UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`NEC CORPORATION OF AMERICA, NEC CASIO MOBILE COMMUNICA-
`TIONS, LTD., HTC CORPORATION, HTC AMERICA, ZTE (USA), PANTECH
`CO., LTD., PANTECH WIRELESS, INC., LG ELECTRONICS, INC., and LG
`ELECTRONICS U.S.A., INC.
`
`Petitioners
`
`v.
`
`CELLULAR COMMUNICATIONS LLC,
`Patent Owner
`_______________
`
`Case: IPR2014-01133
`
`Patent 7,218,923
`_______________
`
`
`
`[PROPOSED] PROTECTIVE ORDER
`
` (INTER PARTES REVIEW OF U.S. PATENT NO. 7,218,923)
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`NEC CORPORATION OF AMERICA, NEC CASIO MOBILE COMMUNICA-
`TIONS, LTD., HTC CORPORATION, HTC AMERICA, ZTE (USA), PANTECH
`CO., LTD., PANTECH WIRELESS, INC., LG ELECTRONICS, INC., and LG
`ELECTRONICS U.S.A., INC.
`
`Petitioners
`
`v.
`
`CELLULAR COMMUNICATIONS LLC,
`Patent Owner
`_______________
`
`Case: IPR2014-01133
`
`Patent 7,218,923
`_______________
`
`
`
`[PROPOSED] PROTECTIVE ORDER
`
` (INTER PARTES REVIEW OF U.S. PATENT NO. 7,218,923)
`
`
`
`Patent No. 7,218,8923 – Protective Order
`
`
`
`This protective order governs the treatment and filing of confidential infor-
`
`mation, including documents and testimony in the above-caption proceeding be-
`
`fore the Patent Office and Trial Board.
`
`1. Confidential information shall be clearly marked ‘‘PROTECTIVE OR-
`
`DER MATERIAL.’’
`
`2. Access to confidential information is limited to the following individuals:
`
`(A) Outside Counsel. Attorneys who are not employees of any named party
`
`to this action or any Related Entity, but who are retained to represent or advise a
`
`named party to this proceeding or any Related Entity, including support personnel;
`
`contract attorneys; paralegals; consultants; legal secretaries; legal clerks; technical
`
`advisors; employees of outside vendors providing copy services, document,
`
`graphics, and exhibit preparation services; and jury consultant and research ser-
`
`vices.
`
`(B) The Office. Employees and representatives of the Office who have a
`
`need for access to the confidential information shall have such access without the
`
`requirement to sign an Acknowledgement. Such employees and representatives
`
`shall include the Director, members of the Board and their clerical staff, other sup-
`
`port personnel, court reporters, and other persons acting on behalf of the Office.
`
`(C) Support Personnel. Administrative assistants, clerical staff, court report-
`
`ers and other support personnel of the foregoing persons who are reasonably nec-
`
`1
`
`
`
`Patent No. 7,218,8923 – Protective Order
`
`essary to assist those persons in the proceeding shall not be required to sign an
`
`Acknowledgement, but shall be informed of the terms and requirements of the Pro-
`
`tective Order by the person they are supporting who receives confidential infor-
`
`mation.
`
`3. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons not
`
`authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality of the
`
`information, which efforts shall be no less rigorous than those the recipient uses to
`
`maintain the confidentiality of information not received from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access to the
`
`confidential information understand and abide by the obligation to maintain the
`
`confidentiality of information received that is designated as confidential; and
`
`(D) Limiting the copying of confidential information to a reasonable number
`
`of copies needed for conduct of the proceeding and maintaining a record of the lo-
`
`cations of such copies.
`
`4. Persons receiving confidential information shall use the following proce-
`
`dures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`2
`
`
`
`Patent No. 7,218,8923 – Protective Order
`
`(i) A party may file documents or information with the Board under seal, to-
`
`gether with a non-confidential description of the nature of the confidential infor-
`
`mation that is under seal and the reasons why the information is confidential and
`
`should not be made available to the public. The submission shall be treated as con-
`
`fidential and remain under seal, unless, upon motion of a party and after a hearing
`
`on the issue, or sua sponte, the Board determines that the documents or information
`
`do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the information
`
`submitted to the Board, the submitting party shall file confidential and non-
`
`confidential versions of its submission, together with a Motion to Seal the confi-
`
`dential version setting forth the reasons why the information redacted from the
`
`non-confidential version is confidential and should not be made available to the
`
`public. The nonconfidential version of the submission shall clearly indicate the lo-
`
`cations of information that has been redacted. The confidential version of the sub-
`
`mission shall be filed under seal. The redacted information shall remain under seal
`
`unless, upon motion of a party and after a hearing on the issue, or sua sponte, the
`
`Board determines that some or all of the redacted information does not qualify for
`
`confidential treatment.
`
`(B) Documents and Information Exchanged Among the Parties. Information
`
`designated as confidential that is disclosed to another party during discovery or
`
`3
`
`
`
`Patent No. 7,218,8923 – Protective Order
`
`other proceedings before the Board shall be clearly marked as ‘‘PROTECTIVE
`
`ORDER MATERIAL’’ and shall be produced in a manner that maintains its confi-
`
`dentiality.
`
`
`
`4
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