`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`_________________
`
`ONEPLUS TECHNOLOGY (SHENZHEN) CO., LTD,
`
`Petitioner
`
`
`v.
`
`
`BELL NORTHERN RESEARCH, LLC,
`
`Patent Owner
`
`_________________
`
`Case IPR2022-00048
`
`U.S. Patent No. 8,416,862
`_________________
`
`
`UNOPPOSED REQUEST THAT THE SETTLEMENT AGREEMENT BE
`TREATED AS BUSINESS CONFIDENTIAL INFORMATION AND
`BE KEPT SEPARATE UNDER 35 U.S.C. § 317(b)
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`US Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Patent Owner Bell
`
`IPR2022-00048
`U.S. Patent No. 8,416,862
`
`
`Northern Research, LLC (“BNR” or “Patent Owner”) hereby requests that the true
`
`copy of the BNR Agreement between BNR and the third-party (Ex. 2001) be
`
`treated as business confidential information and be kept separate from the file of
`
`the involved patent. Petitioner OnePlus Technology (Shenzhen) Co., Ltd.
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`(“OnePlus” or “Petitioner,” together with OnePlus the “Parties”) does not oppose
`
`the content of this Request. Concurrently with the filing of this Request, BNR is
`
`filing a Response to Petitioner’s Unopposed Motion to Terminate Inter Pates
`
`Review due to the settlement between the Parties.
`
`BNR considers the BNR Agreement to contain highly sensitive business
`
`confidential information that would substantially harm the Parties’ business
`
`interests if publicly disclosed. As such, BNR requests that the BNR Agreement be
`
`kept as a separate paper to be made available only under the provisions of 35
`
`U.S.C § 317(b) and 37 C.F.R. § 42.74(c). The BNR Agreement has been filed for
`
`access “Available only to board.” BNR further requests that the Board order that in
`
`the event a person or entity makes a written request, as stated in 37 C.F.R.
`
`§ 42.74(c)(1)-(2), for access to the BNR Agreement, that any such written request
`
`be served upon BNR on the day the written request is provided to the Board and
`
`that BNR be provided an opportunity to respond to the request.
`
`
`
`1
`
`
`
`Date: January 21, 2022
`
`
`
`
`IPR2022-00048
`U.S. Patent No. 8,416,862
`
`
`Respectfully Submitted,
`
`/s/ Timothy Devlin
`Timothy Devlin (Reg. No. 41,706)
`DEVLIN LAW FIRM LLC
`1526 Gilpin Avenue
`Wilmington, DE 19806
`T: 302-449-9010
`TD-PTAB@devlinlawfirm.com
`
`Attorneys for Patent Owner
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 21,
`
`IPR2022-00048
`U.S. Patent No. 8,416,862
`
`
`2022, the foregoing document is being served via electronic mail upon the
`
`following counsel of record for Patent Owner:
`
`LEAD COUNSEL
`Charles M. McMahon (Reg. 44,926)
`cmcmahon@mwe.com
`
`McDermott Will & Emery
`444 West Lake Street, Suite 4000
`Chicago, IL 60606-0029
`Phone: (312) 984-7641
`Fax: (312) 984-7700
`
`BACKUP COUNSEL
`Thomas M. DaMario (Reg. 77,142)
`tdamario@mwe.com
`
`McDermott Will & Emery
`444 West Lake Street, Suite 4000
`Chicago, IL 60606-0029
`Phone: (312) 984-7641
`Fax: (312) 984-7700
`
`Additional email for service: OnePlusService@mwe.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/Timothy Devlin
` Timothy Devlin
`
`
`
`
`
`
`
`3
`
`
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