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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`UNIVERSITY OF MASSACHUSETTS and
`CARMEL LABORATORIES, LLC,
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`Plaintiffs,
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`v.
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`L’ORÉAL USA, INC.,
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`Case No. 17-cv-868-CFC-SRF
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`Defendant.
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`[PROPOSED] ORDER
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`THIS MATTER having been brought before the Court on Motion by Plaintiffs
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`University of Massachusetts and Carmel Laboratories, LLC, seeking production of certain
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`development records for the Accused Products; certain documents related to Defendant’s patent
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`applications; and organizational charts reflecting the structure of Defendant’s business and
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`personnel; and the Court having considered the parties’ positions as set forth in the letters
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`submitted on April 20 and 22, 2020, and during the April 24, 2020 hearing;
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`IT IS on this _______ day of April, 2020, hereby:
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`ORDERED that Plaintiffs’ Motion is hereby GRANTED;
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`ORDERED that Defendant shall produce all documents related to the inclusion of
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`adenosine in each of the Accused Products, no later than May 1, 2020;
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`ORDERED that Defendant shall produce all documents related to the Accused Products
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`effect on wrinkling, roughness, dryness, or laxity of the skin, no later than May 1, 2020;
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`ORDERED that Defendant shall supplement its response to Plaintiffs’ Interrogatory No.
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`6 to provide a complete response, no later than May 1, 2020;
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`Case 1:17-cv-00868-CFC-SRF Document 132-2 Filed 04/27/20 Page 2 of 2 PageID #: 4715
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`ORDERED that Defendant shall search the files of Marc Cornell, Isabelle Hansenne,
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`Hani Fares, and Jean-Baptist Galey and produce all documents therein regarding the effect of
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`adenosine on skin, and L’Oréal’s knowledge of the asserted patents, no later than May 1, 2020;
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`and
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`ORDERED that Defendant shall produce organizational charts and/or documents
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`sufficient to show its organizational structure and the identity of its employees and the
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`employees of its brands, no later than May 1, 2020.
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`________________________________
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`Hon Sherry R. Fallon, U.S.M.J.
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`2
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