`
`Elaine Herrmann Blais
`+1 617 570 1205
`eblais@goodwinlaw.com
`
`
`
`
`Goodwin Procter LLP
`100 Northern Avenue
`Boston, MA 02210
`
`goodwinlaw.com
`+1 617 570 1000
`
`
`September 1, 2022
`
`VIA ECF
`
`The Honorable Allison D. Burroughs
`United States District Court Judge
`John Joseph Moakley U.S. Courthouse
`1 Courthouse Way
`Boston MA 02210
`
`Re:
`
`Teva Pharmaceuticals Int’l GmbH et al. v. Eli Lilly & Co., No. 1:18-cv-12029-ADB
`
`Dear Judge Burroughs:
`
`We write on behalf of Plaintiffs Teva Pharmaceuticals Int’l GmbH and Teva Pharmaceuticals USA, Inc.
`(collectively, “Teva”) and Defendant Eli Lilly and Company (“Lilly”) (all together, “the Parties”) regarding
`the September 7, 2022 continued hearing on the Parties’ motions for summary judgment.
`
`The Parties were informed that a total of three (3) hours will be allotted for continued argument on the
`motions for summary judgment. In the interest of a more efficient hearing, the Parties have conferred on
`the distribution of the remaining time for arguments. The Parties have agreed to the following order of
`arguments and time allotted per party, and also that any amount of time that a party devotes to an
`argument in excess of the allotted time for a given motion will be deducted from that party’s allotted time
`for the remaining motions:
`
`1.
`
`2.
`
`3.
`
`4.
`
`Defendant Eli Lilly and Company’s Motion for Partial Summary Judgment of Non-Infringement
`(ECF No. 297): 60 minutes (30 minutes per side)
`
`Defendant Eli Lilly and Company’s Motion for Summary Judgment of Invalidity for Lack of
`Written Description (ECF No. 293): 60 minutes (30 minutes per side)
`
`Plaintiffs Teva Pharmaceuticals Int’l GmbH and Teva Pharmaceuticals USA, Inc.’s Motion for
`Summary Judgment of No Inequitable Conduct and Unclean Hands (ECF No. 301):
`40 minutes (20 minutes per side)
`
`Defendant Eli Lilly and Company’s Motion for Partial Summary Judgment of No Willful
`Infringement (ECF No. 305): 20 minutes (10 minutes per side)
`
`Of course, if the Court would prefer to hear the motions in a different order, the Parties will be prepared
`to address the motions in the Court’s preferred order.
`
`
`
`
`
`Case 1:18-cv-12029-ADB Document 458 Filed 09/01/22 Page 2 of 2
`
`
`
`
`
`The Honorable Allison D. Burroughs
`September 1, 2022
`Page 2
`
`
`Sincerely,
`
`Elaine Herrmann Blais
`
`Cc: All Counsel of Record via ECF
`
`
`
`
`
`
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