`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD.; AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`SONY CORPORATION; AND
`SONY MOBILE COMMUNICATIONS INC.,
`Petitioners,
`
`v.
`
`NEODRON LTD.,
`Patent Owner.
`
`
`
`
`
`
`
` Case No. IPR2020-01682
`U.S. Patent No. 8,749,251
`
`
`
`JOINT REQUEST TO KEEP SEPARATE PURSUANT TO 35 U.S.C.
`§ 317(b) AND 37 C.F.R. § 42.74(c)
`
`
`
`
`
`Case No. IPR2020-01682
`U.S. Patent No. 8,749,251
`
`Patent Owner Neodron Ltd. and Petitioners Samsung Electronics Co., Ltd. and
`
`Samsung Electronics America, Inc. (collectively “Samsung”), and Sony Corporation
`
`and Sony Mobile Communications Inc. (collectively “Sony”) have reached a
`
`settlement. The settlement agreements resolve the disputes in the above-captioned
`
`inter partes review relating to U.S. Patent No. 8,749,251 (“Patent-in-Suit”). The
`
`parties jointly request that the Board treat the settlement agreements as business
`
`confidential information and keep them separate from the files of this proceeding
`
`and the files of the Patent-in-Suit. The parties were authorized to file this Joint
`
`Motion by the Board (via email) on February 1, 2021.
`
`I.
`
`Statement of Precise Relief Requested
`
`The parties jointly request that the Board treat the settlement agreements as
`
`business confidential information and keep them separate from the files of this
`
`proceeding and the files of the Patent-in-Suit. The parties request that the settlement
`
`agreements “be made available only to Federal Government agencies on written
`
`request, or to any person on a showing of good cause” in accordance with 35 U.S.C.
`
`§ 317(b) and 37 C.F.R. § 42.74.
`
`II. Reasons Why Relief Is Appropriate
`
`The terms of the settlement agreements require the parties to treat the
`
`settlement agreements as confidential information and limit their ability to share the
`
`settlement agreements or disclose their content with third parties. The parties have
`
`
`
`1
`
`
`
`Case No. IPR2020-01682
`U.S. Patent No. 8,749,251
`
`filed copies of the settlement agreements with the Board, as required by 35 U.S.C.
`
`§ 317(b) and 37 C.F.R. § 42.74. The confidential settlement agreements were filed
`
`in the PTAB E2E system to provide availability only to the Board.
`
`
`
`Date: February 5, 2021
`
` /Reza Mirzaie/
`
`
`
`
`
`Respectfully submitted,
`
`
`Reza Mirzaie (Reg. No. 69,138)
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
` rmirzaie@raklaw.com
`
`Counsel for Patent Owner
`
` /John Kappos/
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, California 92660
`Phone: (949) 823-6954
`jkappos@omm.com
`
`Counsel for Samsung Electronics Co.,
`Ltd. and Samsung Electronics
`America, Inc.
`
` /Randy Pritzker/
`
`
`
`
`
`
`
`Randy Pritzker (Reg. No. 35,986)
`Wolf Greenfield & Sacks, P.C.
`
`2
`
`
`
`Case No. IPR2020-01682
`U.S. Patent No. 8,749,251
`
`600 Atlantic Ave.
`Boston, MA 02210
`Phone: (617) 646-8000
`RPritzker-
`PTAB@wolfgreenfield.com
`
`
`Counsel for Sony Corporation and
`Sony Mobile Communications Inc.
`
`
`
`
`
`
`
`3
`
`
`
`Case No. IPR2020-01682
`U.S. Patent No. 8,749,251
`
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
`
`
`The undersigned hereby certifies that the above document was served on
`
`February 5, 2021, by filing this document through the Patent Trial and Appeal Board
`
`End to End system as well as delivering a copy via electronic mail upon the
`
`following attorneys of record for the Petitioners:
`
`John Kappos, jkappos@omm.com
`Nicholas Whilt, nwhilt@omm.com
`Nancy Schroeder, nschroeder@omm.com
`Randy Pritzker, rpritzker-ptab@wolfgreenfield.com
`Marc Johannes, mjohannes-ptab@wolfgreenfield.com
`NeodronSamsungOMM@omm.com
`
`Date: February 5, 2021
`
` /Reza Mirzaie/
`
`
`
`
`
`Reza Mirzaie (Reg. No. 69,138)
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`Phone: (310) 826-7474
` rmirzaie@raklaw.com
`
`Counsel for Patent Owner
`
`4
`
`
`
`
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`
`
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