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`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`J SQUARED, INC. d/b/a UNIVERSITY LOFT COMPANY
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`Petitioner
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`v.
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`SAUDER MANUFACTURING COMPANY
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`Patent Owner
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`_______________
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`
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`Case IPR2015-00958
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`Patent No. 8,585,136
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`CHAIR WITH COUPLING
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`COMPANION STOOL BASE
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`_______________
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`JOINT MOTION TO SEAL
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`-1-
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`Sauder Manufacturing Company (“Patent Owner”), and J Squared, Inc. d/b/a
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`University Loft Company (“Petitioner”) by and through their respective counsel of
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`record, hereby move to seal certain documents identified herein and move for entry
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`of a Protective Order for the following reasons:
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`
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`In support of its Trial Response, Patent Owner intends to file as Exhibits
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`certain excerpts of deposition transcripts and documents that contain information
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`Petitioner deems confidential commercial information, specifically customer
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`names, vendor names and financial information. In addition, Patent Owner will be
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`filing the Declaration of Phillip Bontrager that contains confidential financial
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`information.
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`Pursuant to 37 C.F.R. § 42.54, protective orders may be issued for good
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`cause to protect a party from disclosing confidential information. The parties
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`hereby respectfully request permission to seal these certain documents and request
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`entry of the proposed default protective order set forth in the Office Patent Trial
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`Practice Guide, filed concurrently as Exhibit 4001.
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`Good cause exists for sealing the documents as they each include
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`confidential commercial business information regarding customer and vendor
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`names, as well as Petitioner’s confidential financial information. 37 C.F.R. §
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`42.54. Each undersigned counsel certifies that the information associated with his
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`client for which counsel wishes protection has not been published or otherwise
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`made public. The parties have undertaken efforts to maintain the confidentiality of
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`-2-
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`this information in the related District Court proceeding. The “attorneys eyes
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`only” designation from the deposition transcripts was redacted by stipulation of
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`counsel.
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`Respectfully submitted,
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`/s/William F. Bahret
`/s/Thomas N. Young
`William F. Bahret (Reg. No. 31,087)
`Thomas N. Young (Reg. No. 20985)
`Bahret & Associates LLC
`Young Basile Hanlon & MacFarlane P.C.
`320 North Meridian Street
`3001 W. Big Beaver Rd. Suite 624
`Troy, MI 48084
`Suite 510
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`Phone: (248) 649-3333 Indianapolis, IN 46204
`litigation@youngbasile.com
`Phone: (317) 423-2300
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`bahret@bahretlaw.com
`Attorney for Patent Owner
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`Attorney for Petitioner
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`
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`Dated: November 21, 2015
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`-3-
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`CERTIFICATE OF SERVICE
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`
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`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on November 21, 2015, a complete and entire copy of the foregoing was
`provided via Federal Express, by serving the correspondence address of record as
`follows:
`
`Stephen F. Rost
`Reg. No. 61,983
`Taft Stettinius & Hollister LLP
`One Indiana Square, Suite 3500
`Indianapolis, IN 46204
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`
`
`William F. Bahret
`Reg. No. 31,087
`Bahret & Associates LLC
`320 N. Meridian St., Suite 510
`Indianapolis, Indiana 46204
`
`Timothy Eagle
`Reg. No. 31755
`VARNUM RIDDERING
`SCHMIDT & HOWLETT LLP
`333 Bridge Street NW
`P.O. Box 352
`Grand Rapids, MI 49501-0352
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`/s/Thomas N. Young
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`-4-
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