`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`TENNANT COMPANY,
`Petitioner,
`v.
`OXYGENATOR WATER TECHNOLOGIES, INC.,
`Patent Owner.
`____________
`Case IPR2021-00625
`Patent RE45415
`____________
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`MOTION FOR ENTRY OF PROTECTIVE ORDER
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`Unopposed Motion for Entry of a Protective Order
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`Pursuant to 37 CRF § 42.54, Patent Owner, Oxygenator Water
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`Technologies, Inc., respectfully submits this Unopposed Motion for Entry of a
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`Protective Order in this proceeding. The parties have conferred and agreed to entry
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`of a Protective Order and to the terms of the Protective Order (“Proposed Protected
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`Order”). A clean version (Ex. 2113) of the Proposed Protective Order and a
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`marked-up comparison (Ex. 2114) of the Proposed Protective Order to the Default
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`Protective Order are submitted herewith. The Proposed Protective Order is the
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`same as the Default Protective Order except that section 2(B) has been replaced to
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`clarify that employees of the law firms of attorneys of record are allowed access to
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`confidential information.
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`Unless subsequently modified by the Board, the Proposed Protective Order
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`will cover confidential information submitted and sealed by the Board in
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`conjunction with a Motion to Seal in this proceeding. Good cause exists for the
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`Board to enter the Proposed Protective Order to protect the parties’ confidential
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`information and promote efficiency in resolution of the dispute.
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`Conclusion
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`For the foregoing reasons, the Patent Owner respectfully request that the
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`Board grant this motion and enter the Proposed Protective Order (Ex. 2113) in this
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`proceeding.
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`
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`Dated: September 22, 2021
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`Respectfully submitted,
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`/s/ J. Derek Vandenburgh
`J. Derek Vandenburgh
`Registration No. 32,179
`CARLSON, CASPERS, VANDENBURGH, &
`LINDQUIST, P.A.
`Capella Tower, Suite 4200
`225 South Sixth Street
`Minneapolis, MN 55402
`dvandenburgh@carlsoncaspers.com
`
`
`Counsel for Patent Owner Oxygenator
`Water Technologies, Inc
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`CERTIFICATION OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e) and the agreement of the parties, the
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`undersigned certifies that on September 22, 2021, a true and correct copy of the
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`foregoing was served via electronic mail upon the following:
`
`R. Scott Johnson (Reg. No. 45,792)
`Fredrikson & Byron, P.A.
`505 E. Grand Ave., Suite 200
`Des Moines, IA 50309
`Phone: (515) 242-8930
`Fax: (515) 242-8950
`Email: RSJohnson@fredlaw.com
`
`Adam R. Steinert
`Fredrikson & Byron, P.A.
`200 South 6th Street, Suite 4000
`Minneapolis, MN 55402
`Tel: (612) 492-7000
`Fax: (612) 492-7797
`Email: asteinert@fredlaw.com
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`
`
`/s/ J. Derek Vandenburgh
`J. Derek Vandenburgh
`(Lead Counsel)
`
`
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