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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________
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`ADOBE INC.,
`Petitioner
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`v.
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` SYNKLOUD TECHNOLOGIES, LLC,
`Patent Owner
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`Case IPR2020-01301
`U.S. Patent 9,219,780
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`______________
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`JOINT REQUEST TO MAINTAIN CONFIDENTIALITY
`AND TO KEEP SEPARATE
`PURSUANT TO 35 U.S.C. § 327(b) AND 37 C.F.R. § 42.74
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`1
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`I.
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`INTRODUCTION
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`SynKloud Technologies, LLC (“Patent Owner”) and Petitioner Adobe Inc.
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`(“Petitioner,” collectively “the Parties”) have executed a Settlement Agreement
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`regarding U.S. Patent Nos. 10,015,254, 9,289,780 and 9,239,686. Pursuant to 35
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`U.S.C. § 327(b), the Parties jointly request that the Board treat the Settlement
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`Agreement as business confidential information and keep it separate from the file
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`of the involved patent.
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`II. STATEMENT OF PRECISE RELIEF REQUESTED
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`The Parties jointly request that the Board treat the Settlement Agreement
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`(Exhibit 2042) as business confidential information and keep it separate from the
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`file of the involved patent. The Parties further request that the Board not make the
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`Settlement Agreement available to any third-party, except as provided for in 35
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`U.S.C. § 327(b) and 37 C.F.R. § 42.74.
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`III. STATEMENT OF REASONS FOR THE RELIEF REQUESTED
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`The Parties have settled all of their disputes involving U.S. Patents Nos.
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`10,015,254, 9,289,780 and 9,239,686 (collectively, the “Patents”). The Settlement
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`Agreement provides that its terms are confidential and the Parties have treated
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`them as such. The Parties have filed, concurrently herewith, a true and correct copy
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`of the Settlement Agreement (Exhibit 2042), as required by 35 U.S.C. § 327(b) and
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`37 C.F.R. § 42.74. The Exhibit was filed via the PRPS system to provide
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`availability to the “Parties and Board Only.” The Parties jointly request that the
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`Settlement Agreement be treated as business confidential information and be kept
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`separate from the file of the involved patent, pursuant to 35 U.S.C. § 327(b) and 37
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`C.F.R. § 42.74(c).
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`Dated: June 23, 2021
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`Respectfully Submitted,
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`By: /s/ Gregory J. Gonsalves
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`
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`Dr. Gregory Gonsalves
`Reg. No. 43,639
`Capitol IP Law Group, PLLC
`1918 18th St, Unit 4, NW
`Washington, DC 20009
`Phone: 571-419-7252
`Email: gonsalves@capitoliplaw.com
`
`
`Lead Counsel for Patent Owner
`
`/s/ James L. Day
`James L. Day (Reg. No. 72,681)
`Fabella Braun + Martel LLP
`235 Montgomery Street, 17th Floor
`San Francisco, California, 94104.
`jday@fbm.com
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`
`Lead Counsel for Petitioner
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`3
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`CERTIFICATE OF SERVICE
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`I hereby certify that the Joint Motion To Maintain Confidentiality was
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`served on this 23rd day of June, 2021 by electronic mail to the following:
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`Lead Counsel
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`James L. Day (Reg. No. 72,681)
`Farella Braun + Martel LLP
`235 Montgomery Street, 17th Floor
`San Francisco, California, 94104.
`jday@fbm.com
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`Backup Counsel
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`Winston Liaw (Reg. No. 78,766)
`Daniel Callaway (Reg. No. 74,267)
`Farella Braun + Martel LLP
`235 Montgomery Street, 17th Floor
`San Francisco, California, 94104.
`wliaw@fbm.com
`dcallaway@fbm.com
`calendar@fbm.com
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`Date: June 23, 2021
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`By: _/Gregory Gonsalves_____
`Dr. Gregory Gonsalves
`Reg. No. 43,639
`Capitol IP Law Group, PLLC
`1918 18th St, Unit 4, NW
`Washington, DC 20009
`Phone: 571-419-7252
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`4
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