` U.S. Patent No. 10,335,462
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`APOTEX INC.,
`Petitioner
`
`v.
`NOVO NORDISK A/S,
`Patent Owner
`______________________
`Case IPR2024-00631
`Patent 10,335,462
`______________________
`
`
`
`PATENT OWNER’S MOTION TO SEAL
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`IPR2024-00631
` U.S. Patent No. 10,335,462
`
`
`Introduction
`Pursuant to the default protective order and 37 C.F.R. §§ 42.14, 42.54, and
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`I.
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`42.55, Patent Owner Novo Nordisk A/S (“Novo”) hereby moves to seal its Reply
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`to Petitioner’s Reply to Patent Owner’s Preliminary Response (the “Reply”).
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`Petitioner Apotex Inc. (“Apotex”) has advised Novo that Apotex does not oppose
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`this motion to seal.
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`II. Good Cause Exists to Seal the Reply
`Pursuant to the default protective order (filed by Apotex at Appendix A of
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`Paper 3) and 37 C.F.R. §§ 42.14, 42.54 and 42.55, Novo moves to seal its Reply
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`submitted concurrently with this motion.
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`Based on Apotex’s representations, “good cause” exists to seal the Reply
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`because it includes material that Apotex has represented is non-public business
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`information. See Celltrion, Inc. v. Genentech, Inc., IPR2016-01667, Pap.31, 4
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`(July 23, 2018); Greene’s Energy Grp., LLC v. Oil States Energy Servs., LLC,
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`IPR2014-00216, Pap.27, 5 (Sept. 23, 2014); 37 C.F.R. § 42.54. Specifically,
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`portions of the Reply contain information that Apotex has designated confidential
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`in Apotex’s Third Motion to Seal and Apotex’s Motion to Seal and for Entry of a
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`Protective Order Pursuant to 37 C.F.R. § 42.54. Petitioner has stated that this
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`information, if “publicly disclosed[,] would likely cause competitive business harm
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`to Apotex.” Paper 19 at 2.
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`1
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`Novo has filed and served on Apotex an unredacted, nonpublic version of
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`IPR2024-00631
` U.S. Patent No. 10,335,462
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`the corresponding Reply with this motion. Novo will coordinate with Apotex with
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`respect to the filing of a redacted version of the Reply once Apotex has the
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`opportunity to identify any redactions Apotex believes are necessary.
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`III. Conclusion
`For the foregoing reasons, Novo respectfully requests that the Board grant
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`Dated: July 15, 2024
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`this motion to seal.
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`
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`Respectfully submitted by:
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`/Megan Raymond/
`J. Steven Baughman (Reg. No. 47,414)
`Megan Raymond (Reg. No. 72,997)
`Michael Milea (Reg. No. 71, 863)
`Joshua Reich (Reg. No. 75,338)
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`Attorneys For Patent Owner
`Novo Nordisk A/S
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`2
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`IPR2024-00631
` U.S. Patent No. 10,335,462
`
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`CERTIFICATE OF PAGE COUNT
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`The undersigned certifies that the foregoing PATENT OWNER’S MOTION
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`TO SEAL complies with the 15-page limitation in 37 C.F.R. §42.24(a)(1)(v).
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`Dated: July 15, 2024
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`Respectfully Submitted,
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`/Megan Raymond/
`By:
`Megan Raymond (Reg. No. 72,997)
`GROOMBRIDGE, WU, BAUGHMAN &
`STONE LLP
`801 17th Street, NW, Suite 1050
`Washington, DC, 20006
`P: (202)-505-5878
`megan.raymond@groombridgewu.com
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`1
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`IPR2024-00631
` U.S. Patent No. 10,335,462
`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of PATENT OWNER’S
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`MOTION TO SEAL has been served in its entirety by causing the
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`aforementioned document to be electronically mailed to the following attorneys of
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`record for the Petitioner listed below:
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`John J. Molenda
`Lawrence Kass
`Kyler Doh
`Michael I. Green
`Semaglutide@Steptoe.com
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`Dated: July 15, 2024
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` Respectfully submitted,
`By: /Sayem Osman/
`Sayem Osman
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`2
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