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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________
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`ROKU, INC.,
`Petitioner
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`v.
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`MEDIA CHAIN, LLC,
`Patent Owner
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`___________________
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`Case IPR2022-00394
`U.S. Patent No. 10,885,154
`___________________
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`PETITIONER’S UNOPPOSED REQUEST TO FILE SETTLEMENT
`AGREEMENT AS BUSINESS CONFIDENTIAL INFORMATION
`PURSUANT TO 35 U.S.C. § 317(b)
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Case IPR2022-00394
`U.S. Patent No. 10,885,154
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioner Roku,
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`Inc. (“Petitioner”), hereby requests that a true copy of the confidential settlement
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`agreement between Petitioner and Patent Owner Media Chain, LLC (“Patent
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`Owner”), filed concurrently herewith as Exhibit 1100, be treated as business
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`confidential information and be kept separate from the file of this inter partes
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`review (IPR) proceeding. The Board authorized Petitioner to file this request in an
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`email of May 16, 2022. Concurrently with the filing of this request, Petitioner is
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`filing an Unopposed Motion to Dismiss this IPR pursuant to the confidential
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`settlement agreement between the parties.
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`Petitioner considers the settlement agreement to contain highly sensitive
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`business confidential information that would substantially harm its business
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`interests if publicly disclosed. As such, Petitioner hereby requests 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 “Board and Parties Only.” Petitioner
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`further requests that the Board order that in the event a person or entity makes a
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`written request for access to the settlement agreement, as stated in 37 C.F.R. §
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`42.74(c)(1)-(2), any such written request be served upon Petitioner and Patent
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`Owner on the day the written request is provided to the Board.
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`- 1 -
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`Case IPR2022-00394
`U.S. Patent No. 10,885,154
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Lestin L. Kenton/
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`Lestin L. Kenton (Reg. No. 72,314)
`Attorney for Petitioner Roku, Inc.
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`Date: June 1, 2022
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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`- 2 -
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`Case IPR2022-00394
`U.S. Patent No. 10,885,154
`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that true and correct copies of the
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`foregoing PETITIONER’S UNOPPOSED REQUEST TO FILE
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`SETTLEMENT AGREEMENT AS BUSINESS CONFIDENTIAL
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`INFORMATION PURSUANT TO 35 U.S.C. § 317(b) and EXHIBIT 1100
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`(Confidential) were electronically served in their entireties on June 1, 2022, on the
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`following party via email:
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`Christopher A. Estes chris@mediachainllc.com
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`Date: June 1, 2022
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`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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` 18417008_1.DOCX
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Lestin L. Kenton/
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`Lestin L. Kenton (Reg. No. 72,314)
`Attorney for Petitioner Roku, Inc.
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