`By: Brent Bumgardner
`Registration No. 48,476
`NELSON BUMGARDNER
`CONROY P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3486
`Email: brent@nelbum.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`ROKU, INC.,
`
`Petitioner,
`
`v.
`
`FLEXIWORLD TECHNOLOGIES, INC.,
`
`Patent Owner.
`
`________________
`
`Case IPR2022-01269
`
`U.S. Patent No. 7,944,577
`________________
`
`
`JOINT REQUEST FOR SETTLEMENT AGREEMENT TO BE TREATED
`AS BUSINESS CONFIDENTIAL INFORMATION AND BE KEPT
`SEPARATE PURSUANT TO 35 U.S.C. § 317(b) AND 37 C.F.R. § 42.74
`
`
`
`
`
`
`
`
`
`
`UPDATED EXHIBIT LIST
`Description
`
`Settlement Agreement
`
`Exhibit
`
`2001
`
`
`
`Joint Request for Settlement Agreement
`To Be Treated As Business Confidential
`Information
`
`
`
`i
`
`
`
`Pursuant to 35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), Petitioner Roku, Inc.
`
`(“Roku”) and Patent Owner Flexiworld Technologies, Inc. (“Flexiworld”) jointly
`
`request that their Patent License Agreement (“Agreement”), filed concurrently
`
`herewith as Exhibit 2001, be treated as business confidential information and be kept
`
`separate from the file of the challenged patent, U.S. Patent No. 7,944,577 (“the ’577
`
`patent”), and the above-captioned inter partes review proceeding in accordance with
`
`35 U.S.C. § 317(b) and 37 C.F.R. § 42.74(c), and only made available to Federal
`
`Government agencies upon written request or to any other person upon written
`
`request and a showing of good cause. The Board authorized the parties to file this
`
`joint request in an e-mail to the parties dated October 18, 2022. The Agreement is
`
`confidential and not publicly available. The Agreement contains business
`
`confidential information that could harm the parties’ business interests if disclosed
`
`to the public. Accordingly, the Agreement should be maintained as confidential and
`
`kept separate from the files of the ’577 patent and the above-captioned inter partes
`
`review proceeding.
`
`Based on this joint request, the Agreement has been filed with the Board for
`
`access by the “Parties and Board Only.”
`
`
`
`
`
`Joint Request for Settlement Agreement
`To Be Treated As Business Confidential
`Information
`
`
`
`1
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`By:
`
`
`
`/Brent Bumgardner/
`Brent Bumgardner
`Registration No. 48,476
`NELSON BUMGARDNER
`CONROY P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3486
`Email: brent@nelbum.com
`Attorney for Patent Owner
`
`/Patrick J. McKeever/
`Patrick J. McKeever
`Registration No. 66,019
`PERKINS COIE LLP
`11452 El Camino Real, Suite 300
`San Diego, CA 92130
`Telephone: (858) 720-5700
`Email: PMcKeever@perkinscoie.com
`Attorney for Petitioner
`
`Dated: October 27, 2022
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: October 27, 2022
`
`
`
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`
`
`
`
`
`
`
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`
`
`
`
`
`
`Joint Request for Settlement Agreement
`To Be Treated As Business Confidential
`Information
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that the foregoing Joint Request was served October
`
`27, 2022, to Lead and Back-up Counsel for Petitioner at the service address provided
`
`in Petitioner’s Mandatory Notices:
`
`Email:
`
`mckeever-ptab@perkinscoie.com
`
`Bombach-ptab@perkinscoie.com
`
`Day-ptab@perkinscoie.com
`
`Bernstein-ptab@perkinscoie.com
`
`Schunter-ptab@perkinscoie.com
`
`PerkinsServiceRoku-FlexiworldIPRs@perkinscoie.com
`
`Dated: October 27, 2022
`
`
`
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`
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`
`
`
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`
`
`
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`By:
`
`
`
`/Brent Bumgardner/
`Brent Bumgardner
`Registration No. 48,476
`NELSON BUMGARDNER
`CONROY P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
`Telephone: (817) 377-3486
`Email: brent@nelbum.com
`Attorney for Patent Owner
`
`Joint Request for Settlement Agreement
`To Be Treated As Business Confidential
`Information
`
`
`
`3
`
`
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