`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`MERCEDES-BENZ USA, LLC, and FORD MOTOR COMPANY,1
`Petitioners,
`
`v.
`
`NEO WIRELESS, LLC,
`Patent Owner.
`
`
`IPR2022-01539
`Patent 10,965,512 B2
`
`
`JOINT MOTION TO KEEP CONFIDENTIAL AND SEPARATE
`PURSUANT TO 35 U.S.C. § 317 AND 37 C.F.R. § 42.74
`
`
`
`
`
`1 Mercedes-Benz USA, LLC filed a motion for joinder and a petition in IPR2023-
`00079, and Ford Motor Company filed its own motion for joinder and petition in
`IPR2023-00764. Both motions were granted, and, therefore, Mercedes-Benz USA,
`LLC and Ford Motor Company have been joined as petitioners in this proceeding.
`
`1
`
`
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), and the Board’s
`
`email authorization dated July 28, 2023, Petitioner Mercedes-Benz USA, LLC
`
`(“Mercedes”) and Patent Owner Neo Wireless LLC (“Neo”) (collectively, the
`
`“Parties”) jointly request that Exhibit 2100—the Patent License and Settlement
`
`Agreement—filed today with the Parties’ Joint Motion to Terminate be treated as
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`business confidential information. The Parties further request that Exhibit 2100 be
`
`kept separate from the file of this proceeding and the involved patent, and that it be
`
`made available only to Federal Government agencies on written request, or to
`
`persons showing good cause on written request. Good cause exists to treat the
`
`documents as business confidential, because the documents contain confidential
`
`business information regarding the terms of the Parties’ settlement.
`
`The parties to this Motion, i.e., Mercedes and Neo, jointly request 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 settlement agreement, that any such
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`written request be served upon Mercedes and Neo on the day the written request is
`
`provided to the Board.
`
`
`
`
`
`2
`
`
`
`Dated: August 2, 2023
`
`Respectfully submitted,
`
`
`/s/ Kenneth J. Weatherwax
`Kenneth J. Weatherwax, Reg. No. 54,528
`Lowenstein & Weatherwax LLP
`
`Counsel for Patent Owner Neo Wireless, LLC
`
`
`/s/ Celine J. Crowson
`Celine Jimenez Crowson (Reg. No. 40,357)
`Joseph J. Raffetto (Reg. No. 66,218)
`Scott Hughes (Reg. 68,385)
`Helen Y. Trac (Reg. No. 62,250)
`HOGAN LOVELLS US LLP
`555 13th Street N.W.
`Washington, D.C. 20004
`Telephone: 202.637.5600
`Facsimile: 202.637.5910
`
`Counsel for Petitioner
`Mercedes-Benz USA, LLC
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the following document was served
`via electronic service, by consent between the parties:
`
`JOINT MOTION TO KEEP CONFIDENTIAL AND SEPARATE
`
`PURSUANT TO 35 U.S.C. § 317 AND 37 C.F.R. § 42.74
`
`The names and address of the parties being served are as follows:
`
`Celine J. Crowson
`Joseph J. Raffeto
`
`Scott Hughes
`
`Helen Y. Trac
`
`Ryan C. Richardson
`Michael D. Specht
`Daniel E. Yonan
`
`David Haars
`
`
`
`
`
`
`celine.crowson@hoganlovells.com
`joseph.raffeto@hoganlovells.com
`scott.hughes@hoganlovells.com
`helen.trac@hoganlovells.com
`rrichardson-PTAB@sternkessler.com
`mspecht-PTAB@sternkessler.com
`dyonan-PTAB@sternkessler.com
`dhaars-PTAB@sternkessler.com
`PTAB@sternkessler.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The following document containing confidential business information of the
`
`parties to the Joint Motion was filed Board And Filing Party Only. Accordingly,
`the undersigned certifies that the following document was served via electronic
`service, by consent between the parties, only on counsel of record for those parties:
`
`
`EXHIBIT 2100
`
`
`
`
`
`
`
`
`The names and address of the parties being served are as follows:
`
`
`
`
`
`Celine J. Crowson
`Joseph J. Raffeto
`
`Scott Hughes
`
`Helen Y. Trac
`
`
`
`celine.crowson@hoganlovells.com
`joseph.raffeto@hoganlovells.com
`scott.hughes@hoganlovells.com
`helen.trac@hoganlovells.com
`
`Respectfully submitted,
`
` / William Katz /
`
`Date: August 2, 2023
`
`
`
`
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