UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`______________________
`
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`______________________
`
`PATENT OWNER’S MOTION TO SEAL
`
`
`
`
`
`
`
`
`
`
`
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`
`
`TABLE OF CONTENTS
`
`
`
`C.
`
`I.
`II.
`
`INTRODUCTION ........................................................................................... 1
`REASONS FOR THE REQUESTED RELIEF AND STATEMENT
`OF FACTS ....................................................................................................... 1
`A. Good Cause Exists for Sealing Confidential Information .................... 1
`Exhibits 2001-2007, 2013-2015: Patent Owner Technical
`B.
`Documents ............................................................................................. 2
`Exhibits 2008, 2009, and 2017: Patent Owner Employee
`Declarations ........................................................................................... 3
`Exhibit 2012: Declaration of Dean Garner ........................................... 3
`D.
`Exhibit 2020: Declaration of Dr. Shorya Awtar ................................... 4
`E.
`Patent Owner’s Response ...................................................................... 4
`F.
`III. CERTIFICATION OF NON-PUBLICATION ............................................... 5
`IV. CONCLUSION ................................................................................................ 5
`
`
`i
`
`
`
`I.
`
`INTRODUCTION
`Patent Owner (Ethicon) moves to seal in their entirety Exhibits 2001-2009,
`
`2012-2015, and 2017 pursuant to 37 C.F.R. §§ 42.14 and 42.54.
`
`Patent Owner moves to seal portions of Exhibit 2019 that rely on Exhibits
`
`2001-2007 and 2013-2015 pursuant to 37 C.F.R. §§ 42.14 and 42.54.
`
`Patent Owner also moves to seal portions of Patent Owner’s Response that
`
`rely on Exhibits 2001-2009, 2012-2015, 2017, and Ex. 2019 pursuant to 37 C.F.R.
`
`§§ 42.14 and 42.54.
`
`By agreement of the parties, Patent Owner also requests entry of the
`
`Proposed Protective Order (Attachment 1).1 Patent Owner has conferred with
`
`Petitioner (Intuitive), and the parties have stipulated to the Proposed Protective
`
`Order.
`
`II. REASONS FOR THE REQUESTED RELIEF AND STATEMENT OF
`FACTS
`A. Good Cause Exists for Sealing Confidential Information
`The Board will seal documents for good cause. See 37 C.F.R. § 42.54(a);
`
`see also Argentum Pharms. LLC v. Alcon Research, Ltd., Paper 27, 2 (2013). “The
`
`rules aim to strike a balance between the public’s interest in maintaining a
`
`
`1 Attachment 2 is a redline showing the differences between the proposed
`
`protective order and the PTAB default protective order.
`
`
`
`1
`
`
`
`complete and understandable file history and the parties’ interest in protecting truly
`
`sensitive information.” Office Patent Trial Practice Guide, 77 Fed. Reg. 48756,
`
`48760 (2012). The public’s interest in having access to confidential business
`
`information that is only indirectly related to patentability is “minimal.” Garmin v.
`
`Cuozzo, IPR2012-00001, Paper 36, 8-9 (2013) (granting a motion to seal an
`
`agreement relating to the “commercializ[ation]” of the patent-at-issue). Such
`
`documents should be subject to the Proposed Protective Order. See Attachment 1
`
`at 5-6 (“[I]nformation 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’ and shall be produced in a manner that
`
`maintains its confidentiality.”).
`
`B.
`
`Exhibits 2001-2007, 2013-2015: Patent Owner Technical
`Documents
`Exhibits 2001–2007 and 2013-2015 comprise technical documents of Patent
`
`
`
`Owner that contain confidential design information concerning surgical stapling
`
`technology. These exhibits detail in their entirety confidential and proprietary
`
`research and development information that, if publicly disclosed, would
`
`substantially harm Patent Owner’s competitive position in the surgical instrument
`
`industry and ongoing work directed to, inter alia, surgical staplers. For example,
`
`this information, if not sealed, would provide competitors with valuable
`
`
`
`
`
`2
`
`
`
`information regarding confidential research and development projects. Such
`
`information could also be used by a competitor to improve its products.
`
`C. Exhibits 2008, 2009, and 2017: Patent Owner Employee
`Declarations
`Exhibits 2008, 2009, and 2017 comprise declarations from employees of
`
`Patent Owner’s affiliate regarding the development of surgical stapling technology
`
`at Ethicon. These exhibits also describe the contents of Exhibits 2001-2007 and
`
`2013-2015, which comprise technical documents of Patent Owner containing
`
`confidential design information. Exhibits 2008, 2009, and 2017 provide further
`
`confidential and proprietary research and development information of Patent
`
`Owner that, if publicly disclosed, would substantially harm Patent Owner’s
`
`competitive position in the surgical instrument industry and ongoing work directed
`
`to, inter alia, surgical staplers. For example, this information, if not sealed, would
`
`provide competitors with valuable information regarding confidential research and
`
`development projects. Such information could also be used by a competitor to
`
`improve its products. Exhibits 2008, 2009, and 2017 also detail the process by
`
`which Ethicon develops instrument technology, which if disclosed, would provide
`
`competitors with valuable information regarding Ethicon’s internal processes.
`
`D. Exhibit 2012: Declaration of Dean Garner
`Exhibits 2012 is a declaration from a current employee of Patent Owner that
`
`describes and includes confidential employment files. This exhibit contains
`
`
`
`
`
`3
`
`
`
`confidential identifying and other personal information of employees. This exhibit
`
`further contains confidential business information of Patent Owner that if publicly
`
`disclosed, would provide competitors with valuable information regarding
`
`Ethicon’s internal processes.
`
`E.
`Exhibit 2019: Declaration of Dr. Shorya Awtar
`Exhibit 2019 is a declaration from Patent Owner’s expert witness, Dr.
`
`Shorya Awtar. Portions of Exhibit 2019 describe and include images of
`
`confidential and proprietary information from Exhibits 2001-2009 and 2013-2015.
`
`This confidential and proprietary research and development information of Patent
`
`Owner, if publicly disclosed, would substantially harm Patent Owner’s competitive
`
`position in the surgical instrument industry and ongoing work directed to, inter
`
`alia, surgical staplers. For example, this information, if not sealed, would provide
`
`competitors with valuable information regarding confidential research and
`
`development projects. Such information could also be used by a competitor to
`
`improve its products.
`
`F.
`Patent Owner’s Response
`Portions of Patent Owner’s Response describe and include images of
`
`confidential and proprietary information in Exhibits 2001-2009, 2013-2015, and
`
`2019. This confidential and proprietary research and development information of
`
`Patent Owner, if publicly disclosed, would substantially harm Patent Owner’s
`
`
`
`
`
`4
`
`
`
`competitive position in the surgical instrument industry and ongoing work directed
`
`to, inter alia, surgical staplers. For example, this information, if not sealed, would
`
`provide competitors with valuable information regarding confidential research and
`
`development projects. Such information could also be used by a competitor to
`
`improve its products.
`
`III. CERTIFICATION OF NON-PUBLICATION
`On Patent Owner’s behalf, the undersigned counsel certifies that, to the best
`
`of his knowledge, the sealed Exhibits 2001-2009, 2012-2015, and 2017, and sealed
`
`portions of Exhibit 2019 and Patent Owner’s Response have not been published or
`
`otherwise made public.
`
`IV. CONCLUSION
`Patent Owner respectfully requests that the Board grant its motion to seal in
`
`their entirety, Exhibits 2001-2009, 2012-2015, and 2017, and portions of Exhibit
`
`2019 and Patent Owner’s Response, and that the Board also enter the attached
`
`agreed upon Protective Order. If the Board is not inclined to grant the motion to
`
`seal due to some deficiency in this motion, Patent Owner respectfully requests
`
`leave to file another motion to seal to correct that deficiency, or in the alternative, a
`
`motion to expunge Ethicon’s confidential documents and information from the
`
`record.
`
`
`
`
`
`
`
`5
`
`
`
`Dated: January 14, 2020
`
`Respectfully submitted,
`
`
`
`/Anish R. Desai/
`Anish R. Desai
`Reg. No. 73,760
`WEIL, GOTSHAL & MANGES LLP
`767 Fifth Avenue
`New York, NY 10153
`T: 212-310-8730
`E: anish.desai@weil.com
`
`Counsel for Patent Owner
`
`
`
`
`
`
`6
`
`
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`
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`
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on January 14, 2020, a copy of PATENT OWNER’S
`
`MOTION TO SEAL and any accompanying exhibits were served by filing the
`
`documents through the PTAB’s E2E Filing System as well as delivering a copy via
`
`electronic mail upon the following:
`
`
`Steven R. Katz
`Joshua A. Griswold
`Kenneth W. Darby, Jr.
`John C. Phillips
`Ryan P. O’Connor
`FISH & RICHARDSON
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`katz@fr.com
`griswold@fr.com
`kdarby@fr.com
`phillips@fr.com
`oconnor@fr.com
`
`IPR11030-0052IP1@fr.com
`PTABInbound@fr.com
`
`
`
`
`
`/Timothy J. Andersen/
`Timothy J. Andersen
`Case Manager
`Weil, Gotshal & Manges LLP
`2001 M Street, N.W., Suite 600
`Washington, DC 20036
`202-682-7075
`timothy.andersen@weil.com
`
`
`
`
`
`
`
`
`
`
`
`
`ATTACHMENT 1
`
`ATTACHMENT 1
`
`
`
`ATTACHMENT 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`
`______________________
`
`
`STIPULATED PROTECTIVE ORDER
`
`
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`
`The parties have reached an agreement regarding the terms of a Protective
`
`Order that shall govern the treatment of confidential information submitted during
`
`the above captioned matter. The terms of the stipulated Protective Order are set
`
`forth below:
`
`1. Confidential information shall be clearly marked “PROTECTIVE
`
`ORDER MATERIAL.”
`
`2. Access to confidential information is limited to the following individuals
`
`who have executed the acknowledgment appended to this Order:
`
` (A) Party Representatives. Outside counsel of record for a party in
`
`the proceeding.
`
`(B) 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. The subject matter of
`
`this proceeding is surgical staplers.
`
` (C) 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
`
`
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`the Board and their clerical staff, other support personnel, court
`
`reporters, and other persons acting on behalf of the Office.
`
`(D) 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 who receives confidential information.
`
`3. 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 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
`
`
`
`3
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`to maintain the confidentiality of information received that is
`
`designated as confidential; and
`
`(D) Limiting the copying of confidential information to a reasonable
`
`number of copies needed for conduct of the proceeding and
`
`maintaining a record of the locations of such copies.
`
`4. 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
`
`along with a Motion to Seal. The Motion to Seal should provide
`
`a non-confidential description of the nature of the confidential
`
`information that is under seal, and set forth the reasons why the
`
`information is confidential and should not be made available to
`
`the public. A party may challenge the confidentiality of the
`
`information by opposing the Motion to Seal. The submission
`
`shall be treated as confidential and remain under seal, unless the
`
`Board determines that the documents or information do not
`
`qualify for confidential treatment. The information shall remain
`
`under seal unless the Board determines that some or all of the
`
`information does not qualify for confidential treatment.
`
`
`
`4
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`(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. A party may challenge the
`
`confidentiality of the information by opposing the Motion to
`
`Seal. The non-confidential 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 the Board determines that some or all of the
`
`redacted information does not qualify for confidential
`
`treatment.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`Documents (including deposition transcripts) and other information
`
`designated as confidential that are disclosed to another party during
`
`discovery or other proceedings before the Board shall be clearly
`
`
`
`5
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`marked as “PROTECTIVE ORDER MATERIAL” and shall be
`
`produced in a manner that maintains its confidentiality.
`
`5. Within 60 days after the final disposition of this action, including the
`
`exhaustion of all appeals and motions, each party receiving confidential
`
`information must return, or certify the destruction of, all copies of the confidential
`
`information to the producing party.
`
`
`
`
`
`
`
`6
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`______________________
`
`
`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
`
`
`
`7
`
`
`
`IPR2019-00880
`Patent 7,490,749
`
`Eastern District of Virginia for purposes of enforcing the terms of the Protective
`
`Order and providing remedies for its breach.
`
`
`
`_______________________________
`[Signature]
`
`
`
`
`
`
`
`
`
`8
`
`
`
`ATTACHMENT 2
`
`ATTACHMENT 2
`
`
`
`ATTACHMENT 2
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`
`______________________
`
`
`DEFAULTSTIPULATED PROTECTIVE ORDER
`
`
`
`
`
`
`
`This standing protective order governs
`
`The parties have reached an
`
`agreement regarding the terms of a Protective Order that shall govern the treatment
`
`and filing of confidential information, including documents and testimony.
`
`submitted during the above captioned matter. The terms of the stipulated Protective
`
`Order are set forth below:
`
`1. Confidential information shall be clearly marked “PROTECTIVE
`
`ORDER MATERIAL.”
`
`2. Access to confidential information is limited to the following individuals
`
`who have executed the acknowledgment appended to this order: Order:
`
` (A) Parties. Persons who are owners of a patent involved in the
`
`proceeding and other persons who are named parties to the
`
`proceeding.
`
`(B) Party Representatives. RepresentativesOutside counsel of record
`
`for a party in the proceeding.
`
`(CB) 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. The subject
`
`matter of this proceeding is surgical staplers.
`
`(D) In-house counsel. In-house counsel of a party.
`
`
`
`
`
`(E) Other Employees of a Party. Employees, consultants 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 (C) 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.
`
`(GD) 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
`
`3
`
`
`
`informed of the terms and requirements of the Protective Order by the
`
`person they are supporting who receives confidential information.
`
`3. 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 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 of copies needed for conduct of the proceeding and
`
`maintaining a record of the locations of such copies.
`
`4. Persons receiving confidential information shall use the following
`
`procedures to maintain the confidentiality of the information:
`
`4
`
`
`
`(A) Documents and Information Filed With the Board.
`
`(i) A party may file documents or information with the Board
`
`under seal, together withalong with a Motion to Seal. The
`
`Motion to Seal should provide a non-confidential description of
`
`the nature of the confidential information that is under seal, and
`
`set forth the reasons why the information is confidential and
`
`should not be made available to the public. A party may
`
`challenge the confidentiality of the information by opposing the
`
`Motion to Seal. 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. The information shall remain under seal unless the
`
`Board determines that some or all of the information does not
`
`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
`
`5
`
`
`
`from the non-confidential version is confidential and should not
`
`be made available to the public. A party may challenge the
`
`confidentiality of the information by opposing the Motion to
`
`Seal. The non-confidential 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.
`
`(B) Documents and Information Exchanged Among the Parties.
`
`InformationDocuments (including deposition transcripts) and other
`
`information designated as confidential that isare disclosed to another
`
`party during discovery or other proceedings before the Board shall be
`
`clearly marked as “PROTECTIVE ORDER MATERIAL” and shall
`
`be produced in a manner that maintains its confidentiality.
`
`5. Within 60 days after the final disposition of this action, including the
`
`exhaustion of all appeals and motions, each party receiving confidential
`
`6
`
`
`
`information must return, or certify the destruction of, all copies of the confidential
`
`information to the producing party.
`
`7
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTUITIVE SURGICAL, INC.,
`Petitioner,
`
`v.
`
`ETHICON LLC,
`Patent Owner.
`
`______________________
`
`IPR2019-00880
`U.S. Patent No. 7,490,749
`______________________
`
`Standard 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
`
`8
`
`
`
`Eastern District of Virginia for purposes of enforcing the terms of the Protective
`
`Order and providing remedies for its breach.
`
`
`
`
`_______________________________
`[Signature]
`
`
`
`
`
`
`
`9
`
`
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