From:
`To:
`Cc:
`Subject:
`Date:
`
`Trials
`Stein, Alexander B.; Trials
`Heard, Preston; Moyles, Lisa; Rockman, J; Train, Tyler; Herman, Barry; 697 Patent-PGR-Service; Ney, Angela
`RE: PGR2021-00097: Request for Authorization to file Motion to Seal
`Thursday, April 28, 2022 10:59:08 AM
`
`Counsel,
`To protect third-party confidential information, the availability designations for Exhibits 2032,
`2033, and 2034 (as filed) have been changed from “Public” to “Parties and Board.”
`
`We authorize Petitioner to file a motion to seal these three exhibits out of time. See 37 C.F.R. §
`42.14(b) (“A party intending a document or thing to be sealed shall file a motion to seal
`concurrent with the filing of the document or thing to be sealed.”). As discussed below, with the
`motion to seal, publicly proposed redacted versions of these Exhibits should be filed.
`
`Thank you,
`
`Maria King
`Deputy Chief Clerk for Trials
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`703-756-1288
`
`
`
`
`From: Stein, Alexander B. <alexander.stein@morganlewis.com>
`Sent: Wednesday, April 27, 2022 6:28 PM
`To: Trials <Trials@USPTO.GOV>
`Cc: Heard, Preston <Preston.Heard@wbd-us.com>; Moyles, Lisa <LMoyles@moylesip.com>;
`Rockman, J <JRockman@moylesip.com>; Train, Tyler <Tyler.Train@wbd-us.com>; Herman, Barry
`<Barry.Herman@wbd-us.com>; 697 Patent-PGR-Service <697Patent-PGR-
`Service@morganlewis.com>; Ney, Angela <Angela.Ney@wbd-us.com>
`Subject: PGR2021-00097: Request for Authorization to file Motion to Seal
`
`CAUTION: This email has originated from a source outside of USPTO. PLEASE CONSIDER THE SOURCE before
`responding, clicking on links, or opening attachments.
`
`Your Honors,
`
`The deposition transcripts filed as Exhibits 2032, 2033, and 2034 in PGR2021-00097 each discuss aspects of
`Schlumberger-designated confidential Exhibits 1032 or 1041. See Ex. 2034 at 128:1-129:8 (discussing Ex. 1032); Ex.
`2032 at 18:5-19:9; 153:10-155:7; 159:9-164:19 (discussing Ex. 1041); and Ex. 2033 at 205:14-208:16; 214:1-224:10
`(discussing Ex. 1032). Your Honors previously granted motions to seal Exhibits 1032 and 1041. See Papers 15 and
`29.
`
`PGR2021-00097
`
`1
`
`Ex. 3009
`
`

`

`In view of the above, Petitioners now request authorization to file a motion to seal Exhibits 2032, 2033, and 2034
`and to use redacted versions as the public versions of these deposition transcripts (the redacted portions would be
`the citations provided above).
`
`The parties have discussed this request and Patent Owner’s counsel (copied here) indicated that it does not oppose
`the requested motion to seal.
`
`Best,
`
`
`
`-Alex
`
`
`
`Alexander B. Stein
`
`Morgan, Lewis & Bockius LLP (Silicon Valley Office)
`
`+1.650.843.7278 | Assistant S. Lata Olivier: +1.650.843.7898
`
`PGR2021-00097
`
`2
`
`Ex. 3009
`
`