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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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`APPLE INC.,
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`Petitioner,
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`v.
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`TRAXCELL TECHNOLOGIES, LLC,
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`Patent Owner
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`IPR2022-00073
`U.S. Patent No. 10,820,147
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`JOINT REQUEST THAT THE SETTLEMENT AGREEMENT BE
`TREATED AS BUSINESS CONFIDENTIAL INFORMATION AND BE
`KEPT SEPARATE UNDER 35 U.S.C. § 317(b)
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`IPR2022-00073
`Joint Request re Confidential Information
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`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioner Apple
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`Inc. (“Petitioner”) and Patent Owner Traxcell Technologies LLC (“Patent Owner”)
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`hereby jointly request that a true copy of their settlement agreement, filed
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`concurrently herewith as Exhibit 1021 be treated as business confidential
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`information and be kept separate from the file for this inter partes review (“IPR”)
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`proceeding. Concurrently with the filing of this Request, Petitioner and Patent
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`Owner are filing a Joint Motion to Dismiss the Petition for IPR due to the
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`settlement between the parties.
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`The parties consider the settlement agreement to contain highly sensitive
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`business confidential information that would substantially harm their business
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`interests if publicly disclosed. As such, the parties hereby jointly request that the
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`settlement agreement be kept as a separate paper to be made available only under
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`the provisions of 35 U.S.C § 317(b) and 37 C.F.R. § 42.74(c). The settlement
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`agreement has been filed for access by the “Parties and Board Only.” The parties
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`further jointly request that the Board order that in the event a person or entity
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`makes a written request, as stated in 37 C.F.R. § 42.74(c)(1)-(2), for access to the
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`settlement agreement, that any such written request be served upon the parties on
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`the day the written request is provided to the Board.
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`IPR2022-00073
`Joint Request re Confidential Information
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`Respectfully submitted,
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`/David W. OBrien/
`David W. O’Brien
`Lead Counsel for Petitioner
`Registration No. 40,107
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`William P. Ramey, III
`Lead Counsel for Patent Owner
`Registration No. 44,295
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`Date: March 24, 2022
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