`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`EDWARDS LIFESCIENCES CORPORATION, EDWARDS
`LIFESCIENCES LLC, AND EDWARDS LIFESCIENCES AG
`Petitioners
`
`v.
`
`BOSTON SCIENTIFIC SCIMED, INC.
`Patent Owner
`_____________
`
`Case IPR2017-00060
`Patent 8,992,608 B2
`_____________
`
`JOINT MOTION FOR ENTRY OF STIPULATED PROTECTIVE
`ORDER
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Pursuant to the Final Rules of Practice for Trials Before the Patent Trial
`
`and Appeal Board and Judicial Review of Patent Trial and Appeal Board
`
`Decisions (77 Fed. Reg. 157, Aug. 14, 2012), 35 U.S.C. § 316, 37 C.F.R.
`
`§ 42.54, and § A.2 of the Case Management and Scheduling Order entered in
`
`this proceeding, Patent Owner Boston Scientific Scimed, Inc. and Petitioners
`
`Edwards Lifesciences Corporation, Edwards Lifesciences LLC, and Edwards
`
`Lifesciences AG jointly move for entry of the Stipulated Protective Order attached
`
`hereto as Exhibit 1.
`
`The Stipulated Protective Order is based on the Default Protective Order
`
`provided in Appendix B of the Trial Practice Guide, with modifications agreed
`
`upon by the Parties. These changes are proposed to harmonize the protective
`
`order with the Stipulated Protective Order in place in Case No. 16-275-SLR-
`
`SFR (D. Del.) between the same parties and to permit information from such
`
`litigation to be used in this proceeding, as well as to further ensure the
`
`preservation of confidentiality of information that may be submitted to the
`
`Board. A document comparing the Parties’ Stipulated Protective Order to the
`
`Default Protective Order is attached hereto as Exhibit 2.
`
`The Parties respectfully request that the Board enter the Stipulated
`
`Protective Order.
`
`1
`
`
`
`DATED: June 20, 2017
`
`Respectfully submitted,
`
`/s/ Jennifer A. Sklenar
`Jennifer A. Sklenar (Reg. No. 40,205)
`Wallace Wu (Reg. No. 45,380)
`ARNOLD & PORTER KAYE
`SCHOLER LLP
`777 S. Figueroa Street, 44th Floor
`Los Angeles, CA 90017-5844
`Tel:
`(213) 243-4000
`Fax: (213) 243-4199
`
`Attorneys for Patent Owner Boston
`Scientific Scimed, Inc.
`
`/s/ Gregory S. Cordrey
`Gregory S. Cordrey (Reg. No. 44,089)
`Brian P. Egan (Reg. No. (54,866)
`Catherine Nyarady (Reg. No. 42,042)
`
`Attorneys for Petitioners
`Edwards Lifesciences Corporation,
`Edwards Lifesciences LLC, and
`Edwards Lifesciences AG
`
`2
`
`
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