`
`_________________________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
` NETNUT LTD.,
`
`Petitioner
`
`v.
`
`BRIGHT DATA LTD.,
`
`Patent Owner
`
`_________________________
`
`Case IPR2021-01492
`
`Patent No. 10,257,319
`
`_________________________
`
`
`
`
`
`JOINT REQUEST TO FILE SETTLEMENT AGREEMENT AS BUSINESS
`CONFIDENTIAL INFORMATION AND BE KEPT SEPARATE FROM
`THE PATENT FILES UNDER 35 U.S.C. § 317 AND 37 C.F.R. § 42.741
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`1 This Joint Request was authorized by the Board in an e-mail dated May 24, 2022.
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioner NetNut
`
`Ltd. and Patent Owner Bright Data Ltd. (together, the “Parties”) jointly request that
`
`Exhibit 2019, a true copy of the written Settlement Agreement between the Parties,
`
`which is referenced in the concurrently filed Joint Motion to Terminate due to
`
`Settlement, be treated as business confidential information and be kept separate from
`
`the patent files. Exhibit 2019 has been filed for access by the “Parties and Board
`
`Only.”
`
`The Parties consider the Settlement Agreement to contain highly sensitive
`
`business confidential information that would substantially harm their business
`
`interests if publicly disclosed. The terms of the Settlement Agreement require the
`
`Parties to treat the Settlement Agreement as confidential information and limit the
`
`Parties’ ability to share the Settlement Agreement or disclose its contents with third
`
`parties. Moreover, the Settlement Agreement does not contain any information
`
`material to patentability.
`
`As such, the Parties respectfully request that the Settlement Agreement be
`
`treated as confidential business information and kept separate from the patent files
`
`pursuant to 35 U.S.C § 317(b) and 37 C.F.R. § 42.74(c).
`
`
`
`
`
`
`
`2
`
`
`
`IPR2021-01492 of Patent No. 10,257,319
`
`
`
`Respectfully submitted on May 24, 2022,
`
`
`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`RuyakCherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
`
`
`By: /s/ Ronald Abramson (with
`permission)
`Ronald Abramson
`Reg. No. 34,762
`
`Liston Abramson LLP
`405 Lexington Avenue, 46 FL
`New York, N.Y. 10174
`(212) 822-0163
`
`ATTORNEY FOR PETITIONER,
`NETNUT LTD.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies JOINT
`
`IPR2021-01492 of Patent No. 10,257,319
`
`REQUEST TO FILE SETTLEMENT AGREEMENT AS BUSINESS
`
`CONFIDENTIAL INFORMATION AND BE KEPT SEPARATE FROM THE
`
`PATENT FILES UNDER 35 U.S.C. § 317 AND 37 C.F.R. § 42.74 was served on
`
`the undersigned date via email, as authorized by Petitioner, at the following email
`
`addresses:
`
`ron.abramson@listonabramson.com
`
`ari.jaffess@listonabramson.com
`
`michael.lewis@listonabramson.com
`
`
`
`
`
`
`
`
`Date: May 24, 2022
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`By: /s/ Thomas M. Dunham
`Thomas M. Dunham
`Reg. No. 39,965
`
`RuyakCherian LLP
`1901 L Street NW, Suite 700
`Washington, D.C. 20036
`(202) 838-1567
`
`ATTORNEY FOR PATENT OWNER,
`BRIGHT DATA LTD.
`
`4
`
`
`
`
`
`
`
`
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