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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`ASSA ABLOY AB, ASSA ABLOY INC., ASSA ABLOY RESIDENTIAL
`GROUP, INC., AUGUST HOME, INC., HID GLOBAL CORPORATION,
`ASSA ABLOY GLOBAL SOLUTIONS, INC.,
`Petitioner,
`
`v.
`
`CPC PATENT TECHNOLOGIES PTY LTD.,
`Patent Owner.
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`REVISED JOINT MOTION FOR PROTECTIVE ORDER
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`Case IPR2022-01006
`Patent 9,665,705
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`
`I.
`
`INTRODUCTION
`Pursuant to the Board’s email of November 16, 2022, Petitioners ASSA
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`ABLOY AB, ASSA ABLOY Inc., ASSA ABLOY Residential Group, Inc., August
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`Home, Inc., HID Global Corporation, and ASSA ABLOY Global Solutions, Inc.
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`(collectively, “Petitioners”) and Patent Owner CPC Patent Technologies Pty Ltd.
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`(“CPC” or “Patent Owner”) respectfully submit this Revised Joint Motion for
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`Protective Order. The Parties have agreed upon entry of a [Proposed] Stipulated
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`Protective Order (“Stipulated Protective Order”) in this proceeding. The Stipulated
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`Protective Order is attached hereto as Appendix A. A mark-up showing the
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`differences between the Stipulated Protective Order and the PTAB’s default
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`protective order is also provided and attached hereto as Appendix B. Appendices A
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`and B have been revised in accordance with the Board’s instructions in the
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`aforementioned email.
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`II. GOOD CAUSE EXISTS FOR ENTERING THE STIPULATED
`PROTECTIVE ORDER
`A party seeking to protect confidential information may seek entry of a
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`protective order in a proceeding before the Board. See, e.g., Garmin Int’l, Inc. v.
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`Cuozzo Speed Techs, LLC, IPR2012-00001, Paper 34 (PTAB Mar. 14, 2013).
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`Upon a showing of good cause, the Board may enter a protective order to protect
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`from public disclosure such confidential information as disclosed by a party during
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`the course of a proceeding before the Board. See 37 CFR § 42.54.
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`
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`2
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`Patent Owner and Petitioners have agreed to use the Stipulated Protective
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`Order in Appendix A to govern the handling of confidential information in this
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`proceeding. The Stipulated Protective Order corresponds to the default protective
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`order set forth in the Office Patent Trial Practice Guide, but has been amended to
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`1) revise confidential information designations; 2) preclude access by the Parties
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`and limit in-house counsel access to the protected information; and 3) provide for
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`notice provisions if disclosure of the protected information to an independent
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`consultant or expert is sought. See Appendix B (mark-up showing amendments of
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`the Stipulated Protective Order relative to the language in the Board’s default
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`protective order).
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`Amendment 1) is analogous to an outside-counsel-eyes-only designation and
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`is necessary because the information sought to be protected is considered by the
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`designating party to be highly sensitive technical and business trade secret
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`information.
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`Amendment 2) provides minor revisions to the provisions relating to who
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`may access the protected material, including precluding access by the Parties and
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`provisions relating to limiting the number of in-house counsel who have access to
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`the protected information, as well as prior approval of the opposing party of in-
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`house counsel before disclosure. These minor revisions are designed to avoid
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`inadvertent disclosure of each party’s protected information.
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`3
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`Amendment 3) pertains to notice provisions regarding disclosure of
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`protected information to independent consultants or experts. This revision is
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`typical in standard protective orders and ensures there is no conflict of interest.
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`In view of the foregoing, good cause exists to enter the Stipulated Protective
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`Order. Accordingly, Patent Owner and Petitioners respectfully request entry of the
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`Stipulated Protective Order.
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`
`
`By: /Andrew Devkar/
`Dion Bregman
`Andrew Devkar
`James J. Kritsas
`MORGAN, LEWIS & BOCKIUS LLP
`1400 Page Mill Road
`Palo Alto, CA 94304
`Tel.: (650) 843-4000
`Fax.: (650) 843-4001
`HID-IPRs@morganlewis.com
`
`Attorneys for Petitioners
`
`
`Dated: November 17, 2022
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`Respectfully submitted,
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`
`
`
`By: /Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
`Steven M. Coyle
`(admitted pro hac vice)
`Nicholas A. Geiger
`(admitted pro hac vice)
`CANTOR COLBURN LLP
`20 Church Street, 22nd Floor
`Hartford, CT 06103
`Tel.: (860) 286-2929
`Fax.: (860) 286-0115
`aryan@cantorcolburn.com
`scoyle@cantorcolburn.com
`ngeiger@cantorcolburn.com
`
`Attorneys for Patent Owner
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`4
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on this 17th
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`day of November, 2022, service of the foregoing document was made on counsel
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`of record by filing this document through the Patent Trial and Appeal Board’s
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`P-TACTS platform.
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`Dated: November 17, 2022
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`By:
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`/Andrew C. Ryan/
`Andrew C. Ryan
`Reg. No. 43,070
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`5
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`Appendix A
`Appendix A
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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`Case No. IPR2022-01006
`
`Patent No. 9,665,705
`
`________________________________________________________________
`
`
`
`PROTECTIVE ORDER
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`The following Protective Order will govern the filing and treatment of confidential
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
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`information in the proceeding:
`
`Protective Order
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`This protective order governs the treatment and filing of confidential information,
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`including documents and testimony.
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`1. Confidential information shall be clearly marked “CONFIDENTIAL” or
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`“CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY.”
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`2. Access to information marked “CONFIDENTIAL” is limited to the
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`following individuals who have executed the Acknowledgment appended to
`
`this order:
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`(A). Party Representatives. Representatives of record for a party in the
`
`proceeding, excluding in-house counsel of a party, except as stated in
`
`Section 2(C).
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`(B). Experts. Retained experts of a party in the proceeding who further
`
`certify in the Acknowledgement that they are not a competitor to any
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`party, or a consultant for, or employed by, such a competitor with respect
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`to the subject matter of the proceeding.
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`(i). A party desiring to disclose confidential information designated
`
`as CONFIDENTIAL to an independent expert or independent
`
`consultant shall give prior written notice to the producing party
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`
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`accompanied by an executed copy of the Acknowledgment
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`appended to this order for each independent expert or
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`independent consultant to whom such information or material
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`shall be disclosed, who shall have five (5) business days after
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`such notice is given to object in writing with the basis for the
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`objection. The party desiring to disclose the confidential
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`information must also provide the following information for
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`each expert or consultant: (i) name, address, curriculum vitae,
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`current employer, and employment (including consulting)
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`history for the past four (4) years; and (ii) a listing of cases in
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`which the witness has testified as an expert at trial or by
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`deposition within the preceding four (4) years. No confidential
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`information shall be disclosed to such expert(s) or consultant(s)
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`until after the expiration of the foregoing notice period, or until
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`after the resolution of any objection made under this Section. In
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`the event of an objection, the parties shall first informally try to
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`resolve the objection in good faith. In the event the objection
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`cannot be resolved, the objecting party must seek appropriate
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`relief from the Board within ten (10) business days from the
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`date it first received notice (or within such time as agreed, by
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`
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`the parties); otherwise such independent expert or consultant
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`shall be permitted such access. The burden of proving that the
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`proposed independent expert or consultant should not be
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`permitted access to Confidential Material is on the objecting
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`party.
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`(C). In-house counsel. Up to a maximum of three (3) in-house counsel of
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`a party who are identified and approved by the other party before any
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`confidential information is so disclosed.
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`(D). Support Personnel. Administrative assistants, clerical staff, court
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`reporters and other support personnel of the foregoing persons who are
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`reasonably necessary to assist those persons in the proceeding shall not
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`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.
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`(E). The Office. Employees and representatives of the United States
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`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
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`Case No. IPR2022-01006
`Patent No. 9,665,705
`
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`the Office.
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`3. CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY shall mean (a)
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`commercially sensitive marketing, financial, sales, web traffic, research and
`
`development, or technical data or information; (b) commercially sensitive
`
`competitive information, including, without limitation, information obtained
`
`from a non-party pursuant to a current Nondisclosure Agreement; or (c)
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`commercial agreements, license agreements, settlement agreements, or
`
`settlement communications; and for which the disclosure of any such
`
`document is likely to cause harm to the competitive position of the
`
`producing party. Access to information marked “CONFIDENTIAL –
`
`OUTSIDE ATTORNEYS’ EYES ONLY” is limited to the following
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`individuals who have executed the Acknowledgment appended to this order:
`
`(A). Party Representatives. Representatives of record for a party in the
`
`proceeding, excluding in-house counsel of a party.
`
`(B). Experts. Retained experts of a party in the proceeding who further
`
`certify in the Acknowledgement that they are not a competitor to any
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`party, or a consultant for, or employed by, such a competitor with respect
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`to the subject matter of the proceeding that are subject to the same
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`requirements set forth above in Section (2)(B)(i)).
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`
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`(C). Support Personnel. Administrative assistants, clerical staff, court
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`reporters and other support personnel of the foregoing persons who are
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`reasonably necessary to assist those persons in the proceeding shall not
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`be required to sign an Acknowledgement, but shall be informed of the
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`terms and requirements of the Protective Order by the person they are
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`supporting who receives confidential information.
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`(D). The Office. Employees and representatives of the United States
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`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.
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`4. Employees (e.g., corporate officers or in-house counsel), consultants, or
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`other persons performing work for a party, other than those persons identified
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`above in (2)(A)–(E) and (3)(A)-(D), shall not be extended access to confidential
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`information unless there is a prior agreement of the parties or by order of the Board
`
`upon a motion brought by the party seeking to disclose confidential information to
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`that person and after signing the Acknowledgment. The party opposing disclosure
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`
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`to that person shall have the burden of proving that such person should be
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`restricted from access to confidential information.
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`5. Persons receiving confidential information shall use reasonable efforts to
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`maintain the confidentiality of the information, including:
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`(A). Maintaining such information in a secure location to which persons
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`not authorized to receive the information shall not have access;
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`(B). Otherwise using reasonable efforts to maintain the confidentiality of
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`the information, which efforts shall be no less rigorous than those the
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`recipient uses to maintain the confidentiality of information not received
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`from the disclosing party;
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`(C). Ensuring that support personnel of the recipient who have access to
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`the confidential information understand and abide by the obligation to
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`maintain the confidentiality of information received that is designated as
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`confidential; and
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`(D). Limiting the copying of confidential information to a reasonable
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`number of copies needed for conduct of the proceeding and maintaining a
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`record of the locations of such copies.
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`6. Persons receiving confidential information shall use the following
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`procedures to maintain the confidentiality of the information:
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`(A). Documents and Information Filed with the Board.
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`(i). A party may file documents or information with the Board along with
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`a Motion to Seal. The documents must be filed as viewable by the
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`Board and counsel only. The Motion to Seal should provide a non-
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`confidential description of the nature of the confidential information
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`that is under seal, and set forth the reasons why the information is
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`confidential and should not be made available to the public. A party
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`may challenge the confidentiality of the information by opposing the
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`Motion to Seal. The documents or information shall remain under
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`seal unless the Board determines that some or all of it does not
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`qualify for confidential treatment.
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`(ii). Where confidentiality is alleged as to some but not all of the
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`information submitted to the Board, the submitting party shall file
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`confidential and non-confidential versions of its submission, together
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`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
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`public. A party may challenge the confidentiality of the information
`
`by opposing the Motion to Seal. The non-confidential version of the
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`submission shall clearly indicate the locations of information that has
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`been redacted. The confidential version of the submission shall be
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`
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`filed under seal. The redacted information shall remain under seal
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`Case No. IPR2022-01006
`Patent No. 9,665,705
`
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`unless the Board determines that some or all of the redacted
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`information does not qualify for confidential treatment.
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`(B). Documents and Information Exchanged Among the Parties.
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`Documents (including deposition transcripts) and other information
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`designated as confidential that are disclosed to another party during
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`discovery or other proceedings before the Board shall be clearly
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`marked as “CONFIDENTIAL” or “CONFIDENTIAL – OUTSIDE
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`ATTORNEYS’ EYES ONLY” and shall be produced in a manner that
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`maintains its confidentiality.
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`7. Within 60 days after the final disposition of this action, including the
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`exhaustion of all appeals and motions, each party receiving confidential
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`information must return, or certify the destruction of, all copies of the confidential
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`information to the producing party.
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`
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`
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`Case No. IPR2022-01006
`
`Patent No. 9,665,705
`
`________________________________________________________________
`
`
`ACKNOWLEDGMENT FOR ACCESS TO
`PROTECTIVE ORDER MATERIAL
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`
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`
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`I __________________________________________, affirm that I have read the
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
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`Protective Order; that I will abide by its terms; that I will use the confidential
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`information only in connection with this proceeding and for no other purpose; that
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`I will only allow access to support staff who are reasonably necessary to assist me
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`in this proceeding; that prior to any disclosure to such support staff I informed or
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`will inform them of the requirements of the Protective Order; that I am personally
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`responsible for the requirements of the terms of the Protective Order and I agree to
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`submit to the jurisdiction of the Office and the United States District Court for the
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`Eastern District of Virginia for purposes of enforcing the terms of the Protective
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`Order and providing remedies for its breach.
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`
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`Signature: _______________________________
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`Printed Name: ____________________________
`
`Date: _______________
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`
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`
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`Appendix B
`Appendix B
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`Case No. IPR2022-01006
`
`Patent No. 9,665,705
`
`________________________________________________________________
`
`
`
`DEFAULT PROTECTIVE ORDER
`
`
`
`
`
`
`
`The following Default Protective Order will govern the filing and treatment of
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`confidential information in the proceeding:
`
`Default Protective Order
`
`This protective order governs the treatment and filing of confidential information,
`
`including documents and testimony.
`
`1. Confidential information shall be clearly marked “PROTECTIVE ORDER
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`MATERIALCONFIDENTIAL” or “CONFIDENTIAL – OUTSIDE
`
`ATTORNEYS’ EYES ONLY.”
`
`2. Access to confidential information marked “CONFIDENTIAL” is limited to
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`the following individuals who have executed the Acknowledgment
`
`appended to this order:
`
`(A). Parties. Persons who are owners of a patent involved in the
`
`proceeding and other persons who are named parties to the proceeding.
`
`(B).(A). Party Representatives. Representatives of record for a party in
`
`the proceeding, excluding in-house counsel of a party, except as stated in
`
`Section 2(C).
`
`(C).(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.
`
`
`
`(i). A party desiring to disclose confidential information designated
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`as CONFIDENTIAL to an independent expert or independent
`
`consultant shall give prior written notice to the producing party
`
`accompanied by an executed copy of the Acknowledgment
`
`appended to this order for each independent expert or
`
`independent consultant to whom such information or material
`
`shall be disclosed, who shall have five (5) business days after
`
`such notice is given to object in writing with the basis for the
`
`objection. The party desiring to disclose the confidential
`
`information must also provide the following information for
`
`each expert or consultant: (i) name, address, curriculum vitae,
`
`current employer, and employment (including consulting)
`
`history for the past four (4) years; and (ii) a listing of cases in
`
`which the witness has testified as an expert at trial or by
`
`deposition within the preceding four (4) years. No confidential
`
`information shall be disclosed to such expert(s) or consultant(s)
`
`until after the expiration of the foregoing notice period, or until
`
`after the resolution of any objection made under this Section. In
`
`the event of an objection, the parties shall first informally try to
`
`resolve the objection in good faith. In the event the objection
`
`
`
`cannot be resolved, the objecting party must seek appropriate
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`relief from the Board within ten (10) business days from the
`
`date it first received notice (or within such time as agreed, by
`
`the parties); otherwise such independent expert or consultant
`
`shall be permitted such access. The burden of proving that the
`
`proposed independent expert or consultant should not be
`
`permitted access to Confidential Material is on the objecting
`
`party.
`
`(D).(C). In-house counsel. InUp to a maximum of three (3) in-house
`
`counsel of a party who are identified and approved by the other party
`
`before any confidential information is so disclosed.
`
`(E).(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.
`
`(F).(E). 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
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`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.
`
`3. CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY shall mean (a)
`
`commercially sensitive marketing, financial, sales, web traffic, research and
`
`development, or technical data or information; (b) commercially sensitive
`
`competitive information, including, without limitation, information obtained
`
`from a non-party pursuant to a current Nondisclosure Agreement; or (c)
`
`commercial agreements, license agreements, settlement agreements, or
`
`settlement communications; and for which the disclosure of any such
`
`document is likely to cause harm to the competitive position of the
`
`producing party. Access to information marked “CONFIDENTIAL –
`
`OUTSIDE ATTORNEYS’ EYES ONLY” is limited to the following
`
`individuals who have executed the Acknowledgment appended to this order:
`
`(A). Party Representatives. Representatives of record for a party in the
`
`proceeding, excluding in-house counsel of a party.
`
`(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 that are subject to the same
`
`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`requirements set forth above in Section (2)(B)(i)).
`
`(C). 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.
`
`(D). 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.
`
`3.4.
`
`Employees (e.g., corporate officers or in-house counsel), consultants,
`
`or other persons performing work for a party, other than those persons identified
`
`above in (d)(2)(A)–(E) and (3)(A)-(D), shall not be extended access to confidential
`
`information only uponunless there is a prior agreement of the parties or by order of
`
`the Board upon a motion brought by the party seeking to disclose confidential
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`
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`information to that person and after signing the Acknowledgment. The party
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`opposing disclosure to that person shall have the burden of proving that such
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`person should be restricted from access to confidential information.
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`4.5.
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`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;
`
`(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
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`the confidential information understand and abide by the obligation to
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`maintain the confidentiality of information received that is designated as
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`confidential; and
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`(D). Limiting the copying of confidential information to a reasonable
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`number of copies needed for conduct of the proceeding and maintaining a
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`record of the locations of such copies.
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`5.6.
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`Persons receiving confidential information shall use the following
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`procedures to maintain the confidentiality of the information:
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`
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`(A). Documents and Information Filed with the Board.
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`(i). A party may file documents or information with the Board along with
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`a Motion to Seal. The documents must be filed as viewable by the
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`Board and counsel only. 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
`
`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 documents or information shall remain under
`
`seal unless the Board determines that some or all of it 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
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`submission shall clearly indicate the locations of information that has
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`
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`been redacted. The confidential version of the submission shall be
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`Case No. IPR2022-01006
`Patent No. 9,665,705
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`filed under seal. The redacted information shall remain under seal
`
`unless the Board determines that some or all of the redacted
`
`information does not qualify for confidential treatment.
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`(B). Documents and Information Exchanged Among the Parties.
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`Documents (including deposition transcripts) and other information
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`designated as confidential that are disclosed to another party during
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`discovery or other proceedings before the Board shall be clearly
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`marked as “PROTECTIVE ORDER MATERIALCONFIDENTIAL”
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`or “CONFIDENTIAL – OUTSIDE ATTORNEYS’ EYES ONLY”
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`and shall be produced in a manner that maintains its confidentiality.
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`7. Within 60 days after the final disposition of this action, including the
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`exhaustion of all appeals and motions, each party receiving confidential
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`information must return, or certify the destruction of, all copies of the confidential
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`information to the producing party.
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`
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`
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`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`ASSA ABLOY AB, ASSA ABLOY Inc.,
`ASSA ABLOY Residential Group, Inc., August Home, Inc., HID Global
`Corporation, and ASSA ABLOY Global Solutions, Inc.,
`Petitioners,
`
`v.
`
`CPC Patent Technologies PTY LTD.,
`Patent Owner.
`Case No. IPR2022-01006
`
`Patent No. 9,665,705
`
`________________________________________________________________
`
`
`STANDARD ACKNOWLEDGMENT FOR ACCESS TO
`PROTECTIVE ORDER MATERIAL
`
`
`
`
`
`
`
`
`
`
`
`I __________________________________________, affirm that I have read the
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`Case No. IPR2022-01006
`Patent No. 9,665,705
`
`
`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.
`
`
`
`[Signature]: _______________________________
`
`Printed Name: ____________________________
`
`Date: _______________
`
`
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