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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`LG Electronics, Inc.,
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`Petitioner
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`v.
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`Broadcom Corporation,
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`Patent Owner
`_____________________
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`Case IPR2017-01544
`Patent No. 7,342,967
`_____________________
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`JOINT REQUEST TO FILE SETTLEMENT AGREEMENT
`AS BUSINESS CONFIDENTIAL INFORMATION
`PURSUANT TO 35 U.S.C. § 317 AND 37 C.F.R. § 42.74(c)
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`Pursuant to 35 U.S.C. § 317 and 37 C.F.R. § 42.74, and the Board’s email
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`correspondence of April 6, 2018, authorizing filing of this paper, Petitioner LG
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`Electronics, Inc. (“Petitioner”) and Patent Owner Broadcom Corporation (“Patent
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`Owner”) jointly request to file the Settlement Agreement, submitted concurrently
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`herewith as Exhibit 1015 to the Joint Motion to Terminate Proceeding, in its
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`entirety, as Business Confidential information.1
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`If requested, the rules permit the parties to have any filed settlement
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`agreement treated as business confidential information and kept separate from the
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`files of the involved patent. 37 C.F.R. § 42.74(c). Indeed, the statute requires it.
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`At the request of a party to the proceeding, the agreement or
`understanding shall be
`treated as business confidential
`information, shall be kept separate from the file of the involved
`patents, and shall be made available only
`to Federal
`Government agencies on written request, or to any person on a
`showing of good cause.
`35 U.S.C. § 317(b).
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`Petitioner and Patent Owner hereby request that the settlement agreement
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`filed herewith as Exhibit 1015 be treated as business confidential information, be
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`kept separate from the file of the above captioned IPR, and be made available only
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`1 The Settlement Agreement has been filed electronically via E2E for “Parties and
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`Board Only” to preserve confidentiality.
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`to Federal Government agencies on written request, or to any person on a showing
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`of good cause pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c). In view of
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`that request the settlement agreement has been filed for access by the “Parties and
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`Board Only.”
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`Date: April 9, 2018
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`Respectfully submitted,
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`Date: April 9, 2018
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`/ Erika H. Arner /
`Erika H. Arner, Lead Counsel
` Reg. No. 57,540
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` Lead Counsel for Petitioner
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`Respectfully submitted,
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`/ John M. Caracappa /
`John M. Caracappa, Lead Counsel
` Reg. No. 43,532
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` Lead Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that the foregoing
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`JOINT REQUEST TO FILE SETTLEMENT AGREEMENT AS BUSINESS
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`CONFIDENTIAL INFORMATION PURSUANT TO 35 U.S.C. § 317 AND 37
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`C.F.R. § 42.74(c) was served on April 9, 2018, via email directed to counsel of
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`record for the patent owner at the following:
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`John M. Caracappa
`Email: jcaracp@steptoe.com
`Thomas C. Yebernetsky
`Email: tyebernetsky@steptoe.com
`STEPTOE & JOHNSON LLP
`1330 Connecticut Ave., N.W.
`Washington, D.C. 20036
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`By: /Lauren K. Young/
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`Lauren K. Young
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`Litigation Legal Assistant
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`FINNEGAN, HENDERSON, FARABOW,
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`GARRETT & DUNNER, L.L.P.
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`Dated: April 9, 2018
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