`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`GARMIN INTERNATIONAL, INC. ET AL.
`
`Petitioner
`
`v.
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC
`
`Patent Owner
`
`____________
`
`Case IPR2012-00001
`Patent 6,778,074
`____________
`
`
`
`PATENT OWNER’S RESPONSE TO BOARD’S DECISION
`REGARDING PATENT OWNER’S REVISED MOTION TO SEAL
`In response to the Board’s April 5, 2013 Decision (Paper 36) regarding
`
`
`
`Patent Owner’s Revised Motion
`
`to Seal, Patent Owner Cuozzo Speed
`
`Technologies LLC (hereinafter “Patent Owner”) respectfully submits
`
`this
`
`Response.
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`I.
`
`
`
`
`Attorney’s Docket No.: CUO0001-RE
`Page 2
`
`PATENT OWNER HAS COMPLIED WITH BOARD’S ORDER ON ITS
`MOTION TO SEAL CERTAIN DOCUMENTS SUBMITTED WITH AND
`IN SUPPORT OF PATENT OWNER’S RESPONSE (PAPER 31) AND
`MOTION TO AMEND (PAPER 32).
`
`In compliance with the Board’s Order, the Patent Owner has moved Exhibits
`
`I and J in Revised Exhibits 3000 and 4000 (currently designated confidential) to
`
`publically available Exhibits 3001 and 4001. The Patent Owner understands that
`
`all earlier versions of Exhibits 3000 and 4000 and Exhibits 3001 and 4001 will be
`
`expunged from the record and replaced by the further revised versions submitted
`
`herewith and described below.
`
`II.
`
`(CUOZZO
`4001
`3001 AND
`FURTHER REVISED EXHIBITS
`DECLARATION WITH NON-PROTECTIVE ORDER MATERIAL) AND
`FURTHER REVISED EXHIBITS 3000 AND 4000 (PROTECTIVE ORDER
`MATERIAL OF CUOZZO DECLARATION).
`
`Patent Owner respectfully submits the attached Further Revised Exhibits
`
`3001 and 4001, which replace Revised Exhibits 3001 and 4001 filed with Patent
`
`Owner’s Revised Motion to Seal (Paper 35) on March 21, 2013, which replaced
`
`Exhibits 3001 and 4001 filed with Patent Owner’s Response (Paper 31) and
`
`Motion to Amend (Paper 32), respectively, on March 11, 2013. Specifically,
`
`Further Revised Exhibits 3001 and 4001 each include the Declaration of Giuseppe
`
`A. Cuozzo Pursuant to 37 C.F.R. § 1.131 with non-protective order material, i.e.,
`
`Exhibits A, C-J, and M-O.
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`
`
`Attorney’s Docket No.: CUO0001-RE
`Page 3
`
`Further, Patent Owner respectfully submits the attached Further Revised
`
`Exhibits 3000 and 4000, which replace Revised Exhibits 3000 and 4000 filed with
`
`Patent Owner’s Revised Motion to Seal (Paper 35) on March 21, 2013, which
`
`replaced Exhibits 3000 and 4000 filed with Patent Owner’s Response (Paper 31)
`
`and Motion to Amend (Paper 32), respectively, on March 11, 2013. Further
`
`Revised Exhibits 3000 and 4000 include confidential information designated
`
`PROTECTIVE ORDER MATERIAL and attached to the Declaration of Giuseppe
`
`A. Cuozzo Pursuant to 37 C.F.R. § 1.131, i.e., Exhibits B, K, L, and P.
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`April 11, 2013
`Date
`
`
`
`
`Attorney’s Docket No.: CUO0001-RE
`Page 4
`
`Respectfully submitted,
`
`
`
`/John R. Kasha/
`John R. Kasha, Reg. No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`Cabrach J. Connor
`Reed Scardino LLP
`301 Congress Ave. Ste. 1250
`Austin, Texas 78701
`(512) 615-5989
`(512) 474-2622 facsimile
`Email: cconnor@reedscardino.com
`
`David Skeels
`Friedman Suder & Cooke
`604 East 4th Street
`Suite 200
`Fort Worth, TX 76012
`Email: skeels@fsclaw.com
`
`
`Attorneys for Cuozzo Speed Technologies
`LLC
`(IPR Trial No. 2012-00001)
`
`
`
`Case No.: IPR2012-00001
`Patent No: 6,778,074
`
`
`
`
`
`
`Attorney’s Docket No.: CUO0001-RE
`Page 5
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on the 11th day of April 2013, a true and correct copy of
`
`Patent Owner’s Response to the Board’s Decision Regarding Patent Owner’s
`
`Revised Motion to Seal including Further Revised Exhibits 3000, 3001, 4000,
`
`and 4001has been provided, via electronic mail to counsel of record as follows:
`
`jbailey@hoveywilliams.com (Jennifer C. Bailey, Lead Counsel)
`sbrown@hoveywilliams.com (Scott R. Brown, Back-Up Counsel)
`jcrawford@hoveywilliams.com (Justin Crawford, Paralegal)
`
`
`Respectfully submitted,
`
`/John R. Kasha/
`John R. Kasha, Reg. No. 53,100
`Attorney for Cuozzo Speed Technologies
`LLC
`
`
`
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886, telephone
`(301) 340-3022, facsimile
`Email: john.kasha@kashalaw.com
`
`
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