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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`UNIFIED PATENTS, LLC
`Petitioner
`
`v.
`
`MEMORY WEB, LLC
`Patent Owner
`
`
`
`Case no. IPR2021-01413
`Patent 10,621,228
`
`
`
`
`PETITIONER’S MOTION TO SEAL AND FOR ENTRY OF
`PROTECTIVE ORDER
`
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`Petitioner Unified Patents, LLC (“Petitioner”) hereby moves for entry of the
`
`Protective Order appended below as Appendix A, and further moves to seal Exhibits
`
`1023-1025 and 1029.
`
`
`
`Petitioner has conferred with Patent Owner through counsel via email. Patent
`
`Owner does not oppose entry of the Protective Order or the motion to seal. Lead
`
`counsel for Patent Owner has executed the Standard Acknowledgment for Access to
`
`Protective Order Material, included with Appendix A of this motion.
`
`I. MOTION TO SEAL
`In an inter partes review, it is the default rule that all filings are publicly
`
`available. 35 U.S.C. § 326(a)(1) and 37 C.F.R. § 42.14. Where a paper contains
`
`confidential information, a petitioner may file “a motion to seal with a proposed
`
`protective order as to the confidential information.” 37 C.F.R. § 42.55; see also 35
`
`U.S.C. § 326(a)(1). A motion to seal and to enter a protective order will only be
`
`granted if the movant demonstrates a showing of “good cause.” 37 C.F.R.
`
`§ 42.54(a). The Board has established a four-pronged test that must be met for a
`
`motion to seal to be granted:
`
`a movant to seal must demonstrate adequately that (1) the information
`sought to be sealed is truly confidential, (2) a concrete harm would
`result upon public disclosure, (3) there exists a genuine need to rely in
`the trial on the specific information sought to be sealed, and (4), on
`balance, an interest in maintaining confidentiality outweighs the strong
`
`1
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`
`public interest in having an open record.
`
`Argentum Pharm. LLC v. Alcon Research, Ltd., IPR2017-01053, Paper 27 at 4
`
`(PTAB Jan. 19, 2018) (informative) (citing to inter alia 37 C.F.R. § 42.54(a)).
`
`
`
`Pursuant to the Protective Order, and responsive to Patent Owner’s
`
`Preliminary Response, Petitioner produced certain discovery to Patent Owner
`
`relating to Unified’s members and business operations (EXS1023-1025, EX1029).
`
`Some of this material is in support of the Second Declaration of Kevin Jakel
`
`(EX1023). This Motion to Seal satisfies the four-pronged test in Argentum.
`
`First,
`
`these Documents contain non-public proprietary
`
`information
`
`(“Information”)— confidential member agreements and information regarding
`
`Unified’s business operations—that Petitioner maintains as confidential trade
`
`secrets. This Information includes confidential, sensitive commercial information,
`
`including closely held information related to Unified’s core business. Unified guards
`
`such information closely to protect its members as well as its own business. Unified
`
`has not made, and does not intend to make, this information publicly available and
`
`such information is subject to confidentiality obligations to third parties not involved
`
`in this proceeding.
`
`
`
`Second, several potential harms would occur if this highly confidential
`
`Information were to be disclosed. For example, disclosure of this Information to the
`
`public would expose Unified’s business model and confidential business activities.
`
`2
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`Additionally, Unified has a contractual obligation with third parties not involved in
`
`this proceeding to maintain the confidentiality of this highly confidential business
`
`Information. Without an assurance that this highly confidential business
`
`Information will be protected, Unified’s members wishing to remain confidential
`
`may be adversely affected. Disclosure of this Information to the public will not only
`
`harm Unified, as discussed above, but would also harm third parties not involved in
`
`this proceeding. Further, the public interest will not be harmed by sealing of the
`
`confidential business Information.
`
`
`
`Third, Patent Owner asserts that certain entities are RPI to this proceeding in
`
`its Preliminary Response. See Paper 8, 22-28. Petitioner disputes these assertions.
`
`This Information will be relied on in this trial to resolve this dispute.
`
`
`
`Fourth, on balance, the interest in maintaining confidentiality outweighs the
`
`public interest in having an entirely open record and the Documents should be
`
`sealed. Petitioner respectfully requests that the Board grant this motion to seal.
`
`II. GOOD CAUSE EXISTS FOR SEALING EXHIBITS 1023-1025 and
`1029
`In deciding whether to seal documents, the Board must find “good cause,” and
`
`must “strike a balance between the public’s interest in maintaining a complete and
`
`understandable file history and the parties’ interest in protecting truly sensitive
`
`information.” Garmin v. Cuozzo, IPR2012-00001, Paper 36 (April 5, 2013).
`
`3
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`All of the documents contain information that Petitioner has identified as
`
`confidential business information. Exhibit 1023 is the Supplemental Declaration of
`
`Kevin Jakel and has been marked “HIGHLY CONFIDENTIAL – ATTORNEY’S
`
`EYES ONLY” under the Protective Order in this case. This declaration includes
`
`sensitive business information which Petitioner asserts has not been published or
`
`otherwise been made public. A public version of Exhibit 1023, from which the
`
`confidential information has been redacted, is being filed concurrently as Exhibit
`
`1022.
`
`Exhibits 1024 and 1025 are Unified membership agreements and have been
`
`marked “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY” under the
`
`Protective Order in this case. These documents contain sensitive business
`
`information which Petitioner asserts has not been published or otherwise been made
`
`public. Due to the nature of Exhibits 1024 and 1025, Petitioner cannot meaningfully
`
`provide redacted versions of these documents, and requests that they remain sealed
`
`in their entirety.
`
`Exhibit 1029 is an email list of Unified members who were sent the News
`
`Update of Exhibit 1028 and has been marked “HIGHLY CONFIDENTIAL –
`
`ATTORNEY’S EYES ONLY” under the Protective Order in this case. This
`
`document contains sensitive business information which Petitioner asserts has not
`
`been published or otherwise been made public. Due to the nature of Exhibit 1029,
`
`4
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`Petitioner cannot meaningfully provide redacted versions of this document, and
`
`requests that it remain sealed in its entirety.
`
`Here, the balance overwhelmingly favors protecting Unified’s highly
`
`confidential information. The information Unified seeks to protect has nothing to do
`
`with patentability, the scope of U.S. Patent No. 10,621,228 (the “’228 patent”), or
`
`any matter generally impacting the public interest in evaluating the ’228 patent.
`
`Rather, the limited materials sought to be protected involve Unified’s status as the
`
`real party-in-interest. The material relates to certain contracts and business dealings
`
`between Unified and non-parties to this proceeding. That material is not known to
`
`the public.
`
`The public interest is well-served in keeping the business information
`
`included within the redacted portions of Exhibits 1023-1025 and 1029 confidential.
`
`This information was provided with the expectation that it would remain
`
`confidential. The Board should seal this information so that information can be
`
`exchanged in trial proceedings without the fear of incidental public exposure of
`
`confidential business information.
`
`The redacted portions of Exhibits 1023-1025 and 1029 relate to Unified’s core
`
`business and the business dealings between Unified and at least some of its members.
`
`The redacted portions of Exhibits 1023-1025 and 1029 contain highly confidential
`
`and extremely sensitive commercial information related to Unified’s core business.
`
`5
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`Unified guards such information closely as core business and contractual
`
`information, to protect its members as well as its own business. Unified has not
`
`made, and does not intend to make, this information publicly available.
`
`Unified’s business strategies and dealings with its members constitute highly
`
`confidential business information, as well as trade secrets. Exhibits 1023-1025 and
`
`1029 contain information about how Unified runs its business and its contractual
`
`relationship with its members. Several potential harms would occur if this highly
`
`confidential business information were to be disclosed. For example, disclosure of
`
`this information to the public would provide Unified’s competitors and would-be
`
`business rivals with a roadmap of how to replicate Unified’s unique, valuable
`
`business model. It would reveal contractual business information between two
`
`parties produced voluntarily under a joint protective order. Thus, the public interest
`
`will not be harmed by the sealing of the confidential business information.
`
`III. MOTION FOR PROTECTIVE ORDER
`The agreed-upon Protective Order differs from the Board’s Default Protective
`
`Order in Appendix B of the Patent Trial and Appeal Consolidated Trial Practice
`
`Guide, November 2019 (“TPG”) in that the default Protective Order has been
`
`modified to include the “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES
`
`ONLY” designation. Additionally, the Protective Order identifies the persons to
`
`which access to confidential information is limited and clarifies the treatment of
`
`6
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`confidential materials unless the Board determines that information does not qualify
`
`for confidential treatment. These changes are designed to limit access to certain
`
`materials by each party’s representatives and in-house counsel with competitive
`
`decision-making authority. The Protective Order, which has been acknowledged by
`
`lead counsel for Patent Owner, is attached as Appendix A.
`
`
`
`These additional limitations to the default protective order are necessary. In
`
`particular, Exhibits 1023-1025 and 1029, contain highly confidential, competitively-
`
`sensitive information relating to Unified’s members and business operations.
`
`Additionally, it may be necessary to produce or file additional highly confidential,
`
`competitively-sensitive information in this case.
`
`Counsel for Patent Owner has executed the Protective Order and confidential
`
`material is being served pursuant thereto.
`
`
`
`Accordingly, Petitioner moves for entry of the attached protective order.
`
`IV. NON-CONFIDENTIAL VERSION SUBMITTED
`
`As required by the TPG, the Default Protective Order, and the agreed-upon
`
`Protective Order, a non-confidential redacted version of Exhibit 1023 (Supplemental
`
`Declaration of Kevin Jakel) has been filed as Exhibit 1022. The redactions are
`
`minimal and limited in nature and scope to the confidential data. Petitioner submits
`
`that Exhibits 1024 and 1025, which are agreements with members, and Exhibit 1029,
`
`which is an email list of Unified members who were sent the News Update of Exhibit
`
`7
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`1028, are highly confidential in their entirety.
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`
`V. REQUEST FOR CONFERENCE CALL WITH THE BOARD
`Should the Board not be inclined to grant the present Motion to Seal and Entry
`
`of Protective Order, the parties hereby request a conference call with the Board to
`
`discuss any concerns prior to the Board issuing a decision on the Motion.
`
`VI. CONCLUSION
`The undersigned counsel for Petitioner certifies the information sought to be
`
`sealed by this Motion to Seal has not been published or otherwise made public.
`
`Dated: December 30, 2021
`
`
`
`
`Respectfully submitted,
`
`/Ellyar Y. Barazesh/
`Ellyar Y. Barazesh
`Reg. No. 74,096
`
`COUNSEL FOR PETITIONER
`
`
`
`
`
`
`8
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`
`CERTIFICATION OF SERVICE ON PATENT OWNER
`The undersigned hereby certifies that a copy of the foregoing MOTION TO
`
`SEAL AND FOR ENTRY OF PROTECTIVE ORDER was served on December
`
`30, 2021, via electronic mail, as agreed to by counsel, upon the following counsel
`
`for Patent Owner:
`
`
`
`Jennifer Hayes
`Nixon Peabody LLP
`300 South Grand Avenue, Suite 4100
`Los Angeles, CA 90071-3151
`jenhayes@nixonpeabody.com
`
`George Dandalides
`Nixon Peabody LLP
`70 West Madison, Suite 5200
`Chicago, IL 60602-4224
`gdandalides@nixonpeabody.com
`
`
`
`
`
`
`
`
`/Ashley Cheung/
`Ashley Cheung
`Paralegal
`Unified Patents, LLC
`
`
`
`Dated: December 30, 2021
`
`
`
`
`
`
`
`
`
`
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413, U.S. 10,621,228
`Motion to Seal and for Entry of Protective Order
`
`
`
`
`
`
`
`
`
`
`APPENDIX
`
`
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`UNIFIED PATENTS, LLC
`Petitioner
`
`v.
`
`MEMORY WEB, LLC
`Patent Owner
`
`
`
`Case no. IPR2021-01413
`Patent 10,621,228
`
`
`
`PROTECTIVE ORDER
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`The following Protective Order will govern the filing and treatment of confidential
`
`information in the proceeding:
`
`Protective Order
`
`This protective order governs the treatment and filing of confidential
`
`information, including documents and testimony.
`
`1. Confidential information shall be clearly marked “CONFIDENTIAL –
`
`PROTECTIVE ORDER MATERIAL” or “HIGHLY CONFIDENTIAL –
`
`ATTORNEYS’ EYES ONLY.”
`
`2. Access to confidential information marked “HIGHLY CONFIDENTIAL –
`
`ATTORNEYS’ EYES ONLY” is limited to the following individuals who have
`
`executed the acknowledgement appended to this order:
`
`(A) Outside counsel. Outside counsel of record for a party in the proceeding,
`
`including employees of outside counsel of record’s law firm(s) to whom it is
`
`reasonably necessary to disclose this information to assist outside counsel of
`
`record in connection with this proceeding, including members of their firms,
`
`associate attorneys, paralegal, clerical, and other regular employees of such
`
`counsel. All in-house counsel and other representatives of the parties (other
`
`than outside counsel of record) shall not be allowed to view HIGHLY
`
`CONFIDENTIAL – ATTORNEYS’ EYES ONLY Information.
`
`1
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`(B) Experts. Retained experts of a party in the proceeding who further certify
`
`in the Acknowledgement that they are not a competitor to any party, or a
`
`consultant for, or employed by, such a competitor with respect to the subject
`
`matter of the proceeding.
`
`(C) The Office. Employees and representatives of the United States Patent and
`
`Trademark Office who have a need for access to the confidential information
`
`shall have such access without the requirement to sign an Acknowledgement.
`
`Such employees and representatives shall include the Director, members of
`
`the Board and their clerical staff, other support personnel, court reporters, and
`
`other persons acting on behalf of the Office.
`
`(D) Support Personnel. Administrative assistants, clerical staff, court reporters
`
`and other support personnel of the foregoing persons who are reasonably
`
`necessary to assist those persons in the proceeding shall not be required to
`
`sign an Acknowledgement, but shall be informed of the terms and
`
`requirements of the Protective Order by the person they are supporting who
`
`receives confidential information.
`
`3. Access
`
`to confidential
`
`information marked “CONFIDENTIAL –
`
`PROTECTIVE ORDER MATERIAL” is limited to the following individuals who
`
`have executed the acknowledgment appended to this order:
`
`2
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`(A) Above Personnel. Those persons or entities identified in paragraph 2 of
`
`this Protective Order under the conditions set forth in that paragraph.
`
`(B) Parties. Persons who are owners of a patent involved in the proceeding
`
`and other persons who are named parties to the proceeding.
`
`(C) In-house counsel. In-house counsel of a party.
`
`4. Employees (e.g., corporate officers), consultants, or other persons
`
`performing work for a party, other than in-house counsel and in-house counsel’s
`
`support staff, who sign the Acknowledgement shall be extended access to
`
`confidential information only upon agreement of the parties or by order of the Board
`
`upon a motion brought by the party seeking to disclose confidential information to
`
`that person. The party opposing disclosure to that person shall have the burden of
`
`proving that such person should be restricted from access to confidential
`
`information.
`
`5. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons not
`
`authorized to receive the information shall not have access;
`
`3
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality of the
`
`information, which efforts shall be no less rigorous than those the recipient
`
`uses to maintain the confidentiality of information not received from the
`
`disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access to the
`
`confidential information understand and abide by the obligation to maintain
`
`the confidentiality of information received that is designated as confidential;
`
`and
`
`(D) Limiting the copying of confidential information to a reasonable number
`
`of copies needed for conduct of the proceeding and maintaining a record of
`
`the locations of such copies.
`
`6. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board along
`
`with a Motion to Seal. The Motion to Seal should provide a non-
`
`confidential description of the nature of the confidential information
`
`that is under seal, and set forth the reasons why the information is
`
`4
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`confidential and should not be made available to the public. A party
`
`may challenge the confidentiality of the information by opposing the
`
`Motion to Seal. The submission shall be treated as confidential and
`
`remain under seal, unless the Board determines that the documents or
`
`information do not to qualify for confidential treatment. The
`
`information shall remain under seal unless the Board determines that
`
`some or all of the information does not qualify for confidential
`
`treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. A party
`
`may challenge the confidentiality of the information by opposing the
`
`Motion to Seal. The non-confidential version of the submission shall
`
`clearly indicate the locations of information that has been redacted. The
`
`confidential version of the submission shall be filed under seal. The
`
`redacted information shall remain under seal unless the Board
`
`5
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`determines that some or all of the redacted information does not qualify
`
`for confidential treatment.
`
`(B) Documents and Information Exchanged Among the Parties. Documents
`
`(including deposition transcripts) and other information designated as
`
`confidential that are disclosed to another party during discovery or other
`
`proceedings before the Board shall be clearly marked as “CONFIDENTIAL
`
`– PROTECTIVE ORDER MATERIAL” or “HIGHLY CONFIDENTIAL –
`
`ATTORNEYS’ EYES ONLY” and shall be produced in a manner that
`
`maintains its confidentiality.
`
`7. Within 60 days after the final disposition of this action, including the
`
`exhaustion of all appeals and motions, each party receiving confidential information
`
`must return, or certify the destruction of, all copies of the confidential information
`
`to the producing party.
`
`
`
`6
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
`
`IPR2021-01413
`U.S. 10,621,228
`
`
`EXHIBIT A
`
`UNIFIED PATENTS, LLC v. MEMORY WEB, LLC
`Case No. IPR2021-01413
`U.S. Patent 10,621,228
`
`Standard Acknowledgment for Access to Protective Order Material
`
`I __________________________________________, affirm that I have read
`
`the Protective Order; that I will abide by its terms; that I will use the confidential
`
`information only in connection with this proceeding and for no other purpose; that I
`
`will only allow access to support staff who are reasonably necessary to assist me in
`
`this proceeding; that prior to any disclosure to such support staff I informed or will
`
`inform them of the requirements of the Protective Order; that I am personally
`
`responsible for the requirements of the terms of the Protective Order and I agree to
`
`submit to the jurisdiction of the Office and the United States District Court for the
`
`Eastern District of Virginia for purposes of enforcing the terms of the Protective
`
`Order and providing remedies for its breach.
`
`Executed on
`
`
`
`
`
`
`
`
`
`
`
`, 20__.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1
`
`MemoryWeb Ex. 2028
`Samsung Electronics Co., LTD v. MemoryWeb, LLC - IPR 2022-00222
`
`
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