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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`DISH NETWORK, L.L.C.
`Petitioner
`
`v.
`
`BROADBAND ITV, INC.
`Patent Owner
`______________________
`
`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`______________________
`
`
`
`
`PATENT OWNER BROADBAND iTV, INC.’S MOTION UNDER 37 C.F.R.
`§§ 42.14 AND 42.54 TO SEAL PATENT OWNER’S RESPONSE AND
`EXHIBITS 2035-2038, 2047, 2050-2061, 2063-2068, 2070, 2073-2102, 2104-
`2109, 2117-2127, 2129-2151, 2154-2166, 2177-2179, AND 2181-2185 AND
`ENTER PROTECTIVE ORDER
`
`
`
`
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`
`I.
`II.
`III.
`
`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................................... 1
`GOVERNING RULES AND PTAB GUIDANCE ......................................... 2
`IDENTIFICATION OF CONFIDENTIAL INFORMATION AND
`CERTIFICATION THAT THE CONFIDENTIAL DOCUMENTS
`SOUGHT TO BE PROTECTED HAVE NOT BEEN MADE
`PUBLICALLY AVAILABLE ........................................................................ 4
`IV. GOOD CAUSE EXISTS FOR SEALING THE CONFIDENTIAL
`INFORMATION. ............................................................................................ 5
`A.
`Inventor Emails ..................................................................................... 6
`B.
`Technical Documents ............................................................................ 7
`C.
`Draft Patent Applications ...................................................................... 8
`D.
`Patent Owner’s Response ...................................................................... 8
`E.
`Declarations Supporting Patent Owner’s Response .............................. 8
`PROPOSED PROTECTIVE ORDER ...........................................................10
`V.
`VI. RELIEF REQUESTED .................................................................................11
`
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`U.S. Patent No. 10,028,026
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`I.
`
`INTRODUCTION
`Patent Owner Broadband iTV, Inc. (“Patent Owner”), requests that the
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`confidential version of the Patent Owner’s Response (“POR,” Paper 35) and the
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`confidential versions of accompanying Exhibits 2035-2038, 2047, 2050-2061,
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`2063-2068, 2070, 2073-2102, 2104-2109, 2117-2127, 2129-2151, 2154-2166,
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`2177-2179, and 2181-2185 (collectively the “Confidential Documents”) be sealed
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`under 37 C.F.R. §§ 42.14 and 42.54. Good cause to seal the Confidential
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`Documents exists because information in the Confidential Documents is sensitive,
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`non-public information that a business would not make public. Patent Owner
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`therefore submits this Motion to Seal and requests entry of a protective order in the
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`form appended hereto as Appendix A.
`
`Pursuant to 37 C.F.R. § 42.54(a), Patent Owner’s counsel conferred in good
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`faith with Petitioner’s counsel in an attempt to resolve any dispute about this
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`Motion. Counsel for Petitioner indicated:
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`We are not generally opposed to filings under seal and use of the
`default protective order in appropriate circumstances. But, given that
`we do not know what type of information you contend is confidential,
`we are not in a position to determine whether or not we oppose at this
`time.
`
`EX2186.
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`Case IPR2020-01267
`U.S. Patent No. 10,028,026
`II. GOVERNING RULES AND PTAB GUIDANCE
`In determining whether to grant a Motion to Seal, the Board must find “good
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`cause,” 37 C.F.R. § 42.54(a), and “strike a balance between the public’s interest in
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`maintaining a complete and understandable file history and the parties’ interest in
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`protecting truly sensitive information,” Consolidated Trial Practice Guide,
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`November 2019 (“TPG”), 19. The Board identifies confidential information in a
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`manner “consistent with Federal Rule of Civil Procedure 26(c)(1)(G), which
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`provides for protective orders for … confidential research, development, or
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`commercial information.” TPG, 19.
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`Based on the procedure provided in the TPG, Patent Owner seeks to prevent
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`the disclosure of sensitive business and confidential technical information
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`contained in the aforementioned Confidential Documents.
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`In previous inter partes review (IPR) proceedings, the Board has provided
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`different remedies to maintain the confidentiality of sensitive information. For
`
`example, the Board in Samsung Electronics Co., Ltd. v. NVIDIA Corp. granted a
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`patent owner’s Motion to Seal documents that contain highly confidential technical
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`information, including source code and design documents, relating to the patent
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`owner’s core business. IPR2015-01070, Paper 33 at 3 (P.T.A.B. Mar. 24, 2016).
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`There, the patent owner argued, “[p]ublic disclosure of this information would
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`significantly harm NVIDIA’s competitive position because it would allow
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`U.S. Patent No. 10,028,026
`competitors to access sensitive technical information.” Id., Paper 6 at 1 (P.T.A.B.
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`July 27, 2015). Similarly in this proceeding, public disclosure of Patent Owner’s
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`emails and technical documents would significantly disadvantage Patent Owner’s
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`competitive position because competitors would have access to sensitive technical
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`information about Patent Owner’s commercial products.
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`Furthermore, the Board in Riverbed Technology, Inc. v. Silver Peak Systems,
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`Inc., granted a motion to seal during the duration of the IPR proceedings. IPR2014-
`
`00245, Paper 36 at 4-5 (P.T.A.B. Nov. 19, 2014). There, the patent owner sought
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`to file source code under seal to antedate a reference cited by the petitioner. The
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`patent owner indicated that if the source code were to become public, it would
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`create a risk of “copying and other competitive harms.” Id., Paper 27 at 3.
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`Accordingly, the Board conditionally granted the motion to seal for the duration of
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`the proceeding, stating:
`
`Considering the stated importance and sensitivity of Exhibit 2015 to
`Patent Owner, rather than denying the Motion to Seal, which would
`make Exhibit 2015 immediately publicly accessible, the Board
`conditionally grants the motion for the duration of this proceeding. If
`the Board’s final decision substantively relies on any information in
`Exhibit 2015, then Exhibit 2015 will be unsealed (in whole or in part)
`by an Order of the Board. However, if the Board does not rely on any
`information in Exhibit 2015, then Exhibit 2015 will be expunged from
`the record by an Order of the Board.
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`Id., Paper 36 at 4-5. Similarly, in this case, Patent Owner is attempting to antedate
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`a reference using confidential emails and technical documents. The emails and
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`technical documents include confidential information of Patent Owner’s
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`commercial products. If these emails and technical documents were to become
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`public, competitors could copy their commercial products and internal processes,
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`resulting in competitive harm.
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`In another case, the Board provided the parties an opportunity after a Final
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`Written Decision to determine the scope of final redactions to the public. In
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`Caterpillar Inc. v. Wirtgen America, Inc., the Board initially issued a Final Written
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`Decision under seal and provided the parties an opportunity to identify redactions
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`for the public version of the record. IPR2017-02185, Paper 42 (P.T.A.B. May 3,
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`2019). The Board then issued the Final Written Decision and exhibits with
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`narrowly-tailored redactions. Id., Paper 51. The Board could use a similar approach
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`here. 37 C.F.R. § 42.5.
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`III.
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`IDENTIFICATION OF CONFIDENTIAL INFORMATION AND
`CERTIFICATION THAT THE CONFIDENTIAL DOCUMENTS
`SOUGHT TO BE PROTECTED HAVE NOT BEEN MADE
`PUBLICALLY AVAILABLE
`Patent Owner has submitted with its Patent Owner Response certain
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`documents that it requests be kept confidential and maintained under seal: a
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`confidential version of the Patent Owner’s Response (Paper 35) and Exhibits 2035-
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`2038, 2047, 2050-2061, 2063-2068, 2070, 2073-2102, 2104-2109, 2117-2127,
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`2129-2151, 2154-2166, 2177-2179, and 2181-2185. There are five groups of
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`documents: (1) inventor emails; (2) internal technical documents; (3) draft patent
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`applications; (4) the Patent Owner Response; and (5) declarations supporting the
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`Patent Owner Response. As explained below, good cause exists to maintain these
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`documents under seal and in accordance with the Protective Order. See
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`Appendix A.
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`Patent Owner certifies that, to the best of its knowledge, none of the
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`Confidential Documents described above have been published or otherwise made
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`public.
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`IV. GOOD CAUSE EXISTS FOR SEALING THE CONFIDENTIAL
`INFORMATION.
`The Board routinely seals confidential emails and technical documents. See,
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`e.g., Samsung Electronics Co., Ltd., IPR2015-01070, Paper 33; Riverbed
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`Technology, Inc., IPR2014-00245, Paper 26; Caterpillar Inc., IPR2017-02185,
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`Paper 42. Here, the confidential versions of the POR and Exhibits 2035-2038,
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`2047, 2050-2061, 2063-2068, 2070, 2073-2102, 2104-2109, 2117-2127, 2129-
`
`2151, 2154-2166, 2177-2179, and 2181-2185 contain this same type of
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`information, namely confidential emails, including emails between the company
`
`and its attorney or record, and technical documents. For example, the Confidential
`
`Documents contain internal emails between company employees including
`
`personally identifiable information, and documents describing how BBiTV’s
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`products were created, as well as communications between the company and its
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`attorney of record. Good cause exists to seal and keep this information confidential
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`because it includes details which would be valuable to Patent Owner’s competitors
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`and harmful to Patent Owner and possibly third parties if made public.
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`Accordingly, as in Samsung, Riverbed, and Caterpillar, the Board should seal and
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`keep this information confidential.
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`Public disclosure of the Confidential Documents would significantly harm
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`Patent Owner’s competitive and strategic position in the marketplace. And the
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`public interest will not be harmed by granting this Motion to Seal the documents as
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`“PROTECTIVE ORDER MATERIAL,” because the privacy and confidentiality
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`interests outweigh any public interest in the content of the emails and documents.
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`In short, granting this Motion to Seal would achieve “a balance between the
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`public’s interest in maintaining a complete and understandable file history and the
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`parties’ interest in protecting truly sensitive information.” 77 Fed. Reg. at 48,760.
`
`Therefore, good cause exists for granting this motion to seal.
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`Inventor Emails
`A.
`Exhibits 2047, 2056-2060, 2064-2065, 2068, 2073-2092, 2094-2102, 2104-
`
`2109, 2117-2119, 2121-2122, 2130-2131, 2136, 2138-2141, 2143-2149, 2155-
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`2156, 2159-2163, 2166, 2179, and 2181-2184 are company emails that describe the
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`design of BBiTV systems, internal company communications involving other
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`U.S. Patent No. 10,028,026
`employees and personally identifiable information, as well as communications
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`with its attorney of record. Each of these exhibits contains highly sensitive and
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`proprietary technical information about Patent Owner’s product development as it
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`relates to design, implementation, and testing. Patent Owner does not intend to file
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`redacted versions of Exhibits 2047, 2056-2060, 2064-2065, 2068, 2073-2092,
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`2094-2102, 2104-2109, 2117-2119, 2121-2122, 2130-2131, 2136, 2138-2141,
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`2143-2149, 2155-2156, 2159-2163, 2166, 2179, and 2181-2184 because all
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`relevant information is highly sensitive confidential business information.
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`Technical Documents
`B.
`Exhibits 2050-2055, 2063, 2070, 2093, 2123-2127, 2129, 2132-2135, 2137,
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`2142, 2150-2151, 2154, 2157-2158, 2164-2165, and 2178 are technical documents
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`describing the design and implementation of Patent Owner’s products. Each of
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`these exhibits contains highly sensitive and proprietary technical information about
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`Patent Owner’s product development as it relates to design, implementation, and
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`testing. Patent Owner does not intend to file redacted versions of Exhibits 2050-
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`2055, 2063, 2070, 2093, 2123-2127, 2129, 2132-2135, 2137, 2142, 2150-2151,
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`2154, 2157-2158, 2164-2165, and 2178 because all relevant information is highly
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`sensitive confidential business information.
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`C. Draft Patent Applications
`Exhibits 2061, 2066-2067, 2120, 2177, and 2185 contain material for Patent
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`Owner’s draft patent applications. These documents include confidential material
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`and appear to have been prepared with the assistance of counsel. Patent Owner
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`does not intend to file redacted versions of Exhibits 2061, 2066-2067, 2120, 2177,
`
`and 2185 because all relevant information is highly sensitive confidential business
`
`information.
`
`Patent Owner’s Response
`D.
`Some portions of the Patent Owner’s Response (Paper 35) are not
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`confidential. But portions of the Patent Owner’s Response describe confidential
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`material identified above. For example, Sections 1.A and 1.B include and describe
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`material from confidential technical documents and email communications. These
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`portions contain highly sensitive and proprietary technical information and
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`business information about the design, development, management,
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`implementation, and testing of Patent Owner’s products.
`
`Patent Owner has filed a redacted version of the Patent Owner’s Response
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`(Paper 36) to protect the confidential information.
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`E. Declarations Supporting Patent Owner’s Response
`Exhibit 2035 is the declaration of Michael Shamos. Among other things,
`
`Shamos’s declaration talks about the invention date of the claimed subject matter.
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`Shamos’s declaration also describes in detail and refers to confidential documents
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`related to conception of the claimed subject matter, diligence to a reduction to
`
`practice, and an actual reduction to practice. As with the confidential exhibits
`
`described above, Shamos’s declaration contains highly sensitive and proprietary
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`technical and business information about Patent Owner’s product development.
`
`But not all of Shamos’s declaration contains confidential information, so Patent
`
`Owner has filed a redacted version to protect the confidential information.
`
`Exhibit 2036 is the declaration of Milton Diaz. Diaz is CTO of BBiTV and
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`is one of the inventors of the claimed subject matter. Diaz’s declaration describes
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`in detail and refers to confidential documents related to conception of the claimed
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`subject matter, diligence to a reduction to practice, and an actual reduction to
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`practice. As with the confidential exhibits described above, Diaz’s declaration
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`contains highly sensitive and proprietary business information about Patent
`
`Owner’s product development, as well as personally identifiable information. But
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`not all of Diaz’s declaration contains confidential information, so Patent Owner
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`has filed a redacted version to protect the confidential information.
`
`Exhibit 2037 is the declaration of Leighton Chong. Chong was the patent
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`attorney for BBiTV during the relevant time frame. Chong’s declaration describes
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`confidential documents related to conception of the claimed subject matter,
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`diligence to a reduction to practice, and an actual reduction to practice. As with the
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`confidential exhibits described above, Chong’s declaration contains highly
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`U.S. Patent No. 10,028,026
`sensitive and proprietary business information about Patent Owner’s product
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`development, as well as personally identifiable information. But not all of Chong’s
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`declaration contains confidential information, so Patent Owner has filed a redacted
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`version to protect the confidential information.
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`Exhibit 2038 is the declaration of Clifton Kagawa. Kagawa is the CEO of
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`BBiTV. Kagawa’s declaration describes confidential documents related to
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`conception of the claimed subject matter, diligence to a reduction to practice, and
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`an actual reduction to practice. As with the confidential exhibits described above,
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`Kagawa’s declaration contains highly sensitive and proprietary business
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`information about Patent Owner’s product development, as well as personally
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`idenitifiable information. But not all of Kagawa’s declaration contains confidential
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`information, so Patent Owner has filed a redacted version to protect the
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`confidential information.
`
`V.
`
`PROPOSED PROTECTIVE ORDER
`Patent Owner requests entry of the Protective Order attached to this motion
`
`as Appendix A. Patent Owner has conferred with Petitioner about using the
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`PTAB’s Default Protective Order, and Petitioner is not generally opposed to using
`
`the Default Protective Order. See EX2186.
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`U.S. Patent No. 10,028,026
`
`VI. RELIEF REQUESTED
`For the reasons stated above, Patent Owner requests that the Board seal and
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`protect Patent Owner’s confidential information contained in the confidential
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`versions of the Patent Owner’s Response and Exhibits 2035-2038, 2047, 2050-
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`2061, 2063-2068, 2070, 2073-2102, 2104-2109, 2117-2127, 2129-2151, 2154-
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`2166, 2177-2179, and 2181-2185 and enter a Protective Order in this proceeding in
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`the form appended hereto as Appendix A. Patent Owner further requests that the
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`Board seal and protect the confidential information in these documents until such
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`time as it receives and rules on this Motion.
`
`Respectfully submitted,
`FEINBERG DAY KRAMER ALBERTI LIM TONKOVICH
`& BELLOLI LLP
`
`/David Alberti/
`
`David Alberti
`Registration No. 43,465
`Counsel for Patent Owner
`
`Date: May 10, 2021
`577 Airport Blvd, Suite 250
`Burlingame, CA 94010
`(650) 825-4300
`
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`U.S. Patent No. 10,028,026
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e))
`The undersigned hereby certifies that a true and correct copy of the
`
`foregoing PATENT OWNER BROADBAND ITV, INC.’S MOTION UNDER
`
`37 C.F.R. §§ 42.14 AND 42.54 TO SEAL PATENT OWNER’S RESPONSE
`
`AND 2035-2038, 2047, 2050-2061, 2063-2068, 2070, 2073-2102, 2104-2109,
`
`2117-2127, 2129-2151, 2154-2166, 2177-2179, AND 2181-2185 AND ENTER
`
`PROTECTIVE ORDER was served electronically via e-mail on May 10, 2021,
`
`in its entirety on the following counsel of record for Petitioner:
`
`Alyssa Caridis (Lead Counsel)
`K. Patrick Herman (Back-up Counsel)
` Clement Roberts (Back-up Counsel)
` Will Melehani (Back-up Counsel)
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`A8CPTABDocket@orrick.com
`P52PTABDocket@orrick.com
`croberts@orrick.com
`wmelehani@orrick.com
`
`Respectfully submitted,
`FEINBERG DAY KRAMER ALBERTI LIM TONKOVICH
`& BELLOLI LLP
`
`/David Alberti/
`
`David Alberti
`Registration No. 43,465
`Counsel for Patent Owner
`
`Date: May 10, 2021
`577 Airport Blvd, Suite 250
`Burlingame, CA 94010
`(650) 825-4300
`
`
`
`APPENDIX A
`
`APPENDIX A
`
`
`
`DEFAULT PROTECTIVE ORDER
`
`The following Default Protective Order will govern the filing and treatment of
`
`confidential information in the proceeding:
`
`Default Protective Order
`
`This protective order governs the treatment and filing of confidential information,
`
`including documents and testimony.
`
`1. Confidential information shall be clearly marked “PROTECTIVE ORDER
`
`MATERIAL.”
`
`2. Access to confidential information is limited to the following individuals who
`
`have executed the acknowledgment appended to this order:
`
`(A) Parties. Persons who are owners of a patent involved in the proceeding and
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`other persons who are named parties to the proceeding.
`
`(B) Party Representatives. Representatives of record for a party in the
`
`proceeding.
`
`(C) Experts. Retained experts of a party in the proceeding who further certify in
`
`the Acknowledgement that they are not a competitor to any party, or a consultant
`
`for, or employed by, such a competitor with respect to the subject matter of the
`
`proceeding.
`
`(D) In-house counsel. In-house counsel of a party.
`
`(E) Support Personnel. Administrative assistants, clerical staff, court reporters and
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`
`
`other support personnel of the foregoing persons who are reasonably necessary to
`
`assist those persons in the proceeding shall not be required to sign an
`
`Acknowledgement, but shall be informed of the terms and requirements of the
`
`Protective Order by the person they are supporting who receives confidential
`
`information.
`
`(F) The Office. Employees and representatives of the United States Patent and
`
`Trademark Office who have a need for access to the confidential information shall
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`have such access without the requirement to sign an Acknowledgement. Such
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`employees and representatives shall include the Director, members of the Board
`
`and their clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
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`3. Employees (e.g., corporate officers), consultants, or other persons performing
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`work for a party, other than those persons identified above in (d)(2)(A)–(E), shall be
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`extended access to confidential information only upon agreement of the parties or by
`
`order of the Board upon a motion brought by the party seeking to disclose confidential
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`information to that person and after signing the Acknowledgment. The party opposing
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`disclosure to that person shall have the burden of proving that such person should be
`
`restricted from access to confidential information.
`
`4. Persons receiving confidential information shall use reasonable efforts to
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`118
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`
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`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons not
`
`authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality of the
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`information, which efforts shall be no less rigorous than those the recipient uses to
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`maintain the confidentiality of information not received from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access to the
`
`confidential information understand and abide by the obligation to maintain the
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`confidentiality of information received that is designated as confidential; and
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`(D) Limiting the copying of confidential information to a reasonable number of
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`copies needed for conduct of the proceeding and maintaining a record of the
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`locations of such copies.
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`5. Persons receiving confidential information shall use the following procedures
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`to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board along with a Motion
`
`to Seal. The Motion to Seal should provide a non-confidential description of the
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`nature of the confidential information that is under seal, and set forth the reasons
`
`why the information is confidential and should not be made available to the
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`public. A party may challenge the confidentiality of the information by opposing
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`
`
`
`
`
`the Motion to Seal. The documents or information shall remain under seal unless
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`the Board determines that some or all of it does not qualify for confidential
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`treatment.
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`(ii) Where confidentiality is alleged as to some but not all of the information
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`submitted to the Board, the submitting party shall file confidential and
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`non-confidential versions of its submission, together with a Motion to Seal the
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`confidential version setting forth the reasons why the information redacted from
`
`the non-confidential version is confidential and should not be made available to
`
`the public. A party may challenge the confidentiality of the information by
`
`opposing the Motion to Seal. The non-confidential version of the submission
`
`shall clearly indicate the locations of information that has been redacted. The
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`confidential version of the submission shall be filed under seal. The redacted
`
`information shall remain under seal unless the Board determines that some or all
`
`of the redacted information does not qualify for confidential treatment.
`
` (B) Documents and Information Exchanged Among the Parties. Documents
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`(including deposition transcripts) and other information designated as confidential
`
`that are disclosed to another party during discovery or other proceedings before
`
`the Board shall be clearly marked as “PROTECTIVE ORDER MATERIAL” and
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`shall be produced in a manner that maintains its confidentiality.
`
`
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`6. Within 60 days after the final disposition of this action, including the
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`
`
`
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`120
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`
`
`exhaustion of all appeals and motions, each party receiving confidential information must
`
`return, or certify the destruction of, all copies of the confidential information to the
`
`
`
`producing party.
`
`
`
`(k) Standard Acknowledgement of Protective Order. The following form may be used to
`
`acknowledge a protective order and gain access to information covered by the protective
`
`order:
`
`[CAPTION]
`
`
`
`Standard Acknowledgment for Access to Protective Order Material
`
`
`
`
`
`I __________________________________________, affirm that I
`
`have read the Protective Order; that I will abide by its terms; that I will use
`
`the confidential information only in connection with this proceeding and
`
`for no other purpose; that I will only allow access to support staff who are
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`reasonably necessary to assist me in this proceeding; that prior to any
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`disclosure to such support staff I informed or will inform them of the
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`requirements of the Protective Order; that I am personally responsible for
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`the requirements of the terms of the Protective Order and I agree to submit
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`to the jurisdiction of the Office and the United States District Court for the
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`Eastern District of Virginia for purposes of enforcing the terms of the
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`121
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`Protective Order and providing remedies for its breach.
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`[Signature]
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`122
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