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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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`MEDIATEK INC.,
`
`Petitioner
`v.
`PARKERVISION, INC.,
`Patent Owner.
`____________
`
`Case No: IPR2024-00150
`
`U.S. Patent No. 7,292,835
`____________
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`PETITIONER’S MOTION TO FILE
`CONFIDENTIAL DOCUMENTS UNDER SEAL
`PURSUANT TO 37 C.F.R. §§ 42.14 AND 42.54
`
`164475315.1
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` PTAB Case No. IPR2024-00150 for Patent No. 7,292,835B1
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Petitioner MediaTek Inc.
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`
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`(“MediaTek”) respectfully submits this Motion to Seal Exhibit 1015 filed
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`concurrently with this Motion and the Petition for Inter Partes Review. MediaTek
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`understands that Patent Owner considers Exhibit 1015 highly confidential and
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`therefore no public redacted version of this document is being filed.
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`Pursuant to the Consolidated Trial Practice Guide (Nov. 2019), “[t]he terms
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`of a protective order take effect upon the filing of a Motion to Seal by a party, and
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`remain in place until lifted or modified by the Board either on the motion of a party
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`for good cause shown or sua sponte by the Board.” (Appendix B, § (b).)
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`Accordingly, MediaTek understands that the protective order (Ex. 1022) proposed
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`by MediaTek, and identical to the default protective order from Appendix B of
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`Consolidated Trial Practice Guide (Nov. 2019), will take effect upon filing of this
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`motion.
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`I.
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`
`Background
`MediaTek is concurrently submitting with its Petition for Inter Partes
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`Review an Exhibit 1015. As explained below, this document belongs to Patent
`
`Owner, and Patent Owner apparently considers this document to be highly
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`confidential.
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`1
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` PTAB Case No. IPR2024-00150 for Patent No. 7,292,835B1
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`II. Good Cause Regarding Sealing the Exhibit Containing Confidential
`Information
`Exhibit 1015 was served by Patent Owner on MediaTek in the parallel
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`district court litigation. Patent Owner marked the document “Confidential” on all
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`pages. Exhibit 1015 is an alleged infringement claim chart that constitutes part of
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`Patent Owner’s preliminary infringement contentions in the parallel district court
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`litigation. MediaTek understands, based on activities in a separate district court
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`litigation against a third party, that Patent Owner considers the reverse engineering
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`analysis in documents like Exhibit 1015 to be highly confidential and not
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`appropriate for public disclosure. See Discovery Order, ParkerVision, Inc. v.
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`Realtek Semiconductor Corp., No. 6:22-cv-01162 (W.D. Tex. July 27, 2023)
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`(ECF 63).
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`Thus, Exhibit 1015 belongs to Patent Owner, and Patent Owner apparently
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`considers it to contain highly confidential information not appropriate for public
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`disclosure. On that basis, MediaTek moves to seal Exhibit 1015.
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`2
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`Dated: November 15, 2023
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`
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`PERKINS COIE LLP
`11452 El Camino Real, Ste 300
`San Diego, California 92130-2080
`858.720.5700 (phone)
`858.720.5799 (fax)
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`
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` PTAB Case No. IPR2024-00150 for Patent No. 7,292,835B1
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`Respectfully submitted,
`
` /Jessica C. Kaiser/
`Lead Counsel
`Jessica C. Kaiser, Reg. No. 58,937
`
`Back-up Counsel
`Matthew C. Bernstein, pro hac vice to be
`requested
`Kyle R. Canavera, Reg. No. 72,167
`Kevin A. Zeck, pro hac vice to be
`requested
`
`Attorneys for MediaTek Inc., Petitioner
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`3
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` PTAB Case No. IPR2024-00150 for Patent No. 7,292,835B1
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`CERTIFICATE OF SERVICE
`I hereby certify that on November 15, 2023, a true and correct copy of the
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`foregoing MOTION TO SEAL EXHIBIT by electronic mail on the Patent Owner
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`via its attorneys of record:
`
`Workman Nydegger
`60 East South Temple
`Suite 100
`Salt Lake City, UT 84111
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`and the attorneys of record for Plaintiff in the concurrent litigation matter:
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`rdaignault@daignaultiyer.com
`cbiyer@daignaultiyer.com
`jcharkow@daignaultiyer.com
`ssamay@daignaultiyer.com
`smandir@daignaultiyer.com
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`Daignault Iyer LLP
`8618 Westwood Center Drive
`Suite 150
`Vienna, VA 22182
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`Respectfully submitted,
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`
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`
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`/Anita Chou/
`Anita Chou
`Paralegal
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`4
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`Date: November 15, 2023
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