`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`CYPRESS SEMICONDUCTOR CORP. and STMICROELECTRONICS, INC.,
`Petitioners,
`
`v.
`
`NEODRON LTD.
`Patent Owner.
`
`
` Case IPR2021-01128
`Patent No. 8,432,173
`
`JOINT REQUEST TO KEEP SEPARATE
`
`Patent Owner Neodron Ltd. and Petitioners Cypress Semiconductor
`
`Corporation and STMicroelectronics, Inc., have reached a settlement. The settlement
`
`agreement resolves the disputes in the above-captioned inter partes review relating
`
`to U.S. Patent No. 8,432,173 (“Patent-in-Suit”). Patent Owner’s and Petitioners
`
`jointly request that the Board treat the settlement agreement as business confidential
`
`information and keep it separate from the files of this proceeding and the files of the
`
`Patent-in-Suit. Patent Owner and Petitioners were authorized to file this Joint
`
`Motion by the Board (via email) on December 23, 2021.
`
`
`
`Case IPR2021-01128
`Patent No. 8,432,173
`
`I.
`
`
`
`Statement of Precise Relief Requested
`
`Patent Owner and Petitioners jointly request that the Board treat the settlement
`
`agreement as business confidential information and keep it separate from the files of
`
`this proceeding and the files of the Patent-in-Suit. Patent Owner and Petitioners
`
`request that the settlement agreement “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 agreement require Patent Owner and Petitioners
`
`to treat the settlement agreement as confidential information and limit their ability
`
`to share the settlement agreement or disclose its contents with third parties. Patent
`
`Owner and Petitioners have filed a copy of the settlement agreement with the Board,
`
`as required by 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74. The confidential settlement
`
`agreement was filed in the PTAB E2E system to provide availability only to the
`
`Board.
`
`
`Dated: December 23, 2021
`
`Respectfully submitted,
`
`
`
`/ Reza Mirzaie /
`Reza Mirzaie, Reg. No. 69,138
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`
`
`Case IPR2021-01128
`Patent No. 8,432,173
`
`CERTIFICATE OF SERVICE (37 C.F.R. § 42.6(e)(1))
`The undersigned hereby certifies that the above document was served on
`
`December 23, 2021, by filing this document through the Patent Review Processing
`
`System as well as delivering a copy via electronic mail upon the following attorneys
`
`of record for the Petitioner:
`
`Tyler R. Bowen, Reg. No. 60,461
`tbowen@perkinscoie.com
`Heather Martin
`heathermartin@perkinscoie.com
`STMicroelectronics-
`NeodronIPRService@perkinscoie.com
`
`Date: January 3, 2022
`
` /Reza Mirzaie /
`
`RUSS AUGUST & KABAT
`Reza Mirzaie (Reg. No. 69,138)
`12424 Wilshire Blvd., 12th Fl.
`Los Angeles, CA 90025
`
`Attorney for Patent Owner
`(310) 826-7474
`
`3
`
`
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