`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`MYLAN PHARMACEUTICALS INC., DR. REDDY’S LABORATORIES, INC.,
`
`and DR. REDDY’S LABORATORIES, LTD.,
`
`Petitioner,
`
`v.
`
`NOVO NORDISK A/S,
`
`Patent Owner.
`
`
`
`
`
`
`
`
`
`
`
`Case No. IPR2023-007241
`
`Patent No. 10,335,462
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PETITIONER’S MOTION TO SEAL
`
`
`
`
`
`
`
`
`1 IPR2024-00009 (Dr. Reddy’s Laboratories) has been joined with this proceeding.
`
`
`
`
`
`
`
`I.
`
`Introduction
`
`Pursuant to 37 C.F.R. Sections 42.14 and 42.54, Petitioner Mylan
`
`Pharmaceuticals Inc. (“Petitioner”) hereby moves to seal its Petitioner Reply and
`
`certain exhibits submitted with its Petitioner Reply as described herein. Patent
`
`Owner has advised Petitioner that it does not oppose this motion to seal.
`
`II. Good Cause Exists to Seal the Petitioner Reply Response and Supporting
`Exhibits
`
`Pursuant to the Protective Order proposed by Patent Owner as Exhibit 2079,
`
`Petitioner moves to seal (i) its Petitioner Reply submitted concurrently with this
`
`motion; and (ii) the following exhibits:
`
` EX1308
`
` EX1311
`
` EX1312
`
` EX1314
`
` EX1323
`
`Patent Owner has previously moved to file certain documents under seal.
`
`Paper 28. Petitioner’s Reply and the above-listed exhibits address information filed
`
`under seal by Patent Owner. Accordingly, it is necessary for Petitioner to file these
`
`documents under seal.
`
`Petitioner has concurrently filed its Petitioner Reply and the above-listed
`
`exhibits and served confidential versions on Patent Owner. Petitioner will file
`
`
`
`
`
`
`
`redacted versions of the Petitioner Reply and the above-listed exhibits upon
`
`receiving any redactions Patent Owner believes are necessary.
`
`III. Conclusion
`
`For the foregoing reasons, Petitioner respectfully requests that the Board grant
`
`this motion to seal.
`
`
`Dated: May 22, 2024
`
`
`PERKINS COIE LLP
`700 Thirteenth Street, N.W., Suite 800
`Washington, D.C. 20005-3960
`202.654.6200 (phone)
`202.654.6211 (fax)
`
`
`
`
`
`Respectfully submitted,
`
`/Brandon M. White/
`Lead Counsel
`Brandon M. White, Reg No. 52,354
`
`
`
`
`Attorneys for Petitioner
`
`
`2
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served a true and
`
`correct copy of the foregoing: PETITIONER’S MOTION TO SEAL by email to
`
`the electronic service addresses for Patent Owner and Petitioner in IPR2024-
`
`00009:
`
`J. Steven Baughman
`Megan Raymond
`Jenny C. Wu
`Michael Milea
`Philip S. May
`Joshua Reich
`GROOMBRIDGE, WU, BAUGHMAN &
`STONE LLP
`steve.baughman@groombridgewu.com
`megan.raymond@groombridgewu.com
`jenny.wu@groombridgewu.com
`mike.milea@groombridgewu.com
`philip.may@groombridgewu.com
`Joshua.reich@groombridgewu.com
`Novo-Semaglutide-
`IPR@groombridgewu.com
`
`
`
`
`Dated: May 22, 2024
`
`
`PERKINS COIE LLP
`700 Thirteenth Street, N.W., Suite 800
`Washington, D.C. 20005-3960
`202.654.6200 (phone)
`202.654.6211 (fax)
`
`
`
`
`
`Jovial Wong
`Scott Border
`WINSTON & STRAWN LLC
`jwong@winston.com
`sborder@winston.com
`
`
`
`
`/Brandon M. White/
`Lead Counsel
`Brandon M. White, Reg No. 52,354
`
`
`Attorneys for Petitioner
`
`
`