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`PHIGENIX
`PHIGENIX
`EXHIBIT 1036
`EXHIBIT 1036
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________
`
`Page 1
`
` PHIGENIX, INC.
` Petitioner
` v.
` IMMUNOGEN, INC.
` Patent Owner
` _______________
` Case No. IPR2014-00676
` Patent 8,337,856 B2
` _______________
`
` DEPOSITION OF GEOFFREY A. PIETERSZ, Ph.D.
` Washington, D.C.
` Thursday, March 12, 2015
`
`Reported by: John L. Harmonson, RPR
`Job No. 90903
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`Page 2
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` March 12, 2015
` 9:34 a.m.
`
` Deposition of GEOFFREY A. PIETERSZ, Ph.D.,
`held at the offices of Sterne Kessler Goldstein &
`Fox, PLLC, 1100 New York Avenue, N.W.,
`Washington, D.C., pursuant to Notice, before John
`L. Harmonson, a Registered Professional Reporter
`and Notary Public of the District of Columbia,
`who officiated in administering the oath to the
`witness.
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` A P P E A R A N C E S
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`On Behalf of Petitioner:
` ANDREWS KURTH
` 600 Travis Street
` Houston, Texas 77002
` BY: GREG PORTER, ESQ.
`
` ANDREWS KURTH
` 1350 I Street NW
` Washington, D.C. 20005
` BY: PING WANG, M.D., ESQ.
` JOHN MURRAY, Ph.D. ESQ.
`
`On Behalf of Patent Owner:
` STERNE KESSLER GOLDSTEIN & FOX
` 1100 New York Avenue NW
` Washington, D.C. 20005
` BY: ELDORA ELLISON, ESQ.
` ERIC STEFFE, ESQ.
` OLGA PARTINGTON, ESQ.
` DAVID ROADCAP, ESQ.
`
`ALSO PRESENT:
` JOSEPH J. KENNY, ESQ., ImmunoGen, Inc.
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` G. PIETERSZ
`--------------------------------------------------
` P R O C E E D I N G S
` 9:34 a.m.
`--------------------------------------------------
` Whereupon,
` GEOFFREY A. PIETERSZ, Ph.D.,
` after having been first duly sworn or affirmed,
` was examined and did testify under oath as
` follows:
` EXAMINATION
` BY MR. PORTER:
` Q. Good morning, Dr. Pietersz. I'm Greg
` Porter. I'm an attorney for Phigenix.
` Do you understand the basics of a
` deposition?
` A. Yes, I do.
` Q. Have you been deposed before?
` A. No.
` Q. Will you ask me for clarification if
` at any time you don't understand my question?
` A. I will.
` Q. Okay. And just for definitional
` purposes and to kind of shorten things here
` today, when I use the word "person of ordinary
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`skill in the art," what I'm referring to is the
`way that you used that term as of the date of
`March of 2000. Is that okay with you?
` A. Yes.
` Q. And when I use the word "claims" or
`"patent claims" or "'856 patent," I'm referring
`to the claims of U.S. Patent Number 8,337,856.
` A. Yes.
` Q. Do you understand that?
` A. Yes.
` Q. And I will also use the word
`"Kadcyla." Do you understand what that is?
` A. Yes.
` Q. And do you understand that that's the
`same as T-DM1?
` A. I do.
` Q. Okay. And just by way of background,
`how did you become an expert in this case?
` A. I was engaged by ImmunoGen to be an
`expert witness in this case.
` Q. And have you worked with ImmunoGen
`before?
` A. Not in a case like this. I haven't
`had any collaborations with ImmunoGen.
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` Q. Do you know how they came to select
`you as an expert for this case?
` A. I didn't ask. I assume from the --
`because I was a prolific writer in the period of
`time in immunoconjugates.
` Q. And when you say "period of time,"
`what are you referring to?
` A. March 2000 and earlier.
` Q. And who first contacted you?
` A. I was contacted by the SK -- the
`lawyers.
` Q. And which lawyer?
` A. SKGF. Sorry.
` Q. The lawyers that are sitting to your
`right today?
` A. Yes. Sorry.
` Q. What's your understanding of what this
`proceeding is about?
` A. I understand that there is a petition
`against the '856 patent by Phigenix.
` Q. And before you were engaged for this
`particular proceeding, had you ever read the '856
`patent?
` A. No.
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` Q. And you've now read it, of course?
` A. Yes, I have.
` Q. And how much time have you spent
`reviewing the '856 patent?
` A. I haven't -- I can't give you a number
`specifically for that. But to come up with my
`opinion in the declaration, about 65 hours or so.
` Q. And what did the 65 hours encompass?
` A. Reviewing the exhibits, so that's the
`documents that I've searched, as well as writing
`the declaration.
` Q. And did you assemble all of the
`exhibits that you reviewed?
` A. Yes.
` Q. Were any exhibits provided to you?
` A. Some photocopies of things that I
`couldn't access.
` Q. Had you had an occasion to review
`those exhibits before your engagement for this
`case?
` A. Sorry. I didn't understand the
`question.
` Q. Had you reviewed any of those exhibits
`that became part of your declaration before you
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`were hired for this proceeding?
` A. Yes. Yes.
` Q. Were there any new exhibits that you
`reviewed apart from the '856 patent for this
`proceeding?
` A. Yeah, there was a few. I can't
`remember exactly how many, but some of them,
`during my period of working with
`immunoconjugates, I had reviewed them, or seen
`them at least.
` (ImmunoGen Exhibit 2135 marked for
` identification and attached hereto.)
`BY MR. PORTER:
` Q. I'm going to hand you what's been
`marked as ImmunoGen Exhibit 2135.
` A. Thank you.
` Q. What is Exhibit 2135?
` A. That's my curriculum vitae.
` Q. And is that current as of today?
` A. It is.
` Q. What is your current position?
` A. I'm a principal research fellow at the
`Burnet Institute.
` Q. And what do you do as a principal
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`research fellow?
` A. I run a lab at the Burnet Institute.
`It's a bio-organic and medicinal chemical lab.
` Q. When you say you run a lab, what's
`involved with that?
` A. So it involves day-to-day supervision
`of students as well as post-docs.
` Q. Do you do your own research as part of
`that lab?
` A. Yes. I do try to get in the lab
`whenever I can.
` Q. And what type of research do you do?
` A. Primarily my research is in vaccines,
`particularly breast cancer vaccines and vaccines
`for infectious diseases.
` Q. And what type of infectious diseases
`does your research encompass?
` A. I've worked on influenza, respiratory
`syncytial virus. Currently I've got a grant on
`Hendra virus. They are just a few.
` Q. What is Hendra virus?
` A. Hendra virus is a virus that is
`actually endemic in bats. They shed -- they
`don't get sick from it. They shed the virus in
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`their droppings. And the horses, when they
`ingest it in contaminated food, get the Hendra
`virus. And people who handle the horses that are
`infected can get the Hendra virus. But there is
`no transmission from human to human. So we're
`looking at a vaccine for humans.
` Q. And what type of vaccine is that?
` A. We're looking at a mucosal vaccine.
`So this is something that we can put in the nose
`and get respiratory immunity.
` Q. Okay. And has your research involved
`looking at cancer drugs at any time?
` A. Yes. Yes.
` Q. At what period of time did your
`research involve that?
` A. I worked with cancer drugs in the
`periods from early '80s to let's say 2000s. And
`I'm currently doing some work on a new class of
`cancer drug called histone deacetylases.
` Q. What is histone deacetylases?
` A. Histone deacetylase is actually
`regulators of the unwinding of DNA. So DNA
`usually is very compact. And when you use the
`histone deacetylase, what it does is it unwinds
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`the DNA, and that allows transcription to happen.
`So you're able to bring up dormant genes. I'm
`using it in HIV to try to wake up the latent
`virus.
` Q. Have you done research with
`immunoconjugates for cancer?
` A. Yes. So again, I extensively did work
`during my career and currently as well on
`immunoconjugates.
` Q. And what does your current work
`involve with immunoconjugates?
` A. So again, I'm using the histone
`deacetylases to target using anti-moc-1
`antibodies.
` Q. Is all of the research done in the
`laboratory that you mentioned earlier?
` A. Yes.
` Q. What sort of capabilities does that
`laboratory have?
` A. Well, I've got a synthetic facility in
`my lab as well as ability to do biological
`experiments like cell culture. And then we also
`have a large animal house that allows us to do
`some in vivo work in mice.
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` Q. Does it have the capability to make
`immunoconjugates, then?
` A. Yes. My lab does that.
` Q. Does it have capability to test
`immunoconjugates?
` A. Yes.
` Q. And in connection with your work for
`this case, have you done any experiments with
`Kadcyla?
` A. No.
` Q. And coming back to your CV, that's the
`exhibit there, can you turn to the list of
`patents that you have.
` A. Yes.
` Q. I think it's on page 21 of
`Exhibit 2135.
` A. Page, sir?
` Q. Page 21.
` A. Yeah.
` Q. What generally are the patents that
`are referred to from the 1986 to 1988 time frame
`on page 21?
` A. You want me to tell you what they are
`or --
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` Q. Well, I was puzzling over what PH4103
`means basically. What country patent number is
`that?
` A. That's not a patent number. That's
`just an ID. I must say I didn't have the patent
`numbers there. That's an oversight on my part.
`Sorry. They granted patents that have now
`expired. Sorry, I must apologize I didn't have
`the numbers there.
` Q. And so when you say it's an ID number,
`what does that mean?
` A. It comes from one of the grants that I
`put in. So it's an oversight.
` Q. And then continuing on to page 22, is
`the list of patents on page 21 and 22 the
`complete list of all of your patents?
` A. Yes. Yes. And you can see the patent
`numbers are indicated in that case. These are
`just old expired patents.
` Q. The ones from 1986 to '88 are expired?
` A. Yes. You can see the current ones
`have proper patent numbers.
` Q. And coming back to your CV, it talks
`about some work with a company called Ascend
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`Biopharmaceuticals?
` A. Biopharmaceuticals, yes.
` Q. What is your role in connection with
`that?
` A. I lost my page.
` Q. Sorry. It's on page 3.
` A. Sorry. I got this mixed up.
` So Ascend Biopharmaceuticals is a
`company that was formed from the intellectual
`property at the Burnet Institute. So I had
`patents that is a composition for a vaccine, and
`they were licensed to a company called 4G
`Vaccines. And then a company was formed by
`private investment to try and commercialize the
`breast cancer vaccine. And that is Ascend. And
`I am the technical officer, the chief technical
`officer.
` Q. And approximately how much time do you
`spend in your role there versus your role as the
`senior principal research fellow?
` A. A max of three days. But it's a lot
`less because I oversee manufacture.
` Q. And then on page 9 of your CV it has a
`list of publications and refereed journal
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`articles.
` A. Yes.
` Q. Is that a complete list and current of
`your journal articles?
` A. Yes, it is.
` Q. Dr. Pietersz, what did you do to
`prepare for today's deposition?
` A. Well, I reviewed my declaration and
`met with counsel.
` Q. Did you review anything else besides
`your declaration?
` A. Some of the exhibits as well.
` Q. And how much time did you spend
`reviewing your declaration, the exhibits and
`meeting with counsel? Specifically for preparing
`for the deposition.
` A. Preparing for deposition, like in the
`last couple of days or --
` Q. How much time did you spend
`specifically preparing for today's deposition?
` A. Since I can't sleep and I'm from
`Australia, I've been working almost all night, so
`I really can't give you a number. I met with
`counsel this morning at 8:45. But before that I
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`had been working in the hotel on my own.
` Q. When did you arrive in Washington,
`D.C.?
` A. I came on Monday evening.
` Q. And so before you met with counsel
`yesterday, you were preparing on your own?
` A. Once I came -- Yeah. Sorry. Did you
`mean in the last two days?
` Q. Yeah.
` A. I did meet with counsel as well.
`Sorry.
` Q. How long did you spend meeting with
`counsel yesterday?
` A. In the last two days, yeah.
` Q. So you met with counsel Tuesday and
`Wednesday of this week?
` A. Yes.
` Q. Was it a full-day meeting both days?
` A. It was about that, yeah.
` Q. And in addition to your declaration,
`you mentioned you reviewed certain exhibits. Do
`you recall what those exhibits were?
` A. Not -- For the case? Clarify.
` Q. In preparation for your deposition,
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`during your meetings with counsel, did you review
`any exhibits?
` A. No. Not other that I haven't actually
`got in my declaration.
` Q. And in your declaration there is a
`list of exhibits that you reviewed.
` A. Yes.
` Q. Was that a complete list of all of the
`exhibits that you reviewed in connection with
`your work for this case?
` A. No. They're the ones that are
`relevant to my declaration. I mean, I've
`researched and looked at lots of ones.
` Q. Did you keep a list of the other ones
`that you reviewed but you didn't put into your
`declaration?
` A. No, I haven't. It's searches from the
`databases.
` Q. And of the exhibits that you list in
`your declaration, some you specifically refer to
`later and others you don't. Is that right?
` A. I think they all refer to --
`Everything in the declaration exhibits are
`referred to. I don't think there's any that
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`isn't.
` Q. Okay. And when you say they're all
`referred to, meaning that they are used to
`support some statement in your declaration?
` A. Exactly.
` Q. Do you know what the chemical
`structure for Kadcyla is, Dr. Pietersz?
` A. I wouldn't be able to draw the
`maytansine structure by heart, but I can tell you
`it is a linkage of maytansine. I don't think I
`can draw a micro-like structure, but it is
`maytansine with SMCC link to an antibody.
` Q. And for that drug Kadcyla that has the
`maytansine connected to the MCC linker connected
`to the antibody, how many maytansines are
`connected to the linker?
` MS. ELLISON: Objection; form.
` THE WITNESS: The range in the papers,
` it's an average number of molecules. It
` could range around about 3.5. But remember
` it's average, it's a normal distribution, so
` it could have more on either side.
`BY MR. PORTER:
` Q. And what type of -- what do you mean
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`by it's a normal distribution?
` A. Because when you link the
`non-cleavable SMCC linker to an antibody, there's
`no way of controlling the number of SMCCs on that
`molecule because there's a lot of lysines on the
`antibody that it actually reacts with. So you
`might get some molecules that might have seven,
`some that have one. So it's an average
`distribution.
` Q. In the Kadcyla pharmaceutical, the
`commercial formulation, what range is there of
`the number of maytansines per antibody?
` A. I can't be sure of this because it's
`not listed as an exhibit. So the number could be
`slightly different. It's around 3.6 or 3.2, an
`average number. Again, average. So it's a
`distribution.
` Q. How does the number of maytansines
`that are linked to a particular linker affect the
`activity, if at all?
` MS. ELLISON: Objection; scope.
` THE WITNESS: So this is something
` that has to be tested, because you have to
` link the cross-linker with the antibody and
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` see whether you lose activity and then base
` your upper and lower end based on the
` remaining antibody activity. Then you react
` with the maytansine. So it's something that
` you have to do.
`BY MR. PORTER:
` Q. And how would you go about doing that?
` A. So as a chemical reaction, you would
`have the antibody in a solution or a buffer, and
`then you would react -- you've got SMCC, a
`chemical you can buy, and you would react
`different fold excesses. So you might try
`fivefold excess, a tenfold excess, twentyfold
`excess, and then you conjugate how much is
`actually modified. So that's how you see how
`much is modified. You test each one of those,
`and then you see which is optimum in retaining
`the antibody binding activity.
` Q. And when you say determine which is
`optimum for retaining the antibody binding
`activity, what do you mean by that?
` A. So you can do it by chemical assays
`that look at binding of the cells using
`radioactivity, for instance. There are
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`established assays that can be used to determine
`how much activity is left compared to the
`original antibody.
` Q. Would you be able to determine if
`there is a significant difference in activity
`with a 3.2 versus 3.6 number of maytansinoids per
`antibody?
` MS. ELLISON: Objection; scope.
` THE WITNESS: I mean, again, it's
` something that has to be done and tested,
` and I can't say that I've done that. So you
` would react to the fivefold excess, tenfold
` excess and then compare those. So that's
` the way you can do it. But you can't say
` 3.6 or 3.2 or something.
`BY MR. PORTER:
` Q. So right now, without any testing, you
`wouldn't be able to determine whether a 3.2
`versus 3.6 maytansinoids per antibody had a
`different level of activity or not?
` MS. ELLISON: Objection; scope.
` Relevance.
` THE WITNESS: It depends on what
` you're trying to show there. I mean,
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` remember I said this is average
` distribution. So if you're doing average
` distribution looking at 3.2 and 3.6, it's
` not possible because it's statistically not
` possible.
`BY MR. PORTER:
` Q. Which claims, if any, of the '856
`patent cover the drug Kadcyla?
` A. Can I have a copy of the patent,
`please, of the exhibit?
` Q. Sure.
` (Phigenix Exhibit 1001 marked for
` identification and attached hereto.)
`BY MR. PORTER:
` Q. I'll hand you what's been marked as
`Phigenix Exhibit 1001.
` Phigenix Exhibit 1001, that's the
`patent at issue that we're talking about here,
`right?
` A. Yes.
` Q. The '856 patent?
` A. Exactly.
` Q. So the question I asked was: Which
`claims, if any, of Claims 1 through 8 would cover
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`Kadcyla?
` A. It's Claim 8.
` Q. Anything else?
` A. That's specifically Kadcyla?
` Q. Yes.
` A. It's dependent on 7. And I'm giving
`this opinion based as a scientist, not as a
`patent lawyer. So what I would say is that
`7 makes a specific form of DM1, and then the
`other six would cover any variations of DM1, any
`maytansinoid. That's my opinion.
` Q. And so your opinion is that Claims 6,
`7 and 8 specifically cover Kadcyla?
` MS. ELLISON: Objection; form.
` THE WITNESS: It's 8. 8 is
` specifically Kadcyla.
`BY MR. PORTER:
` Q. Okay. And when you say it's
`specifically Kadcyla, you mean that it has
`maytansine connected to an SMCC linker connected
`to the antibody?
` A. Yes. DM1.
` Q. And in Claim 8, is there any
`particular limitation as to the number of
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`maytansinoid molecules per antibody molecule?
` MS. ELLISON: Objection; form.
` Foundation.
` THE WITNESS: Again, from me as a
` scientist and a researcher, looking at this,
` there would be no limitations in that one.
`BY MR. PORTER:
` Q. And so as far as the scope of Claim 8
`goes, it could cover any number of maytansinoid
`molecules per antibody molecule?
` MS. ELLISON: Objection; form.
` Foundation.
` THE WITNESS: Can you repeat that
` question again, please?
`BY MR. PORTER:
` Q. As far as Claim 8 goes, the scope of
`the claim would cover any number of maytansinoid
`molecules per antibody molecule; is that correct?
` MS. ELLISON: Objection; form.
` Foundation.
` THE WITNESS: So again, the number of
` residues or the number of maytansinoids on
` there would depend on retaining an
` immunoconjugate, an active immunoconjugate.
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` So that has to be kept into account as well.
` So you can't have an indefinite number of
` residues, because it has to be accomplished
` with immunoconjugate.
`BY MR. PORTER:
` Q. And what, in your view, would be an
`indefinite number of maytansinoid molecules per
`antibody molecule for Claim 8?
` MS. ELLISON: Objection; scope.
` THE WITNESS: Again, this is something
` I can't speculate on. But me, again as a
` scientist, could only say that if you put
` too many residues of maytansinoid on the
` Herceptin, you're going to lose the
` activity. That's all I can say.
`BY MR. PORTER:
` Q. Do you know how many is too many?
` MS. ELLISON: Objection; scope.
` THE WITNESS: Again, I can't because
` it's something that you have to do. You
` might get precipitation if you put 20. So I
` can't give a proper answer for that.
`BY MR. PORTER:
` Q. You reviewed the specification of the
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`'856 patent, correct?
` A. I did.
` Q. Was there any indication in the '856
`specification as to how many maytansinoid
`molecules per antibody would be suggested?
` MS. ELLISON: Objection; form. Scope.
` THE WITNESS: So on Column 44, line 65
` down, or 64 to be precise, the number of DM1
` drug molecules linked per antibody molecule,
` and I'll just skip to the end, was found to
` be 3.7 drug molecules per antibody molecule.
` Again, this is an average.
`BY MR. PORTER:
` Q. If you could turn to Column 40, line
`about 66.
` A. Yes.
` Q. Doesn't that say that there can be one
`to ten maytansinoid molecules conjugated to each
`antibody molecule?
` A. It also says after that preferably
`three to four. And three to four, an average
`would be 3.5. So this is again the range.
`Remember, it's not precise. You have to use an
`average or a normal distribution.
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` Q. And so for the scope of Claim 8, which
`you said specifically covers Kadcyla but it
`doesn't have a limit as to the number of
`maytansinoids, would a fair limit of number of
`maytansinoids for the scope of Claim 8 be one to
`ten based on Column 40?
` MS. ELLISON: Objection to form.
` Outside the scope.
` THE WITNESS: Again, from what I see
` in front of me, I would say one to ten.
`BY MR. PORTER:
` Q. How does Kadcyla work in the body?
` MS. ELLISON: Objection; scope.
` THE WITNESS: I'm really not clear
` what you want me to say there.
`BY MR. PORTER:
` Q. I'll try and clear it up.
` How does Kadcyla treat breast cancer?
` MS. ELLISON: Objection; scope.
` THE WITNESS: The conjugate of DM1
` with Herceptin is binding the breast cancer
` cells and killing them, because they express
` the antigen HER2.
`BY MR. PORTER:
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` Q. Functionally how does that work? Or
`what is the mechanism?
` MS. ELLISON: Objection; form. Scope.
` THE WITNESS: Again, I can speak at
` the time of the prior to date of March 2000.
` And in that period it was -- since SMCC is a
` non-cleavable linker, no one knew why other
` than it's not released compared to a
` releasable disulfide link conjugate.
` So my answer is going to depend on
` whether I'm looking at March of 2000 or
` later. So March of 2000, no one knew.
` Because it's a non-releasable conjugate.
`BY MR. PORTER:
` Q. And when you say no one knew in March
`of 2000 with respect to a non-releasable
`conjugate, what do you mean when you say
`"non-releasable conjugate"?
` A. Because SMCC is considered a
`non-cleavable linker. So it can't release
`maytansinoid from the conjugate.
` Q. And when you say no one knew about a
`non-cleavable conjugate in March of 2000, are you
`including the inventors of the '856 patent also?
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` A. That's not what I said. I said no one
`knew how SMCC conjugate of DM1 in an antibody
`would work on a cell because it's a
`non-releasable or non-cleavable linker.
` Q. And when you say no one knew, you're
`including the inventors of the '856 patent,
`correct?
` A. Yes.
` Q. Did the inventors of the '856 patent
`discuss anywhere whether there was a preference
`for a non-cleavable linker versus a cleavable
`linker?
` A. In '92, Chari '92, a cleavable linker
`is what was preferred. And that was the art as
`of March 2000.
` Q. My question was about the '856 patent.
`Is there anywhere in the specification where
`there's a preference for either a cleavable or a
`non-cleavable linker?
` MS. ELLISON: Objection; relevance.
`BY MR. PORTER:
` Q. Dr. Pietersz, we might be able to save
`a bit of time. If you turn to Column 36.
` A. Yes. I was just wondering if I should
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`dog-ear it or if I'm allowed to do that.
` Q. I'll give you a sticker if you want a
`sticker.
` A. I found it the same time as you.
` Yes. So the SMCC linker is listed
`there as cyclohexane-1-carboxylate.
`Cyclohexane-1-carboxylate.
` Q. And in that Column 36, doesn't it say
`at line 25 that particularly preferred coupling
`agents include SPDP and SPP?
` A. Yes. That's to provide disulfide
`linkages specifically. But if you are looking at
`a thioether linkage like in Kadcyla, then you
`would use SMCC, which is listed there.
` Q. But you would agree that the inventors
`here in Column 36 are expressing a preference for
`SPDP and SPP by nature of their language
`"particularly preferred coupling agents"?
` A. Again, reading as a scientist, it's
`preferred for disulfide linkages because of the
`very last part of that sentence. So that's what
`I would say. It leaves open that you can still
`have SMCC linkages because it's precisely said
`there.
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` Q. So are you saying that the Column 36,
`line about 13 through 29, suggests in some way
`that SMCC is preferred over SPDP and SPP linkers?
` MS. ELLISON: Objection; form.
` THE WITNESS: Can you repeat that
` question again, please?
` MR. PORTER: I said it very well
` before. Can you read that back?
` (Whereupon, the requested portion was
` read back by the Reporter.)
` MS. ELLISON: Same objection.
` THE WITNESS: Again, looking at this
` paragraph, I can't, from my knowledge,
` eliminate the possibility of using SMCC as
` well as SPDP because of that bottom sentence
` there.
`BY MR. PORTER:
` Q. I guess the question was: Is this
`paragraph suggesting SMCC is better and more
`preferred in some way than SPDP and SPP in light
`of the express language at Column 36, line 25
`that it says "particularly preferred coupling
`agents include SPDP and SPP"?
` MS. ELLISON: Objection; form.
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` Relevance.
` THE WITNESS: Again, I don't think it
` says that precisely because of the specific
` line there saying for disulfide linkages at
` the bottom of that paragraph. This is 28.
` So you're not specifically saying one is
` better than the other, but they can be used
` for conjugation. But for SS linkages you
` would use those. That's my understanding.
`BY MR. PORTER:
` Q. What examples did the inventors of
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