`IPR2021-00144 (U.S. Patent No. 8,095,879)
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`SAMSUNG ELECTRONICS CO. LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC. AND
`APPLE INC.
`
`Petitioners
`
`
`v.
`
`NEONODE SMARTPHONE LLC,
`
`Patent Owner
`
`Case IPR2021-00144
`U.S. Patent No. 8,095,879
`
`
`SAMSUNG-PETITIONERS’ UNOPPOSED MOTION TO SEAL PATENT
`OWNER’S SUR-REPLY
`
`
`LIB\99999.9
`
`
`
`
`
`Samsung-Petitioners’ Unopposed Motion to Seal
`IPR2021-00144 (U.S. Patent No. 8,095,879)
`Pursuant to 37 C.F.R. § 42.54 and Petitioners Samsung Electronics Co. Ltd.,
`
`Samsung Electronics America, Inc. (collectively “Samsung-Petitioners”) previous
`
`Unopposed Motion to Seal and Submission of Joint Proposed Protective Order at
`
`Paper 39, Samsung-Petitioners move to seal a portion of Patent Owner’s Sur-reply
`
`(Paper 49) at page 5 (redaction at Exhibit 1073) as SAMSUNG-NEONODE-
`
`CONFIDENTIAL-APPLE ATTORNEY’S EYES ONLY under the Joint Proposed
`
`Protective Order. Samsung-Petitioners have met and conferred with Patent Owner,
`
`and Patent Owner does not oppose sealing the identified material.
`
`Samsung-Petitioners submit that, in light of the reasons discussed herein, in
`
`Samsung-Petitioners’ Motion to Seal at Paper 39, and the Board’s Order Granting
`
`Samsung-Petitioners’ Motion to Seal in a related proceeding (IPR2021-00145,
`
`Paper 53), good cause exists to seal the identified material in Patent Owner’s Sur-
`
`reply. The identified material at page 5 of Patent Owner’s Sur-reply references
`
`confidential information in the Samsung-Neonode Agreement of Exhibit 2028,
`
`which Samsung-Petitioners previously moved to seal in its entirety. See Paper 39.
`
`In particular, the identified material contains a reference to the terms of Exhibit
`
`2028 that the Board ordered sealed in a related proceeding. IPR2021-00145, Paper
`
`53 at 5-6. A public redacted version of Patent Owner’s Sur-reply, as agreed to by
`
`Patent Owner, is filed herewith at Exhibit 1073.
`
`LIB\99999.9
`
`1
`
`
`
`Samsung-Petitioners’ Unopposed Motion to Seal
`IPR2021-00144 (U.S. Patent No. 8,095,879)
`
`
`
`Dated: August 19, 2022
`
`
`
`Respectfully Submitted,
`
`
`/Tiffany C. Miller/
`Tiffany C. Miller, Reg. No. 52,032
`James M. Heintz, Reg. No. 41,828
`
`Attorneys for Samsung-Petitioners
`
`
`
`
`
`
`LIB\99999.9
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that service
`
`was made on the Patent Owner as detailed below:
`
`SAMSUNG-PETITIONERS’ UNOPPOSED MOTION TO SEAL
`PATENT OWNER’S SUR-REPLY
`
`Date of Service:
`
`August 19, 2022
`
`Manner of Service:
`
`Electronic Mail
`
`Kenneth J. Weatherwax
`Nathan Lowenstein
`
`Parham Hendifar
`
`
`Vinson Lin
`
`
`Philip Graves
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`weatherwax@lowensteinweatherwax.com
`lowenstein@lowensteinweatherwax.com
`hendifar@lowensteinweatherwax.com
`lin@lowensteinweatherwax.com
`philipg@hbsslaw.com
`
`Neonode_IPRs@lowensteinweatherwax.com
`
`
`
`Dated: August 19, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Tiffany C. Miller/
`
`
`
`
`
`LIB\99999.9
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
