New Pacer--BARCO’S ADMINISTRATIVE MOTION FOR A SEALING ORDER

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
BARCO N.V., a Belgian corporation
Plaintiff,
v.
TECHNOLOGY PROPERTIES LTD.,
PATRIOT SCIENTIFIC CORP., and
ALLIACENSE LTD.,
Defendants.
Case No. C 08 05398 JW

BARCO’S ADMINISTRATIVE MOTION FOR A SEALING ORDER

Pursuant to Civil Local Rule 7-11 and 79-5, Barco hereby moves for an administrative
order sealing Barco’s Motion to Strike Portions of TPL’s Infringement Contentions (the “Motion”)
and the following exhibits to its concurrently-filed Motion:
Exhibit Description
Exhibit D-1 Product Report for BARCO JPEG 2000 ENCODER/DECODER BOARD
DCPB-2000 – Reexamined ‘336 Patent (PIC00001596-1634)
Exhibit D-2 Product Report for BARCO JPEG 2000 ENCODER/DECODER BOARD
DCPB-2000 Reexamined ‘336 Patent (PIC00001635-1673)
Exhibit D-3 Product Report for BARCO PROJECTOR ICON H400 - Reexamined ‘336
Patent (PIC00012499-12565)
Exhibit D-4 Product Report for BARCO PROJECTOR SIM 5R - Reexamined ‘336 Patent
(PIC00012566-12632)
Exhibit D-5 Product Report for BARCO PROJECTOR SLM R12+ - Reexamined ‘336
Patent (PIC00012633-12688)
Exhibit D-6 Product Report for BARCO MEDIA SERVER AXON - Reexamined ‘336
Patent (PIC00001809-1870)
Exhibit D-7 Product Report for BARCO LED DISPLAY DIGITIZER DX-700 -
Reexamined ‘336 Patent (PIC00001871-1924)
Exhibit D-8 Product Report for BARCO PROJECTOR RLM R6+ - Reexamined ‘336
Patent (PIC00012813-12868)
Exhibit D-9 Product Report for BARCO PROJECTOR ICON H500/H250 – Reexamined
‘336 Patent (PIC00012869-12934)
Exhibit D-10 Product Report for BARCO PROJECTOR ID R600+ - Reexamined ‘336
Patent (PIC00012935-13000)
Exhibit D-11 Product Report for BARCO LIGHTING CONSOLE HOG IPC – Reexamined
‘336 Patent (PIC0002061-2104)
Exhibit E-1 Product Report for BARCO PROJECTOR ICON H400 – Reexamined ‘749
patent (PIC00012757-12784)
Exhibit E-2 Product Report for BARCO PROJECTOR SIM 5R Reexamined ‘749 patent
(PIC00012785-12812)
Exhibit E-3 Product Report for BARCO PROJECTOR ICON H500/H250 – Reexamined
‘749 Patent (PIC00013067-13093)
Exhibit E-4 Product Report for BARCO PROJECTOR ID R600+ - Reexamined ‘749
Patent (PIC00013094-13120)
Exhibit F-1 Product Report for BARCO PROJECTOR ICON H400 – Reexamined ‘890
Patent (PIC00012689-12722)
Exhibit F-2 Product Report for BARCO PROJECTOR SIM 5R Reexamined ‘890 Patent
(PIC00012723-12756)
Exhibit F-3 Product Report for BARCO PROJECTOR ICON H500/H250 – Reexamined
‘890 Patent (PIC00013001-13033)
Exhibit F-4 Product Report for BARCO PROJECTOR ID R600+ - Reexamined ‘890
Patent (PIC00013034-13066)
Exhibit G-1 Highly Confidential Texas Instruments Compendium To Defendants’
Amended Infringement Contentions, October 11, 2011, (PIC00012461-12498)
The Motion and above-listed exhibits are being lodged with the Clerk in a sealed envelope.
The Motion include information that has been marked “confidential unpublished work” or
“Confidential – Attorneys' Eyes Only” by Defendants. The above-listed exhibits have also been
marked “confidential unpublished work” or “Confidential – Attorneys' Eyes Only” by Defendants.
Pursuant to the protective order in this case, documents marked “confidential” must be filed under
seal with the Court, unless such designation is withdrawn by Defendants.
Because these documents were designated “confidential” by Defendants, Defendants are
required under Civil Local Rule 79-5(d) to file with the Court and serve a declaration establishing
that the designated information is sealable within five days hereafter, and must lodge and serve a
narrowly tailored proposed sealing order, or must withdraw the designation of confidentiality.
Civil Local Rule 79-5(d). If Defendants do not file its responsive declaration as required, the
documents lodged with the Clerk are to be made part of the public record. Id.
Dated: December 9, 2011 BAKER & McKENZIE LLP
By: s/ Edward K. Runyan
Edward K. Runyan
Daniel J. O’Connor
Tod L. Gamlen
Attorneys for Plaintiff Barco N.V.

PROOF OF SERVICE CASE NO. C 08-05398 JF

I, Edward K. Runyan, declare I reside in the State of Illinois, over the age of eighteen years,
and not a party to the within action; my business address is Baker & McKenzie LLP, 130
East Randolph Drive, Chicago, IL 60601. On December 9, 2011, the following documents
were served:

1. BARCO'S ADMINISTRATIVE MOTION FOR A SEALING ORDER

by transmittal via email to the persons listed below:
Charles T. Hoge
choge@knlh.com
Counsel for Patriot Scientific Corp.
I declare under penalty of perjury under the laws of the State of Illinois that the above is true and correct.
Executed on December 9, 2011 at Chicago, Illinois.
s/ Edward K. Runyan