`
`
`v.
`
`ELI LILLY AND COMPANY,
`Defendant.
`
`Civil Action No.
`1:18-cv-12029-ADB
`
`
`
`
`Case 1:18-cv-12029-ADB Document 433 Filed 07/27/22 Page 1 of 3
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MASSACHUSETTS
`
`
`
`
`TEVA PHARMACEUTICALS
`INTERNATIONAL GMBH and
`TEVA PHARMACEUTICALS
`USA, INC.,
`
`
`
`
`DECLARATION OF ELAINE HERRMANN BLAIS IN SUPPORT OF PLAINTIFFS’
`MOTION TO EXCLUDE CERTAIN OPINIONS OF DEFENDANT’S
`EXPERT JAMES M. MCDONNELL, PH.D.
`
`
`I, Elaine Herrmann Blais, hereby declare as follows:
`
`1.
`
`I am a resident of the United States and over the age of 21. The facts set forth
`
`herein are true and of my personal knowledge. If called upon to testify, I could and would verify
`
`competently thereto.
`
`2.
`
`I am a Partner at the law firm of Goodwin Procter LLP, counsel for Plaintiffs Teva
`
`Pharmaceuticals International GmbH and Teva Pharmaceuticals USA, Inc. (collectively, “Teva”)
`
`in the above-captioned action. I am a member in good standing of the State Bar of Massachusetts.
`
`3.
`
`I submit this declaration in support of Plaintiffs’ Motion to Exclude Certain
`
`Opinions of Defendant’s Expert James M. McDonnell, Ph.D.
`
`4.
`
`Attached as Exhibit 1 hereto is a true and correct copy of excerpts of U.S. Patent
`
`No. 8,586,045 (TEVA_FREM_000055080).
`
`
`
`Case 1:18-cv-12029-ADB Document 433 Filed 07/27/22 Page 2 of 3
`
`5.
`
`Attached as Exhibit 2 hereto is a true and correct copy of excerpts of the Opening
`
`Expert Report of Jeffrey V. Ravetch, M.D., Ph.D., Regarding Infringement, dated September 16,
`
`2021.
`
`6.
`
`Attached as Exhibit 3 hereto is a true and correct copy of excerpts of the Rebuttal
`
`Expert Report of James M. McDonnell, Ph.D. Regarding Noninfringement of U.S. Patent Nos.
`
`8,586,045, 9,884,907, and 9,884,908, dated October 28, 2021.
`
`7.
`
`Attached as Exhibit 4 hereto is a true and correct copy of excerpts of the transcript
`
`of the January 7, 2022, deposition of James McDonnell, Ph.D.
`
`8.
`
`Attached as Exhibit 5 hereto is a true and correct copy of excerpts of the Opening
`
`Expert Report of James M. McDonnell, Ph.D. Regarding Invalidity of U.S. Patent Nos. 8,586,045,
`
`9,884,907, and 9,884,908, dated September 16, 2021.
`
`9.
`
`Attached as Exhibit 6 hereto is a true and correct copy of excerpts of the Reply
`
`Expert Report of James M. McDonnell, Ph.D. Regarding Invalidity of U.S. Patent Nos. 8,586,045,
`
`9,884,907, and 9,884,908, dated December 7, 2021.
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`
`
`Executed: March 28, 2022
`
`
`
`
`
`/s/ Elaine Herrmann Blais
` Elaine Herrmann Blais (BBO #656142)
`
`2
`
`
`
`Case 1:18-cv-12029-ADB Document 433 Filed 07/27/22 Page 3 of 3
`
`CERTIFICATE OF SERVICE
`
`I, Elaine Hermann Blais, hereby certify that this document filed through the ECF system
`
`will be sent electronically to the registered participants as identified on the Notice of Electronic
`
`Filing (“NEF”) and paper copies will be sent to those indicated as non-registered participants
`
`on July 27, 2022.
`
`/s/ Elaine Herrmann Blais
`Elaine Herrmann Blais (BBO# 656142)
`GOODWIN PROCTER LLP
`100 Northern Avenue
`Boston, MA 02210
`Tel.: (617) 570-1000
`Fax: (617) 523-1231
`eblais@goodwinlaw.com
`
`
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