “Absent such agreement,
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`the default standing protective order will be automatically entered.”1 Id.
`
`Despite objections from Yita about MacNeil’s deviations from the default
`
`protective order, MacNeil unilaterally proceeded and now seeks to have entered its
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`divergent protective order. MacNeil’s changes are not trivial. For example, the
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`Board’s default protective order requires “persons who are named parties to the
`
`proceeding” and “[i]n-house counsel of a party” to have access to protective order
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`material. Patent Trial and Appeal Board Consolidated Trial Practice Guide, 108
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`(Nov. 2019), https://www.uspto.gov/TrialPracticeGuideConsolidated
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`(“Consolidated Trial Practice Guide”). MacNeil’s proposed altered protective order
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`excludes these persons from accessing any materials that MacNeil self-designates
`
`as “Attorneys’ Eyes Only.” Motion, 2-3, Appendix A.
`
`MacNeil first notified Yita of its proposed, altered protective order five days
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`before filing its Patent Owner’s Response. See EX1038, 3-4. (communications
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`between MacNeil and Yita regarding the proposed modifications to the protective
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`order). In return, Yita raised its concerns about the additional restrictive terms in
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`MacNeil’s proposed protective order and suggested entry of the Board’s default
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`
`1 Emphasis added throughout unless noted.
`
`2
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`protective order. Id., 1-3. But MacNeil refused to negotiate these terms with Yita.
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`Id., 1.
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`Because the parties have not agreed to a stipulated protective order, the
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`default protective order should be automatically entered consistent with the Trial
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`Practice Guide. Office Patent Trial Practice Guide, Appendix B, 77 Fed. Reg.
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`48756, 48769 (Aug. 14, 2012).
`
`II. MacNeil’s modifications violate the Trial Practice Guide by failing to
`define the types of information belonging in the “Attorneys’ Eyes Only”
`designation.
`“A protective order that deviates from the Board's default protective order
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`must nonetheless include certain terms as outlined in the Office Patent Trial
`
`Practice Guide ….” CRS Advanced Techs., Inc. v. Frontline Techs., Inc.,
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`CBM2012-00005, Paper 43 at 3 (P.T.A.B. May 28, 2013) (citing Office Patent
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`Trial Practice Guide 77 Fed. Reg. 48756, 48770 (Aug. 14, 2012)). For example,
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`modified protective orders “must adequately define what types of materials are to
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`be included in any additional tier or category of confidential information, such as
`
`Attorneys’ Eyes Only category.” Coolpad Techs., etc. v. Bell N. Research LLC,
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`IPR2019-01319, Paper 40, 5 (P.T.A.B. June 2, 2020.). Indeed, the Office Patent
`
`Trial Practice Guide states that “[t]he Board will not accept overly inclusive
`
`definitions that encourage the parties to categorize all or most of their discovery
`
`materials as ‘Attorneys’ Eyes Only.’” Consolidated Trial Practice Guide, 116.
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`3
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`Here, MacNeil does not define the type of information to be included in its
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`additional category for “Attorneys’ Eyes Only.” Rather, MacNeil merely
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`“contemplates” that the parties will use the “Attorneys’ Eyes Only” designation for
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`documents that would qualify for this second tier of confidentiality in district court
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`discovery practice. Motion, 4. However, MacNeil’s tenuous suggestion for
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`parallelism between the protective order designations in the district court
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`proceeding (where discovery is voluminous) and the PTAB proceeding (where
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`discovery is closely circumscribed) is inappropriate and in conflict with previous
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`PTAB guidance. See Consolidated Trial Practice Guide, 116; see also Coolpad
`
`Techs., Paper 40 at 4-5 (denying motion to enter a modified protective order
`
`because Petitioner did not adequately define the types of material to be included
`
`under the additional tier of confidentiality); Illumina, Inc. v. Natera, Inc., IPR2019-
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`01201, Paper 19, 49 (P.T.A.B. Dec. 18, 2019) (denying Petitioner’s motion for
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`“Attorney Eyes’ Only” category of confidentiality for not adequately defining the
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`types of materials to be included in this additional category of confidentiality);
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`Guardant Health, Inc. v. Foundation Med., Inc., IPR2017-01170, Paper 31, 3
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`(P.T.A.B. April 4, 2018) (denying Patent Owner’s motion to enter modified
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`protective order for imposing an overbroad restriction).
`
`MacNeil’s reliance on the district court’s protective order to define the types
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`of materials belonging in the additional tier of confidentiality does not satisfy the
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`4
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`terms of the Office Patent Trial Practice Guide. See Consolidated Trial Practice
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`Guide, 116; Illumina, Inc., Paper 19 at 49 (“The Board will not undertake to
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`review the district court protective order to identify which provisions of that
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`protective order Petitioner intends to have applied here.”) Indeed, the district
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`court’s protective order broadly defines the type of information to be included in
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`the “Attorney Eyes Only” category. See Motion, Appendix C, Section 2.2.
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`(“‘Outside Counsel Attorneys Eyes Only’ material shall include documents … that
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`… are reasonably believed by the designating party to represent … confidential
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`commercial information … that its dissemination cannot adequately be covered by
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`the protections set forth for confidential materials.”) The broad and inclusive
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`definition under the district court proceeding for “Attorneys’ Eyes Only”
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`information simply is not suitable for the type of information MacNeil offers in the
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`IPR proceeding, and MacNeil has not shown otherwise.
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`Thus, prohibiting all of Yita’s in-house counsel and personnel from viewing
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`material that MacNeil labels “Attorney’s Eyes Only,” yet hinges its patentability
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`arguments on, is inconsistent with the integrity and efficient administration of the
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`proceeding. Consolidated Trial Practice Guide, 115-116; see also Coolpad Techs.,
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`Paper 40 at 2 (“The parties may propose modifications to the Default Protective
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`Order and the Board will generally accept such proposed changes if they are
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`5
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`consistent with the integrity and efficient administration of the proceedings.” 2).
`
`Accordingly, the Board should deny entry of MacNeil’s modified protective order.
`
`III. MacNeil’s modifications to the Board’s default protective order are
`unnecessary.
`The standard acknowledgement of the Board’s default protective order
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`requires that confidential information will only be used “in connection with this
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`proceeding and for no other purpose.” Consolidated Trial Practice Guide, 113, 121.
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`This restriction in the standard acknowledgement shields MacNeil’s business
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`interests from competitors who may come across potential confidential business
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`information disclosed in this proceeding. Rather than accepting this scope of
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`protection, MacNeil proposes an overly inclusive measure—denying all of Yita’s
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`in-house counsel and personnel access to any information that MacNeil designates
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`“Attorneys’ Eyes Only.” Motion, 2-3.
`
`MacNeil, however, does not explain why the standard acknowledgement of
`
`the Board’s default protective order is insufficient to protect its business interests.
`
`Attempting to justify its proposed changes, MacNeil refers to two decisions—Endo
`
`Pharms., Inc. v. Depomed, Inc., IPR2014-00652, Paper 61, 2 (P.T.A.B. June 3,
`
`
`2 This guidance appears to apply in circumstances where the parties agree on
`
`the proposed changes to the Default Protective Order. Of course, this is not the
`
`case here.
`
`6
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`2015) and Cisco Systems, Inc. v. Crossroads Systems, Inc., IPR2014-01544, Paper
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`50, 29 (P.T.A.B. Jan. 29, 2016)—where the Board sealed exhibits that disclosed
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`product sales and licensing information, similar to the information MacNeil seeks
`
`to seal here. But in Cisco Systems, the Board entered the default protective order,
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`not a modified protective order. See Cisco Sys., Inc. v. Crossroads Sys., Inc.,
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`IPR2014-01544, Paper 39 at 2 (P.T.A.B. Sep. 29, 2015). And in Endo
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`Pharmaceuticals, the Board entered a stipulated protective order that still provided
`
`access to designated in-house counsel of the parties, unlike MacNeil’s modified
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`protective order that restricts access to all of Yita’s in-house counsel and
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`personnel. Compare Endo Pharms, Inc. v. Depomed, Inc., IPR2014-00652, Paper
`
`24, Exhibit B (P.T.A.B. Dec. 22, 2014), with Motion, Appendix B.
`
`Thus, MacNeil’s proposed changes to the Board’s default protective order—
`
`restricting all of Yita’s in-house counsel and personnel from accessing any
`
`information that MacNeil designates “Attorneys’ Eyes Only”—exceed what is
`
`necessary to protect its business interests.
`
`IV. MacNeil fails to show “good cause” for modifying the Board’s default
`protective order.
`In addition to meeting all the requirements outlined in the Office Patent Trial
`
`Practice Guide, MacNeil must still show “good cause” for entering its modified
`
`protective order in lieu of the Board’s default protective order. 37 C.F.R. §§ 42.20,
`
`42.54. As demonstrated below, MacNeil has failed to meet its burden.
`
`7
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`A. MacNeil does not show that concrete harm would result from
`disclosing the redacted material to the restricted parties.
`One requirement for establishing “good cause” is showing that concrete
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`harm would result from disclosing the protected material to the public or the
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`prohibited party. See Argentum Pharms. LLC v. Alcon Research, Ltd., IPR2017-
`
`01053, Paper 27, 3-4 (P.T.A.B. Jan. 19, 2018) (informative); Intri-Plex Techs.,
`
`Inc., etc. v. Saint-Gobain Performance Plastics Rencol Ltd., IPR2014-00309,
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`Paper 35 at 5-6 (P.T.A.B. Aug. 27, 2014).
`
`For example, in Intri-Plex Techs., the Board denied entry of a modified
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`protective order because the moving party failed to show that concrete harm would
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`result from entering the Board’s default protective order. Intri-Plex Techs., Paper
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`35 at 5-6. In that case, Patent Owner—Saint-Gobain—moved for entry of a non-
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`standard protective order and sought to redact various materials, including
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`“[i]nformation related to the volume of sales of alleged commercial embodiments
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`of the patented invention.” Id. at 5. Without submitting any evidence that it would
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`suffer injury if a default protective order was entered, Saint-Gobain expressed
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`concerns that its confidential information may be disclosed to employees of the
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`petitioner—Intri-Plex—who could allegedly exploit such information for Intri-
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`Plex’s advantage. Id. at 5-6. The Board denied entry of Saint-Gobain’s non-
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`standard protective order because Saint-Gobain failed to show how it “will suffer
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`substantial harm if the Board does not enter Saint-Gobain’s proposed, non-standard
`
`8
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`Protective Order” and “why its concerns are not addressed adequately by … [the
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`Board’s] default Protective Order.” Id. at 5-6.
`
`Likewise here, MacNeil fails to show that concrete harm would result from
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`entering the Board’s default protective order instead of its more restrictive
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`protective order. Specifically, MacNeil contends that its Patent Owner’s Response
`
`and Exhibit 2042 “may include competitively-sensitive business information.”
`
`Motion, 1-2. The potential sensitive business information redacted from these
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`documents is the number of sold tray sets and the gross sales revenue generated
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`between years 2004 and 2020. POR, 77-78; EX2042, 31. MacNeil indecisively
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`alleges that providing access to this information “could cause harm to the
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`producing party” and that “allowing any party representative to view potentially
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`confidential business information could be harmful to the other party’s business
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`interests.” Motion, 2-3.
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`MacNeil’s statements merely speculate about the possibility of harm if its
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`more restrictive protective order is not entered by the Board. Nowhere does
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`MacNeil describe any particular, concrete adverse consequences that will result
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`from disclosing the sales data to the restricted parties. Nor does MacNeil provide
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`any underlying facts or reasoned analysis supporting its speculations.
`
`9
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`Accordingly, just as the Board denied entry of Saint-Gobain’s non-standard
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`protective order for failing to show concrete harm, the Board should likewise deny
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`entry of MacNeil’s modified protective order.
`
`The district court’s protective order in parallel litigation does not
`B.
`establish “good cause” for modifying the Board’s default protective
`order.
`MacNeil also references the district court’s protective order in parallel
`
`litigation as alleged support for its modified protective order. Motion, 2-3.
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`Particularly, MacNeil notes that the district court’s protective order prohibits all
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`party representatives, including the parties’ in-house counsel, from accessing
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`documents designated “Attorneys’ Eyes Only.” Id. But the district court’s
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`protective order is irrelevant here.
`
`The standard for the Board to enter protective orders differs from district
`
`court. See Consolidated Trial Practice Guide, 116 (explaining to remove provisions
`
`in district court protective orders that are unnecessary or inappropriate in inter
`
`partes review proceedings). And a protective order previously entered by a district
`
`court in parallel litigation, alone, does not justify entering a protective order in the
`
`inter partes review. See Great W. Cas. Co., v. Intellectual Ventures II LLC,
`
`IPR2015-01706, Paper 60, 3-4 (P.T.A.B Aug. 6, 2019) (denying motion that
`
`merely refers to district court protective order to support entry of protective order
`
`in IPR); Guardant Health, Inc., Paper 36 at 4 (proposed restrictions in parallel
`
`10
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`district court litigation do not justify adopting the same restrictions in protective
`
`orders in inter partes review); Skechers U.S.A., Inc. v. Nike, Inc., IPR2017-00620,
`
`Paper 31 at 2-4 (P.T.A.B. Sep. 25, 2017) (denying unopposed motion to seal
`
`because good cause is not shown by stating that the document at issue was
`
`“previously sealed by a district court”).
`
`Thus, the district court’s protective order does not establish “good cause” for
`
`entering a second tier of confidentiality that restricts Yita’s in-house counsel from
`
`accessing material that MacNeil self-designates “Attorneys’ Eyes Only.”
`
`11
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`
`V. Conclusion
`The parties have not agreed on a modified protective order, and accordingly,
`
`in keeping with the Trial Practice Guide, the default protective order should be
`
`entered. Furthermore, MacNeil fails to show “good cause” for modifying the
`
`Board’s default protective order, neglecting to even define the type of information
`
`falling under the “Attorneys’ Eyes Only” designation. Yita respectfully requests
`
`that the Board deny MacNeil’s Motion to enter its modified protective order.
`
`Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/ R. Wilson Powers III /
`
`R. Wilson Powers III (Reg. No. 63,504)
`Attorney for Petitioner
`
`
`
`
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`
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`
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`
`
`Date: June 7, 2021
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`12
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`CERTIFICATE OF COMPLIANCE WITH PAGE LIMITATION,
`TYPEFACE REQUIREMENTS, AND TYPE STYLE REQUIREMENTS
`1.
`This Petitioner’s Opposition to Patent Owner’s Motion for Entry of
`
`
`
`Modified Protective Order complies with the page limitation of 15 pages,
`
`excluding the parts exempted by 37 C.F.R. § 42.24(a).
`
`
`
`2.
`
`This Petitioner’s Opposition to Patent Owner’s Motion for Entry of
`
`Modified Protective Order complies with the general format requirements of 37
`
`C.F.R. § 42.6(a) and has been prepared using Microsoft® Word 2016 in 14 point
`
`Times New Roman.
`
`Respectfully submitted,
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
` /
`
` R. Wilson Powers III /
`
`
`R. Wilson Powers III (Reg. No. 63,504)
`Attorney for Petitioner
`
`
`Date: June 7, 2021
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
`
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`
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`IPR2020-01139
`U.S. Patent No. 8,382,186
`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that on June 7, 2021, true and correct
`
`
`
`
`copies of the foregoing PETITIONER’S OPPOSITION TO PATENT
`
`OWNER’S MOTION FOR ENTRY OF MODIFIED PROTECTIVE ORDER
`
`and EXHIBIT 1038 were served electronically via e-mail in its entirety on the
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`following counsel for Patent Owner:
`
`David G. Wille (Lead Counsel)
`Chad C. Walters (Back-up Counsel)
`Clarke W. Stavinoha (Back-up Counsel)
`BAKER BOTTS L.L.P.
`david.wille@bakerbotts.com
`chad.walters@bakerbotts.com
`clarke.stavinoha@bakerbotts.com
`
`Jefferson Perkins (Back-up Counsel)
`PERKINS IP LAW GROUP LLC
`jperkins@perkinsip.com
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/ R. Wilson Powers III /
`
`R. Wilson Powers III (Reg. No. 63,504)
`Attorney for Petitioner
`
`
`
`
`
`Date: June 7, 2021
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
`
`
`
`16844165_3
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