`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 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
`______________________________________________
`
`
`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 Electronics Co.,
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`Ltd., and Samsung Electronics America, Inc. (Collectively “Samsung”) have
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`reached a settlement. The settlement agreement resolves the disputes in the above-
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`captioned inter partes review relating to U.S. Patent No. 7,868,880 (“Patent-in-
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`Suit”). 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 were authorized to file
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`this Joint Motion by the Board (via email) on August 9, 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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`
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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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`
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`Dated: August 12, 2022
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`Respectfully submitted,
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`
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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
`
`
`
`
`/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
`
`Attorney for Patent Owner
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`
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`2
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`
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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 August 12, 2022 by filing this document through the
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`Patent Trial and Appeal Board End to End system as well as by delivering a copy
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`via electronic mail to the 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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`3
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