`Petition for Inter Partes Review
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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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`SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS CO., LTD.,
`AND SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioners
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`v.
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`SOLAS OLED LTD.
`Patent Owner.
`______________________________________________
`Case No. IPR2021-00591
`U.S. Patent No. 7,868,880
`______________________________________________
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`JOINT REQUEST TO KEEP SEPARATE PURSUANT TO
`35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c)
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`U.S. Patent No. 7,868,880
`Petition for Inter Partes Review
`Patent Owner Solas Ltd. (“Solas”) and Petitioner Samsung Display Co., Ltd.
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`(“Samsung Display”) have reached a settlement. The settlement agreement
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`resolves the disputes in the above-captioned inter partes review relating to U.S.
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`Patent No. 7,868,880 (“Patent-in-Suit”). The parties jointly request that the Board
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`treat the settlement agreement as business confidential information and keep it
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`separate from the files of this proceeding and the files of the Patent-in-Suit. The
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`parties were authorized to file this Joint Motion by the Board (via email) on
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`April 4, 2022.
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`I. Statement of Precise Relief Requested
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`The parties jointly request that the Board treat the settlement agreement as
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`business confidential information and keep it separate from the files of this
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`proceeding and the files of the Patent-in-Suit. The parties request that the
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`settlement agreement “be made available only to Federal Government agencies on
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`written request, or to any person on a showing of good cause” in accordance with
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`35 U.S.C. § 317(b) and 37 C.F.R. § 42.74.
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`II. Reasons Why Relief Is Appropriate
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`The terms of the settlement agreement require the parties to treat the
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`settlement agreements as confidential information and limit their ability to share
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`the settlement agreement or disclose its content with third parties. The parties have
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`filed a copy of the settlement agreement with the Board, as required by 35 U.S.C.
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`1
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`U.S. Patent No. 7,868,880
`Petition for Inter Partes Review
`§ 317(b) and 37 C.F.R. § 42.74. The confidential settlement agreement was filed in
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`the PTAB E2E system to provide availability only to the Board.
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`Dated: April 8, 2022
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`Respectfully submitted,
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`/s/ Nicholas J. Whilt
`Nicholas J. Whilt (Reg. No. 72,081)
`Email: nwhilt@omm.com
`O’Melveny & Myers LLP
`300 South Hope Street, 18th Floor
`Los Angeles, California 90071
`Telephone: (213) 430-6000
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`Attorney for Petitioners
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`/s/ Neil A. Rubin
`Neil A. Rubin (Reg. No. 67,030)
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
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`Attorney for Patent Owner
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`U.S. Patent No. 7,868,880
`Petition for Inter Partes Review
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`CERTIFICATE OF SERVICE
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`The undersigned certifies to 37 C.F.R. §42.6(e) and §42.105 that the above
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`document was served on April 8, 2022 by filing this document through the Patent
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`Trial and Appeal Board End to End system as well as by delivering a copy via
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`electronic mail to the following attorneys of record for the Patent Owner:
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`/s/ Nicholas J. Whilt
`Nicholas J. Whilt (Reg. No. 72,081)
`Email: nwhilt@omm.com
`O’Melveny & Myers LLP
`300 South Hope Street, 18th Floor
`Los Angeles, California 90071
`Telephone: (213) 430-6000
`Attorney for Petitioners
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