IPR2017-01977
`U.S. Patent No. 8,755,376
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`JOINT MOTION FOR ENTRY
`OF PROTECTIVE ORDER
`
`
`U.S. Patent No. 8,755,376
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`JOINT MOTION FOR ENTRY
`OF PROTECTIVE ORDER
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`
`I.
`
`Statement of Precise Relied Requested
`Pursuant to 37 C.F.R. § 42.54(a) and the Board’s May 24, 2018 Order
`
`Authorizing Motion for Discovery (Paper No. 17), Patent Owner and Petitioner
`
`move for entry of a protective order in the form appended hereto as Exhibit A.1
`
`II.
`
`Factual Background
`On May 23, 2018, the Board and the parties conducted a telephonic hearing
`
`regarding Patent Owner’s request to seek discovery. Petitioner asserts that the
`
`requested materials contain confidential information that requires protection beyond
`
`the Default Protective Order. On May 24, 2018, the Board issued an Order directing
`
`the parties to meet and confer on a mutually-agreeable protective order and to file a
`
`motion for entry of protective order by May 25, 2018. (Paper No. 17.)
`
`The parties have met and conferred as directed by the Board and have agreed
`
`on the language modifying the Default Protective Order and now jointly move for
`
`entry of the modified protective order attached as Appendix A.
`
`1 A redline of the proposed Protective Order that shows changes to the PTAB’s
`default protective order (published in Appendix B of the Office Patent Trial Practice
`Guide, 77 Fed. Reg. 48756, 48769-71 (Aug. 14, 2012) (the “Default Protective
`Order”), is appended here as Appendix B.
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`III. Argument
`The parties propose adding an additional tier of confidentiality for attorneys’
`
`eyes only information. (Compare Appx. A at ¶¶ 1-3, 5.B. and Appx. B at ¶¶ 1-2,
`
`4.B.) The Board may add a tier of “attorneys’ eyes only” confidentiality to ensure
`
`that confidential party information is not disclosed in a way that could result in
`
`putting the disclosing party at an unfair competitive disadvantage or give the
`
`receiving party an unfair competitive advantage. See, e.g., Baker Hughes Inc. v.
`
`Lubrizol Specialty Prods., TPR2016-00734, Paper 40 (Jan. 6, 2017); Daicel Corp.
`
`v. Celanese Int’l Corp., IPR2015-00170, Paper 70 (Jan 20, 2016); Greene’s Energy
`
`Grp., LLC, Inc. v. Oil States Energy Servs., LLC, 1PR2014-00216, Paper 27 (Sept.
`
`23, 2014); see also, e.g., In re Deutsche Bank Trust Co. Americas, 605 F.3d 1373,
`
`1378 (Fed. Cir. 2010) (“The purpose of a protective order is to prevent inadvertent
`
`compromise of confidential information.”). In this case, an “attorneys’ eyes only”
`
`designation is appropriate because the parties are competitors and the additional
`
`confidentiality tier protects against disclosure of sensitive financial and technical
`
`information to employees of the parties. For the same reason—to protect against
`
`disclosure of competitively sensitive information—the parties propose adjustments
`
`to the definitions of people who may have access to certain protected information.
`
`(Compare Appx. A at ¶¶ 2.(A.), (B.), (E.) and Appx. B at ¶¶ 2.(A.), (B.), (E.).)
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`The parties further agree to the addition of a provision that allows a party to
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`submit mutually-agreeable redactions to confidential materials to redact sensitive
`
`information that is not relevant to the case. (Compare Appx. A at ¶ 5.A.(ii) and
`
`Appx. B at ¶ 4.A.(ii).) Petitioner contends that the modification is appropriate in
`
`this case because the mutually-agreeable redactions help reduce the risk of public
`
`disclosure of irrelevant confidential information if the document were to ultimately
`
`become public inadvertently or intentionally and because it helps clarify that such
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`redactions are allowable notwithstanding the immediately proceeding provision that
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`might otherwise be construed to limit redactions or construed to imply that non-
`
`redacted information is non-confidential.
`
`The parties further agree to a provision that requires a receiving party to
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`cooperate with a producing party who seeks to keep confidential information sealed
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`in the event that the Board indicates that it intends to unseal the producing party’s
`
`material. (Appx. A at ¶ 6.) The provision is meant to clarify the process by which
`
`a party can seek to keep sealed competitively sensitive information submitted in this
`
`case. Similarly, the parties agree to a modification to ¶ 4.A. of the Default Protective
`
`Order to delete the “sua sponte” language to accommodate the parties’ proposed
`
`process set forth in Appx. A at ¶ 6.
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`U.S. Patent No. 8,755,376
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`Finally, the parties further agree to a provision to clarify the ability to make
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`copies of information designated by another party under the Proposed Protective
`
`Order. Specifically, the parties agree to modify the language of the Default
`
`Protective Order that reads “a reasonable number of copies” to “only those copies
`
`needed for.” (Compare Appx. A at ¶ 4(D) and Appx. B at ¶ 3(D).) Petitioner
`
`contends that the modification is appropriate to clarify the scope of the provision.
`
`IV. Certification of Conference with Opposing Party Pursuant to 37 C.F.R.
`§ 42.54
`Patent Owner, in good faith, met and conferred with Petitioner regarding the
`
`entry of the Proposed Protective Order and the motion to seal. Petitioner agrees to
`
`the entry of the Proposed Protective Order.
`
`WHEREFORE, the parties respectfully request that the Board enter a
`
`Protective Order in the form appended hereto as Appendix A.
`
`Date: May 25, 2018
`
`Respectfully submitted,
`
`
`
`/Wayne O. Stacy/
`Wayne O. Stacy
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the 25th day
`
`of May 2018, a complete and entire copy of this Petitioners' Motion for Entry of
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`Protective Order was provided via the Patent Trial and Appeal Board End to End
`
`(PTAB E2E) System as well as delivering a copy via email on the following counsel
`
`for Petitioner at:
`
`PETITIONER:
`
`Jesse J. Camacho
`Elena K. McFarland
`Christine Guastello
`Mary J. Peal
`SHOOK, HARDY & BACON LLP
`jcamacho@shb.com
`emcfarland@shb.com
`cguastello@shb.com
`mpeal@shb.com
`
`Date: May 25, 2018
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Lead Counsel
`
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`IPR2017-01977
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`IPR2017-01977
`U.S. Patent No. 8,755,376
`US. Patent No. 8,755,376
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`APPENDIX A
`
`APPENDIX A
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`2
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`[PROPOSED] STIPULATED PROTECTIVE ORDER
`
`3
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`Protective Order
`
`This protective order governs the treatment and filing of confidential
`
`information, including documents and testimony.
`
`1. Confidential information shall be clearly marked PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL.”
`
`2. Access to confidential information marked as “PROTECTIVE ORDER
`
`MATERIAL” is limited to the following individuals who have executed the
`
`Acknowledgment appended to this order:
`
`(A) Parties. Designated officers, directors, and employees of the Receiving
`
`Party to whom disclosure is reasonably necessary;
`
`(B) Outside Counsel. Outside counsel of record for a party in the Proceeding
`
`(and they shall have such access without the requirement to sign the
`
`Acknowledgement).
`
`(C) Experts. Retained experts of a party in the Proceeding who further
`
`certify in the Acknowledgement that they are not a competitor to any party,
`
`or a consultant for, or employed by, such a competitor with respect to the
`
`subject matter of the proceeding.
`
`(D) In-house counsel. In-house counsel of a party.
`
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`U.S. Patent No. 8,755,376
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`(E) Other Persons Associated With a Party. Consultants or other persons
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`performing work for a party, other than in-house counsel and in-house
`
`counsel’s support staff, who sign the Acknowledgement shall be extended
`
`access to confidential information only upon agreement of the parties or by
`
`order of the Board upon a motion brought by the party seeking to disclose
`
`confidential information to that person. The party opposing disclosure to that
`
`person shall have the burden of proving that such person should be restricted
`
`from access to confidential information.
`
`(F) The Office. Employees and representatives of the Office who have a
`
`need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees and
`
`representatives shall include the Director, members of the Board and their
`
`clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
`
`(G) Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons who are
`
`reasonably necessary to assist those persons in the proceeding shall not be
`
`required to sign an Acknowledgement, but shall be informed of the terms
`
`and requirements of the Protective Order by the person they are supporting
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`who receives confidential information.
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`3. A party or non-party may designate certain confidential material as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL,” by
`
`marking it as such, provided that the party or non-party has a good faith basis to
`
`believe that such information is particularly sensitive and a substantial competitive
`
`harm might result if it were made public. Access to any material marked as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL” is
`
`limited to the following individuals who have executed the acknowledgment
`
`appended to this order: outside counsel of record for a party in this IPR
`
`Proceeding, and only the individuals identified above in 2(C), 2(F), and 2(G).
`
`Nothing in this Order, or the parties’ consent thereto, should be construed to
`
`supersede or replace any other confidentiality obligations held by a disclosing
`
`party under a protective order entered by another tribunal including the
`
`International Trade Commission or any U.S. district court.
`
`4. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
`
`(A) Maintaining such information in a secure location to which persons not
`
`authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality of the
`
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`information, which efforts shall be no less rigorous than those the recipient
`
`uses to maintain the confidentiality of information not received from the
`
`disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access to the
`
`confidential information understand and abide by the obligation to maintain
`
`the confidentiality of information received that is designated as confidential;
`
`and
`
`(D) Limiting the copying of confidential information to only those copies
`
`needed for conduct of the proceeding and maintaining a record of the
`
`locations of such copies.
`
`5. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board under
`
`seal, together with a non-confidential description of the nature of the
`
`confidential information that is under seal and the reasons why the
`
`information is confidential and should not be made available to the
`
`public. The submission shall be treated as confidential and remain
`
`under seal, unless, upon motion of a party and after a hearing on the
`
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`IPR2017-01977
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`issue the Board determines that the documents or information do not
`
`to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`locations of information that has been redacted. The confidential
`
`version of the submission shall be filed under seal. The redacted
`
`information shall remain under seal unless, upon motion of a party
`
`and after a hearing on the issue the Board determines that some or all
`
`of the redacted information does not qualify for confidential
`
`treatment. Notwithstanding the foregoing, a party may submit
`
`versions of documents containing redactions made by agreement in
`
`which the unredacted material is confidential and to be afforded the
`
`protections of this order but the redacted material is agreed to by the
`
`parties as not relevant, and in that situation, an unredacted version of
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`the document does not need to be submitted.
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`(B) Documents and Information Exchanged Among the Parties.
`
`Information designated as confidential that is disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” or
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” and shall be produced in a manner that maintains its
`
`confidentiality.
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`6. If the producing party seeks to keep “PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” sealed, the other party will cooperate in those efforts, including by
`
`not opposing a request by the producing party to keep the documents sealed.
`
`“Acknowledgement” of Protective Order. The following form may be used to
`
`acknowledge a protective order and gain access to information covered by the
`
`protective order:
`
`Dated: May 25, 2018
`
`
`
`Respectfully submitted,
`
`
`
`/Wayne O. Stacy/
`Wayne O. Stacy
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`ACKNOWLEDGEMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
`
`10
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`Acknowledgment for Access to Protective Order Material
`
`I ________________, affirm that I have read the Protective Order; that I will
`
`abide by its terms; that I will use the confidential information only in connection
`
`with this proceeding and for no other purpose; that I will only allow access to support
`
`staff who are reasonably necessary to assist me in this proceeding; that prior to any
`
`disclosure to such support staff I informed or will inform them of the requirements
`
`of the Protective Order; that I am personally responsible for the requirements of the
`
`terms of the Protective Order and I agree to submit to the jurisdiction of the Office
`
`and the United States District Court for the Eastern District of Virginia for purposes
`
`of enforcing the terms of the Protective Order and providing remedies for its breach.
`
`By: _______________________
`
`Date:________________________
`
`11
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`IPR2017-01977
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`US. Patent No. 8,755,376
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`APPENDIX B
`
`APPENDIX B
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`12
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`[PROPOSED] STIPULATED PROTECTIVE ORDER
`
`13
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`
`IPR2017-01977
`U.S. Patent No. 8,755,376
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`Standing Protective Order
`
`This standing protective order governs the treatment and filing of
`
`confidential information, including documents and testimony.
`
`1. Confidential information shall be clearly marked PROTECTIVE ORDER
`
`MATERIAL.”” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL.”
`
`2. Access to confidential information marked as “PROTECTIVE ORDER
`
`MATERIAL” is limited to the following individuals who have executed the
`
`acknowledgmentAcknowledgment appended to this order:
`
`(A) Parties. Persons who are ownersDesignated officers, directors,
`
`and employees of a patent involved in the proceeding and other persons who
`
`are named parties Receiving Party to the proceeding.whom disclosure is
`
`reasonably necessary;
`
`(B) Party Representatives. RepresentativesOutside Counsel. Outside
`
`counsel of record for a party in the proceeding.Proceeding (and they shall
`
`have such access without the requirement to sign the Acknowledgement).
`
`(C) Experts. Retained experts of a party in the proceedingProceeding
`
`who further certify in the Acknowledgement that they are not a competitor
`
`to any party, or a consultant for, or employed by, such a competitor with
`
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`respect to the subject matter of the proceeding.
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`(D) In-house counsel. In-house counsel of a party.
`
`(E) Other Employees ofPersons Associated With a Party. Employees,
`
`consultantsConsultants or other persons performing work for a party, other
`
`than in-house counsel and in-house counsel’s support staff, who sign the
`
`Acknowledgement shall be extended access to confidential information only
`
`upon agreement of the parties or by order of the Board upon a motion
`
`brought by the party seeking to disclose confidential information to that
`
`person. The party opposing disclosure to that person shall have the burden of
`
`proving that such person should be restricted from access to confidential
`
`information.
`
`(F) The Office. Employees and representatives of the Office who have
`
`a need for access to the confidential information shall have such access
`
`without the requirement to sign an Acknowledgement. Such employees and
`
`representatives shall include the Director, members of the Board and their
`
`clerical staff, other support personnel, court reporters, and other persons
`
`acting on behalf of the Office.
`
`(G) Support Personnel. Administrative assistants, clerical staff, court
`
`reporters and other support personnel of the foregoing persons who are
`
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`reasonably necessary to assist those persons in the proceeding shall not be
`
`required to sign an Acknowledgement, but shall be informed of the terms
`
`and requirements of the Protective Order by the person they are supporting
`
`who receives confidential information.
`
`3. A party or non-party may designate certain confidential material as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL,” by
`
`marking it as such, provided that the party or non-party has a good faith basis to
`
`believe that such information is particularly sensitive and a substantial competitive
`
`harm might result if it were made public. Access to any material marked as
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY MATERIAL” is
`
`limited to the following individuals who have executed the acknowledgment
`
`appended to this order: outside counsel of record for a party in this IPR
`
`Proceeding, and only the individuals identified above in 2(C), 2(F), and 2(G).
`
`Nothing in this Order, or the parties’ consent thereto, should be construed to
`
`supersede or replace any other confidentiality obligations held by a disclosing
`
`party under a protective order entered by another tribunal including the
`
`International Trade Commission or any U.S. district court.
`
`4. Persons receiving confidential information shall use reasonable efforts to
`
`maintain the confidentiality of the information, including:
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`IPR2017-01977
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`(A) Maintaining such information in a secure location to which
`
`persons not authorized to receive the information shall not have access;
`
`(B) Otherwise using reasonable efforts to maintain the confidentiality
`
`of the information, which efforts shall be no less rigorous than those the
`
`recipient uses to maintain the confidentiality of information not received
`
`from the disclosing party;
`
`(C) Ensuring that support personnel of the recipient who have access
`
`to the confidential information understand and abide by the obligation to
`
`maintain the confidentiality of information received that is designated as
`
`confidential; and
`
`(D) Limiting the copying of confidential information to a reasonable
`
`number ofonly those copies needed for conduct of the proceeding and
`
`maintaining a record of the locations of such copies.
`
`45. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board
`
`under seal, together with a non-confidential description of the nature
`
`of the confidential information that is under seal and the reasons why
`
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`the information is confidential and should not be made available to
`
`the public. The submission shall be treated as confidential and remain
`
`under seal, unless, upon motion of a party and after a hearing on the
`
`issue, or sua sponte, the Board determines that the documents or
`
`information do not to qualify for confidential treatment.
`
`(ii) Where confidentiality is alleged as to some but not all of the
`
`information submitted to the Board, the submitting party shall file
`
`confidential and non-confidential versions of its submission, together
`
`with a Motion to Seal the confidential version setting forth the reasons
`
`why the information redacted from the non-confidential version is
`
`confidential and should not be made available to the public. The
`
`nonconfidential version of the submission shall clearly indicate the
`
`locations of information that has been redacted. The confidential
`
`version of the submission shall be filed under seal. The redacted
`
`information shall remain under seal unless, upon motion of a party
`
`and after a hearing on the issue, or sua sponte, the Board determines
`
`that some or all of the redacted information does not qualify for
`
`confidential treatment. Notwithstanding the foregoing, a party may
`
`submit versions of documents containing redactions made by
`
`18
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`IPR2017-01977
`U.S. Patent No. 8,755,376
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`agreement in which the unredacted material is confidential and to be
`
`afforded the protections of this order but the redacted material is
`
`agreed to by the parties as not relevant, and in that situation, an
`
`unredacted version of the document does not need to be submitted.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`Information designated as confidential that is disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” or
`
`“HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” and shall be produced in a manner that maintains its
`
`confidentiality.
`
`Standard 6. If the producing party seeks to keep “PROTECTIVE ORDER
`
`MATERIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES ONLY
`
`MATERIAL” sealed, the other party will cooperate in those efforts, including by
`
`not opposing a request by the producing party to keep the documents sealed.
`
`“Acknowledgement” of Protective Order. The following form may be used
`
`to acknowledge a protective order and gain access to information covered by the
`
`protective order:
`
`19
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`
`Dated: May 25, 2018
`
`
`
`Respectfully submitted,
`
`
`
`/Wayne O. Stacy/
`Wayne O. Stacy
`
`Reg. No. 67,771
`
`COUNSEL FOR PATENT OWNER
`TWILIO INC.
`
`
`/Jesse Camacho/
`Jesse Camacho
`Reg. No. 51,258
`COUNSEL FOR PETITIONER
`TELESIGN CORPORATION
`
`20
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`TELESIGN CORPORATION
`Petitioner,
`
`v.
`
`TWILIO INC.
`Petitioner
`
`––––––––––
`
`Case IPR2017-01977
`Patent 8,755,376
`
`––––––––––
`
`ACKNOWLEDGEMENT FOR ACCESS
`TO PROTECTIVE ORDER MATERIAL
`
`21
`
`
`
`IPR2017-01977
`U.S. Patent No. 8,755,376
`
`Acknowledgment for Access to Protective Order Material
`
`I ________________, affirm that I have read the Protective Order; that I will
`
`abide by its terms; that I will use the confidential information only in connection
`
`with this proceeding and for no other purpose; that I will only allow access to
`
`support staff who are reasonably necessary to assist me in this proceeding; that
`
`prior to any disclosure to such support staff I informed or will inform them of the
`
`requirements of the Protective Order; that I am personally responsible for the
`
`requirements of the terms of the Protective Order and I agree to submit to the
`
`jurisdiction of the Office and the United States District Court for the Eastern
`
`District of Virginia for purposes of enforcing the terms of the Protective Order and
`
`providing remedies for its breach.
`
`By: _______________________
`
`Date: ________________________
`
`22
`
`
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