`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`Solenis LLC
`
`Petitioner,
`
`v.
`
`Ecolab USA Inc.,
`
`Patent Owner
`
`_____________________
`
`Inter Partes Review No.: IPR2016-1281
`
`U.S. Patent No. 8,465,623
`
`
`
`JOINT REQUEST TO TREAT EXHIBIT 1032 AS BUSINESS
`CONFIDENTIAL PURSUANT TO 35 U.S.C. § 317(b) and 37 C.F.R. §42.74(c)
`
`
`
`
`
`Petitioner Solenis LLC and Patent Owner Ecolab USA Inc. jointly request
`
`that Exhibit 1032, a copy of the settlement agreement in the related district court
`
`litigations identified in the parties mandatory disclosures be treated as “business
`
`confidential” and be kept separate from the public file of 8,465,623. Exhibit 1032
`
`is being submitted as the PRPS system as “Parties and Board Only.” The parties
`
`further request the Board to not make Exhibit 1032 available to any third party,
`
`except as provided for in 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c).
`
`Date: August 24, 2017
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`/s/Michael P. Chu
`Michael P. Chu
`Kevin P. Shortsle
`McDermott Will & Emery LLP
`444 West Lake Street, Suite 4000
`Chicago, Illinois 60606
`Phone: 312.372.2000
`Fax: 312.984.7700
`mchu@mwe.com
`kshortsle@mwe.com
`Attorneys for Petitioner
`
`/s/Anthony R. Zeuli
`Anthony R. Zeuli, Reg. No. 45,255
`Merchant & Gould P.C.
`3200 IDS Center
`80 South 8th Street
`Minneapolis, MN 55402
`Telephone: (612) 371-5208
`Fax: (612) 332-9081
`Email: tzeuli@merchantgould.com
`NalcoIPR@merchantgould.com
`Attorney for Patent Owner
`
`
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