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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`AMAZON.COM, INC.,
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`Petitioner,
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`v.
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`JAWBONE INNOVATIONS LLC,
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`Patent Owner.
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`Case IPR2023-00251
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`U.S. Patent No. 11,122,357
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`JOINT MOTION TO FILE AGREEMENTS AS BUSINESS
`CONFIDENTIAL INFORMATION PURSUANT TO 35 U.S.C. § 317
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`LIST OF EXHIBITS
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`Exhibit No. Description of Document
`2001
`Confidential Settlement Agreement
`2002
`Confidential Release
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`i
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`Patent Owner Jawbone Innovations, LLC (“Patent Owner”) is filing,
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`concurrently with the Parties’ Joint Motion to Terminate Proceedings, a true copy of
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`the confidential settlement agreements resolving the parties’ disputes and agreeing
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`to terminate this proceeding and the parties’ related district court proceeding. The
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`confidential agreements include a confidential settlement agreement (Exhibit 2001)
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`and a related release agreement between the parties (Exhibit 2002).
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`The parties jointly request, pursuant to 35 U.S.C. § 317(b) and 37 C.F.R.
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`§ 42.74(c), and the July 26, 2023, authorization of the Board, that the agreement and
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`release be treated as business confidential information and be kept separate from the
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`public files of the involved patent (U.S. Patent No. 11,122,357) and inter partes
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`review proceeding. The agreement and release describe the confidential terms
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`resolving the parties’ dispute, which constitutes confidential information under the
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`Board’s rules. See 37 C.F.R. § 42.54. The parties hereby certify that, to the best of
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`their knowledge, the documents sought to be protected have not been made publicly
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`available.
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`Date: July 29, 2023
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`Respectfully submitted,
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`/Colin B. Heideman/
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`Colin B. Heideman
`Reg. No. 61,513
`KNOBBE MARTENS OLSON &
`BEAR, LLP
`925 4th Ave., Ste. 2500
`Seattle, WA 98104
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`/Peter Lambrianakos/
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`Peter Lambrianakos
`Reg. No. 58,279
`FABRICANT LLP
`411 Theodore Fremd Road, Suite 206
`South Rye, New York 10580
`Tel. 212-257-5797
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`1
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`Tel: 206-405-2000
`Fax: 206-405-2001
`2cbh@knobbe.com
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`Counsel for Petitioner
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`Fax. 212-257-5796
`plambrianakos@fabricantllp.com
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`Counsel for Patent Owner
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`2
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