Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`
`Filed: October 30, 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, a GE COMPANY, LLC,
`Petitioner,
`
`v.
`
`LIQUIDPOWER SPECIALTY PRODUCTS INC.
`Patent Owner.
`______________________
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`______________________
`
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`U.S. Patent No. 8,450,249 B2
`
`Filed: October 30, 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, a GE COMPANY, LLC,
`Petitioner,
`
`v.
`
`LIQUIDPOWER 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
`
`1.
`
`moves to seal portions of three sentences on pages 10 and 11 in its Motion to
`
`Exclude, filed concurrently herewith, that refer to statements made by, and
`
`information contained in certain exhibits submitted by, Petitioner Baker Hughes,
`
`Inc. (“Baker”), which previously have been designated by Baker as confidential or
`
`highly confidential information under the Protective Order, and which refer to the
`
`composition of Baker’s copy product. Accordingly, pursuant to Baker’s
`
`designations and Baker’s prior representations to the Board that the information is
`
`confidential, LSPI moves to seal the passages.
`
`Concurrently herewith, LSPI is filing an unredacted copy of LSPI’s Motion
`
`to Seal for access by the Board and Parties only. LSPI also is filing a redacted
`
`copy of LSPI’s Motion to Seal, with the aforementioned portions of three
`
`sentences on pages 10 and 11 of LSPI’s Motion to Seal redacted, for access by the
`
`public.
`
`2.
`
`Patent Owner LSPI also hereby moves to seal a portion of a sentence
`
`on page 4 of its Sur-Reply, Paper 39, filed October 23, 2017, which refers to the
`
`identity of a hydrocarbon that was the subject of LSPI’s internal business and
`
`technical documents, which is confidential information that and has not been
`
`disclosed publicly. Disclosure of this confidential information to LSPI’s
`
`
`
`
`competitors would eliminate its economic value, and LSPI therefore moves to seal
`
`Case IPR2016-01905
`U.S. Patent No. 8,450,250 B2
`
`the passage referring to this information.
`
`LSPI also moves to seal certain passages on pages 1-3 and 5 of the Sur-
`
`Reply, which similarly refer to statements made by, and information contained in
`
`certain exhibits submitted by, Petitioner Baker Hughes, Inc. (“Baker”), which
`
`previously have been designated by Baker as confidential or highly confidential
`
`information under the Protective Order. Those passages refer to statements made
`
`in Baker’s business documents and e-mail communications, the identity of a Baker
`
`customer, and the composition of Baker’s copy product. Accordingly, pursuant to
`
`Baker’s designations and Baker’s prior representations to the Board that this
`
`information is confidential, LSPI moves to seal the passages referring to this
`
`information.
`
`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.
`
`2
`
`
`
`
`Dated: October 30, 2017
`
`
`
`
`
`
`Case IPR2016-01905
`U.S. Patent No. 8,450,250 B2
`
`
`/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.
`
`3
`
`
`
`
`
`
`Case IPR2016-01901
`U.S. Patent No. 8,450,249 B2
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on October 30, 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: October 30, 2017
`
`/s/ Douglas W. McClellan
`Douglas W. McClellan
`Reg. No. 41,183
`
`
`
`
`
`
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