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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PHIGENIX, INC.
`Petitioner
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`IMMUNOGEN, INC.
`Patent Owner
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`Case IPR2014—OO676
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`Patent 8,337,856 B2
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`PHIGENIX, INC.’S RESPONSE TO IMMUNOGEN’S MOTION TO
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`ENTER PROTECTIVE ORDER
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`PHIGENIX, INC.’S RESPONSE TO INHVIUNOGEN’S MOTION TO ENTER PROTECTIVE ORDER
`CASE IPR2014-00676
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`Phigenix was surprised to see in the Motion that Immunogen “certifies it met
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`and conferred with Petitioner, Phigenix, Inc., in an attempt to reach agreement on
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`entry of this Default Protective Order , but no agreement was reached.” In point of
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`fact, Phigenix had previously stated back on January 16, 2015 that “we do not
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`oppose entry of the default protective order.” (Exhibit A). Before Immunogen
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`made the certification in its motion, it did not attempt to meet, confer, or even
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`answer the question posed in Phigenix correspondence of the same day. (Exhibit
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`B). Without waiving any rights it may have to object to or move to strike any
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`evidence produced under a protective order, Phigenix does not oppose entry of the
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`default protective order.
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`Date: February 13, 2015
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`Lead Attorney for Petitioner
`Phigenix, Inc.
`Registration No. 48,328
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`1350 I Street, NW, Suite 1100
`Washington, DC. 20005
`(202) 662-3042
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`Case IPR2014—00676
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`Patent No. 8,337,856
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`CERTIFICATE OF SERVICE 137 C.F.R. § 42.6gefi, 42.105§an
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`The undersigned hereby certifies that the above—captioned “Phigenix Inc.’s
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`Response to Imrnnogen, Inc.’s Motion to Enter Protective Order” was served in its
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`entirety on February 13, 2015, upon the following parties via electronic mail:
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`Eldora L. Ellison, PhD.
`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`1100 New York Ave., NW.
`Washington, DC. 20005—3934
`Tel: (202) 772—8508
`Fax: (202) 371—2540
`eellison@skgf.com
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`Eric K. Steffe
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`Sterne, Kessler, Goldstein & Fox P.L.L.C.
`1100 New York Ave., NW.
`Washington, DC. 20005—3934
`Tel: (202) 772-8625
`Fax: (202) 371—2540
`esteffe@skgf.com
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`Date: February 13, 2015
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`1350 I Street, NW, Suite 1100
`Washington, DC. 20005
`(202) 662-3042
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`\ANDREWS KURJH, LLP
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`.13., Esq.
`Pix g Wang, i.
`RegistrationNo. 48,328
`Lead Attorney for Petitioner
`Phigenix, Inc.
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