`U.S. Patent No. 8,450,249 B2
`
`Filed: September 12, 2017
`
`Filed on behalf of:
`Patent Owner LiquidPower Specialty Products, Inc.
`By: Douglas W. McClellan, Reg. No. 41,183
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, Texas 77002
`Tel: (713) 546-5000, Fax: (713) 224-9511
`doug.mcclellan@weil.com
`
`Elizabeth S. Weiswasser, Reg. No. 55,721
`Weil, Gotshal & Manges LLP
`767 Fifth Avenue
`New York, NY 10153
`Tel: (212) 310-8000, Fax: (212) 310-8007
`elizabeth.weiswasser@weil.com
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`BAKER HUGHES INCORPORATED,
`Petitioner,
`
`v.
`
`LIQUIDPOWER SPECIALTY PRODUCTS INC.
`(f/k/a LUBRIZOL SPECIALTY PRODUCTS, INC.)
`Patent Owner.
`______________________
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`______________________
`
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`
`
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`
`Patent Owner LiquidPower Specialty Products, Inc. (“LSPI”) hereby moves
`
`to seal a sentence, and its accompanying citation, in its Opposition to Petitioner’s
`
`Motion for Additional Discovery.
`
`Counsel for LSPI provided the aforementioned sentence and citation to
`
`counsel for Baker prior to the filing of the instant motion and inquired whether
`
`Baker contends that the sentence contains confidential information under the
`
`Protective Order. Counsel for Baker responded that the sentence and citation
`
`“contain confidential information that warrants filing under and seal and redaction
`
`in a publicly-filed version, for at least the reason that the citation is to 32 pages of a
`
`document (the Patent Owner Response) that LSPI itself designated as containing
`
`confidential information subject to the protective order.” In addition, the sentence
`
`refers to documents produced by non-party Flowchem LLC (“Flowchem”), which
`
`have been designated by Flowchem as confidential or highly confidential under the
`
`Protective Order. Accordingly, LSPI moves to seal the sentence and citation.
`
`LSPI is filing an unredacted copy of LSPI’s Opposition to Petitioner’s
`
`Motion for Additional Discovery, for the Board and Parties only, concurrently
`
`herewith. LSPI also is filing a redacted copy of LSPI’s Opposition to Petitioner’s
`
`Motion for Additional Discovery, with the aforementioned sentence and citation
`
`redacted, for access by the public concurrently herewith.
`
`
`
`
`
`
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`
`On behalf of LSPI, the undersigned counsel certifies that the
`
`information sought to be sealed by this motion has not, to their knowledge, been
`
`published or otherwise made public.
`
`Dated: September 12, 2017
`
`
`
`
`
`
`
`/s/ Douglas W. McClellan /
`Douglas W. McClellan, Reg. No. 41,183
`Melissa L. Hotze, Reg. No. 55,279
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, TX 77002
`Tel: (713) 546-5000
`Fax: (713) 224-9511
`doug.mcclellan@weil.com
`melissa.hotze@weil.com
`
`Elizabeth S. Weiswasser, Reg. No. 55,721
`Weil, Gotshal & Manges LLP
`767 Fifth Avenue
`New York, NY 10153
`Tel: (212) 310-8000
`Fax: (212) 310-8007
`elizabeth.weiswasser@weil.com
`
`
`Attorneys for Patent Owner LiquidPower
`Specialty Products, Inc.
`
`2
`
`
`
`
`
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on September 12, 2017, a copy of the foregoing
`
`Motion to Seal was served by filing this document through the PTAB’s E2E
`
`System as well as delivering a copy via electronic mail upon the following:
`
`Herbert D. Hart III
`Registration No. 30,063
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street
`Chicago, Illinois 60661
`Tel.: (312) 775-8000
`Email: hhart@mcandrews-ip.com
`
`George F. Wheeler
`Registration No. 28,766
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street
`Chicago, Illinois 60661
`Tel.: (312) 775-8000
`Email: gwheeler@mcandrews-
`ip.com
`
`Aaron F. Barkoff
`Registration No. 52,591
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street
`Chicago, Illinois 60661
`Tel.: (312) 775-8000
`Email: abarkoff@mcandrews-ip.com
`
`Peter J. Lish
`Registration No. 59,383
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street
`Chicago, Illinois 60661
`Tel.: (312) 775-8000
`Email: plish@mcandrews-ip.com
`
`
`Dated: September 12, 2017
`
`/s/ Douglas W. McClellan
`Douglas W. McClellan
`Reg. No. 41,183
`
`
`
`
`
`
`
`
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