Bryan Bergeron, MD, FACMI - January 21, 2016
`
` U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
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`P A R P H A R M A C E U T I C A L , )
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`I N C . , W O C K H A R D T B I O A G )
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`a n d A M N E A L )
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`P H A R M A C E U T I C A L S L L C , ) N o .
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` P e t i t i o n e r s , ) I P R 2 0 1 5 - 0 0 5 4 8
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` v s . )
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`J A Z Z P H A R M A C E U T I C A L S , )
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`I N C . , )
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` P a t e n t O w n e r . )
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`_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ )
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` D E P O S I T I O N U N D E R O R A L E X A M I N A T I O N O F
`
` B R Y A N B E R G E R O N , M D , F A C M I
`
` J a n u a r y 2 1 , 2 0 1 6
`
` N e w Y o r k , N e w Y o r k
`
` R E P O R T E D B Y : D A N A N . S R E B R E N I C K , C R R C L R
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 1 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 2
`
`2 (Pages 2 to 5)
`
`Page 4
`
`1 A P P E A R A N C E S (continued)
`
`2 3
`
` JONES DAY
`4 BY: JOHN V. BIERNACKI, ESQ.
`5 North Point
`6 901 Lakeside Avenue
`7 Cleveland, Ohio 44114-1190
`8 216.586.7747
`9 jvbiernacki@jonesday.com
`10 Counsel for the Patent Owner,
`11 Jazz Pharmaceuticals
`12
`13 QUINN EMANUEL URQUHART &
`14 SULLIVAN LLP
`15 BY: FRANK CALVOSA, ESQ.
`16 EVANGELINE SHIH, ESQ.
`17 51 Madison Avenue, 52nd Floor
`18 New York, New York 10010
`19 212.849.7569
`20 Evangelineshih@quinnemanuel.com
`21 frankcalvosa@quinnemanuel.com
`22 Counsel for the Patent Owner,
`23 Jazz Pharmaceuticals, Inc.
`24
`25
`
` Transcript of the deposition of
` BRYAN BERGERON, MD, FACMI, called for
` Oral Examination in the
` above-captioned matter, said
` deposition taken pursuant to United
` States Patent and Trademark Office
` rules and regulations, by and before
` DANA N. SREBRENICK, a
` Federally-Approved Certified Realtime
` Reporter, a New Jersey Certified Court
` Reporter, a Certified Livenote
` Reporter, and a Notary Public for the
` State of New York, at the offices of
` QUINN EMANUEL URQUHART & SULLIVAN LLP,
` 51 Madison Avenue, New York, New York
` 10010, commencing at 9:30 a.m.
`
` - - -
`
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`Page 3
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`Page 5
`
` - - -
` BRYAN BERGERON, MD, FACMI,
` 27 Stearns Road, Brookline,
` Massachusetts 02246, after having been
` duly sworn, was examined and testified
` as follows:
` - - -
` EXAMINATION BY MR. BERMAN:
` - - -
`
` Q. Q. Good morning, Dr. Bergeron. My
`
` Q. Q.
` name is Rich Berman. I'm counsel for Par
` Pharmaceutical. I'll be asking you some
` questions today.
`
` A. A. Good morning.
`
` A. A.
`
` Q. Q. Can you please recite your full
`
` Q. Q.
` name and home address for the record?
`
` A. A. Sure. Bryan Patrick Bergeron.
`
` A. A.
` My home address is 27 Stearns Road,
` Brookline, Mass 02446.
`
` Q. Q. And you've been deposed before,
`
` Q. Q.
` correct?
`
` A. A. I have.
`
` A. A.
`
` Q. Q. And that's reflected in your CV?
`
` Q. Q.
`
` A. A. Yes, it is.
`
` A. A.
`
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`1 A P P E A R A N C E S
`
`23
`
` ARENT FOX
`4 BY: RICHARD J. BERMAN, ESQ.
`5 1717 K Street, NW
`6 Washington, DC 20036-5342
`7 202.857.6000
`8 Richard.berman@arentfox.com
`9 Counsel for the Petitioner,
`10 Par Pharmaceutical
`11
`12 MADDOX EDWARDS, PLLC
`13 BY: MATTHEW C. RUEDY, ESQ.
`14 1900 K Street NW - Suite 725
`15 Washington, DC 20006
`16 202.830.0779
`17 mruedy@meiplaw.com
`18 Counsel for the Petitioner,
`19 Amneal Pharmacuetical
`20
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 2 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 6
`
` BRYAN BERGERON, M.D.
`
` Q. Q. Let me just go over the ground
`
` Q. Q.
` rules. Let me know if you don't hear or
` understand a question. If you answer a
` question, we will assume that you heard
` and understood the question, okay?
`
` A. A. Okay.
`
` A. A.
`
` Q. Q. Let me know if you don't know or
`
` Q. Q.
` can't remember the information sought by a
` question. If you answer, we'll assume
` that you know and can remember the
` information sought, okay?
`
` A. A. Okay.
`
` A. A.
`
` Q. Q. We have a court reporter here
`
` Q. Q.
` making a transcript, so be sure to answer
` out loud. The court reporter cannot
` record nodding or shaking of the head.
` Also please say "yes" rather than
` "uh-huh," which sometimes cannot be
` understood by the court reporter, okay?
`
` A. A. Understood.
`
` A. A.
`
` Q. Q. Let me know if you want to take
`
` Q. Q.
` a break for any reason, okay?
`
` A. A. Okay.
`
` A. A.
`
` Q. Q. And let me know if you realize
`
` Q. Q.
`
`Page 7
`
` BRYAN BERGERON, M.D.
` that an answer that you previously gave is
` inaccurate or incomplete, just say you
` want to correct or supplement the record,
` okay?
`
` A. A. Okay.
`
` A. A.
`
` Q. Q. Is there any reason you can't
`
` Q. Q.
` give full and complete answers today?
`
` A. A. No.
`
` A. A.
`
` Q. Q. Are you represented by counsel
`
` Q. Q.
` today?
`
` A. A. Yes, I am.
`
` A. A.
`
` Q. Q. Who is that?
`
` Q. Q.
`
` A. A. Seated here at the table is John
`
` A. A.
` Biernacki at the end, Frank Calvosa in the
` middle and Evangeline Sue --
` MS. SHIH: Shih.
`
` A. A. Sorry, Shih.
`
` A. A.
` BY MR. BERMAN:
`
` Q. Q. And you submitted declarations
`
` Q. Q.
` in connections with certain inter partes
` re-exam proceedings or IPRs, correct?
`
` A. A. That's correct.
`
` A. A.
`
` Q. Q. And those IPRs are for six
`
` Q. Q.
` different patents owned by Jazz, correct?
`
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`3 (Pages 6 to 9)
`
`Page 8
`
` BRYAN BERGERON, M.D.
`
` A. A. That's my understanding, yes.
`
` A. A.
`
` Q. Q. And they were filed by either
`
` Q. Q.
` Par Pharmaceutical, Amneal Pharmaceutical
` or Wockhardt, correct?
`
` A. A. I'm not sure who actually filed
`
` A. A.
` them.
`
` Q. Q. But is it okay if I call the
`
` Q. Q.
` filers "petitioners" today?
`
` A. A. Sure.
`
` A. A.
` MR. BERMAN: And just for the
` record, the IPRs are 2015-545, 546,
` 547, 548, 551 and 554, joined with
` IPR 2015-1810, 1813, 1814, 1815,
` 1816, 1817, 1818 and 1820.
` BY MR. BERMAN:
`
` Q. Q. So generally, the Jazz patents
`
` Q. Q.
` that are the subject of the IPRs deal with
` restricted drug distribution systems,
` correct?
`
` A. A. In general, yes.
`
` A. A.
`
` Q. Q. And for the purposes of this
`
` Q. Q.
` deposition, I'm going to refer to the
` patents by the last three numbers, for
` example, patent 7,668,730 I'll refer to as
`
`Page 9
`
` BRYAN BERGERON, M.D.
` the '730 patent. Is that okay?
`
` A. A. That's fine.
`
` A. A.
`
` Q. Q. Okay. And we're going to be
`
` Q. Q.
` talking about your knowledge as of certain
` dates. When I ask about your knowledge
` about something in the early 2000s, I mean
` prior to December '2002, okay?
`
` A. A. Okay.
`
` A. A.
`
` Q. Q. Have you read the six patents
`
` Q. Q.
` involved in these IPRs?
`
` A. A. I have.
`
` A. A.
`
` Q. Q. And you've been named as an
`
` Q. Q.
` inventor on several patent and patent
` applications, correct?
`
` A. A. That's correct.
`
` A. A.
`
` Q. Q. Have you been involved with the
`
` Q. Q.
` proceedings at the Patent Office for any
` of those patents or patent applications?
`
` A. A. Meaning what?
`
` A. A.
`
` Q. Q. Have you had interactions with
`
` Q. Q.
` the Patent Office regarding any of those
` patents or patent applications?
`
` A. A. Through my patent attorney, but
`
` A. A.
` not directly.
`
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 3 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 10
`
` BRYAN BERGERON, M.D.
`
` Q. Q. Okay. So have you participated
`
` Q. Q.
` in responses to Office actions?
`
` A. A. Not directly.
`
` A. A.
`
` Q. Q. Have you interacted with your
`
` Q. Q.
` attorney to craft responses to Office
` actions?
`
` A. A. Yes.
`
` A. A.
`
` Q. Q. Have you ever read an Office
`
` Q. Q.
` action?
`
` A. A. Yes.
`
` A. A.
`
` Q. Q. Have you ever -- have any of the
`
` Q. Q.
` patent applications that you filed ever
` gone to appeal?
`
` A. A. I believe there's one going to
`
` A. A.
` appeal now.
`
` Q. Q. Do you know whether an appeal
`
` Q. Q.
` brief was filed in that?
`
` A. A. I don't know.
`
` A. A.
`
` Q. Q. Do you know what an appeal brief
`
` Q. Q.
` is before the Patent and Trademark Office?
`
` A. A. I'm not positive, but -- I'm not
`
` A. A.
` positive.
`
` Q. Q. Is it your understanding that
`
` Q. Q.
` that's a request for the board of patent
`
`Page 11
`
` BRYAN BERGERON, M.D.
` appeals to overturn an examiner's
` rejection?
`
` A. A. I'll follow that. It makes
`
` A. A.
` sense.
`
` Q. Q. But you don't recall whether or
`
` Q. Q.
` not your -- you've filed an appeal brief
` in that case?
`
` A. A. This is early on. This is just
`
` A. A.
` happening. I'm not sure where my attorney
` is in that process. It was his decision
` to do something within the last week or
` two.
`
` Q. Q. When were you asked to be an
`
` Q. Q.
` expert in this case?
`
` A. A. I guess a little less than a
`
` A. A.
` year ago.
`
` Q. Q. And what were you told would be
`
` Q. Q.
` your assignment?
` MS. SHIH: Just caution the
` witness not to reveal any
` attorney/client privileged
` communications. If you can answer
` without doing so, then you can. If
` you cannot answer, then --
`
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`4 (Pages 10 to 13)
`
`Page 12
`
` BRYAN BERGERON, M.D.
`
` A. A. This is an IPR case in general
`
` A. A.
` and -- it's an IPR case.
` BY MR. BERMAN:
`
` Q. Q. And you've been involved in IPRs
`
` Q. Q.
` before?
`
` A. A. Yes, I have. As is on my CV.
`
` A. A.
`
` Q. Q. Prior to this case, had you ever
`
` Q. Q.
` heard of XYREM?
`
` A. A. Yes, I have.
`
` A. A.
`
` Q. Q. How?
`
` Q. Q.
`
` A. A. I'm not sure. I don't recall
`
` A. A.
` exactly. It could have been the press.
` It could have been a lecture or something
` I heard in the hospitals. It's been
` around for years.
`
` Q. Q. Prior to this case, had you ever
`
` Q. Q.
` heard of the active pharmaceutical
` ingredient known as GHB or sodium oxybate?
`
` A. A. I've heard of it.
`
` A. A.
`
` Q. Q. In what capacity?
`
` Q. Q.
`
` A. A. It's also known as the date rape
`
` A. A.
` drug, to put it in that context, at least.
` It's -- yeah.
`
` Q. Q. And you've just heard it in --
`
` Q. Q.
`
`Page 13
`
` BRYAN BERGERON, M.D.
` in what capacity?
`
` A. A. I don't recall. Either --
`
` A. A.
` either in the press or in the medical
` arena in terms of a notification that
` there are drugs that are out there that
` are potential drugs for abuse.
`
` Q. Q. And you know that XYREM is an
`
` Q. Q.
` approved form of GHB, correct?
` MS. SHIH: Objection.
`
` A. A. I don't know. I haven't --
`
` A. A.
` haven't been asked to comment on the
` status of the drug or how it was developed
` or anything. I don't have an opinion on
` that.
` BY MR. BERMAN:
`
` Q. Q. Do you know what the active
`
` Q. Q.
` ingredient in XYREM is?
`
` A. A. I believe it's a gamma
`
` A. A.
` hydroxybutyrate.
`
` Q. Q. So GHB?
`
` Q. Q.
`
` A. A. Yes.
`
` A. A.
`
` Q. Q. Do you recall if you heard of
`
` Q. Q.
` GHB prior to you hearing about XYREM?
`
` A. A. I don't recall.
`
` A. A.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 4 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 14
`
` BRYAN BERGERON, M.D.
`
` Q. Q. So other than knowing that GHB
`
` Q. Q.
` was a date rape drug, what else did you
` know about it?
`
` A. A. At some point what it's used
`
` A. A.
` for, for narcolepsy, for example, for
` treating sleep disorder -- or wakefulness
` or sleep disorders.
`
` Q. Q. When did you hear about that?
`
` Q. Q.
`
` A. A. I don't recall.
`
` A. A.
`
` Q. Q. Was it after XYREM was approved?
`
` Q. Q.
`
` A. A. I don't know.
`
` A. A.
`
` Q. Q. If you were interested in
`
` Q. Q.
` learning more about GHB, how would you
` learn more about it?
` MS. SHIH: Objection. Outside
` the scope.
`
` A. A. It's not something I've
`
` A. A.
` considered.
` BY MR. BERMAN:
`
` Q. Q. If you were interested in
`
` Q. Q.
` learning more about XYREM, how would you
` learn about it?
` MS. SHIH: Same objection.
`
` A. A. Same thing. I haven't been
`
` A. A.
`
`Page 15
`
` BRYAN BERGERON, M.D.
` asked to -- I haven't thought about that.
` It's not why I'm here right now. I
` haven't been asked to evaluate that aspect
` of the drug. I haven't been asked to
` evaluate that part of the pharmacology
` system.
` BY MR. BERMAN:
`
` Q. Q. So you're not particularly
`
` Q. Q.
` interested in XYREM?
` MS. SHIH: Objection.
`
` A. A. I'm not saying either way.
`
` A. A.
` Personally interested in XYREM? I'm not
` sure what you're asking me.
`
` Q. Q. You're not particularly
`
` Q. Q.
` interested in XYREM enough to research it?
`
` A. A. I haven't been; in the past I've
`
` A. A.
` had no -- none that I can recall.
`
` Q. Q. Would the same be true of GHB in
`
` Q. Q.
` general?
`
` A. A. Again, as I recall it, yes.
`
` A. A.
`
` Q. Q. Prior to this case, have you
`
` Q. Q.
` ever heard of restricted drug distribution
` systems?
`
` A. A. I'm familiar with the concept.
`
` A. A.
`
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`5 (Pages 14 to 17)
`
`Page 16
`
` BRYAN BERGERON, M.D.
`
` Q. Q. How?
`
` Q. Q.
`
` A. A. I'm a physician.
`
` A. A.
`
` Q. Q. Can you --
`
` Q. Q.
`
` A. A. So as a physician, I can't --
`
` A. A.
` physicians can't just simply order
` anything they want. So working in a
` hospital you have a formulary and it's an
` approved set of drugs for certain
` purposes. So there are restrictions.
`
` Q. Q. And that goes to a certain class
`
` Q. Q.
` of drugs, correct?
`
` A. A. It does do that, yes.
`
` A. A.
`
` Q. Q. So aside from -- aside from
`
` Q. Q.
` knowing that you can't just simply order a
` drug, what else do you know about
` restricted drug distribution systems?
` MS. SHIH: Objection.
`
` A. A. Again we're talking about me as
`
` A. A.
` a physician or am I talking as a person of
` ordinary skill in the art? How are you
` addressing me?
` BY MR. BERMAN:
`
` Q. Q. I'm addressing you as Dr.
`
` Q. Q.
` Bergeron, the physician.
`
`Page 17
`
` BRYAN BERGERON, M.D.
`
` A. A. Okay, so again -- there's --
`
` A. A.
` you're only allowed to use drugs on a
` formulary working in a hospital and there
` are restrictions on what can be ordered
` for certain types of patients.
`
` Q. Q. So if you were interested in
`
` Q. Q.
` learning more about restricted drug
` distribution systems, how would you learn
` about them?
` MS. SHIH: Objection.
`
` A. A. It's not something I've thought
`
` A. A.
` about.
` BY MR. BERMAN:
`
` Q. Q. Do you know whether there's
`
` Q. Q.
` particular publications that talk about
` restricted drug distribution systems?
`
` A. A. Today, through this -- this
`
` A. A.
` proceeding, I'm aware of what's been
` brought to the table in terms of the
` references here; but before then, no.
`
` Q. Q. So what about in the early
`
` Q. Q.
` 2000s, if you wanted to learn more about
` restricted drug distribution systems, how
` would you learn about it?
`
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 5 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 18
`
` BRYAN BERGERON, M.D.
` MS. SHIH: Objection.
`
` A. A. Again, that's not something I've
`
` A. A.
` been asked to opine on or thought about.
` BY MR. BERMAN:
`
` Q. Q. Have you done anything to
`
` Q. Q.
` prepare for today's deposition?
`
` A. A. Yes.
`
` A. A.
`
` Q. Q. What have you done?
`
` Q. Q.
`
` A. A. Prior to -- I came here on --
`
` A. A.
` MS. SHIH: I just caution the
` witness not to reveal any
` attorney/client privileged
` communications.
` THE WITNESS: Okay.
`
` A. A. I came to New York Sunday night.
`
` A. A.
` I spent this week here so far with the
` attorneys at the table. Prior to that, I
` spent a couple of days over the last, I
` guess, six months or whatever it's been
` working with the materials and coming up
` with the -- my responses, my declarations.
`
` Q. Q. Well, in particular, for today's
`
` Q. Q.
` deposition, prior to meeting with the
` attorneys this week, did you do any other
`
`Page 19
`
` BRYAN BERGERON, M.D.
` preparation?
`
` A. A. I read the materials.
`
` A. A.
`
` Q. Q. What materials?
`
` Q. Q.
`
` A. A. The patents and reviewed my
`
` A. A.
` declarations.
`
` Q. Q. Did you read the references
`
` Q. Q.
` cited in your declarations?
`
` A. A. I'm sure I read certain parts of
`
` A. A.
` them. Not all of them, not all of it. So
` I read the references. I didn't read them
` from page to page, but I read what I
` thought would be relevant.
`
` Q. Q. Did you discuss your testimony
`
` Q. Q.
` with anyone besides your attorneys?
`
` A. A. No.
`
` A. A.
`
` Q. Q. Did you do any separate research
`
` Q. Q.
` on your own other than reviewing the
` documents that you cited in the
` declarations?
`
` A. A. No.
`
` A. A.
`
` Q. Q. I'm showing you what's been
`
` Q. Q.
` marked already as Exhibit 2047, and these
` are actually six declarations, one for
` each of the six IPRs. We'll go through
`
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`6 (Pages 18 to 21)
`
`Page 20
`
` BRYAN BERGERON, M.D.
` them thoroughly here. If you look on the
` front, you'll see every one has the
` patents listed separately.
` So let's start with the '059 IPR
` first. Just go through and take care of
` some formalities. Go to page 24. Is that
` your signature there?
`
` A. A. It is.
`
` A. A.
`
` Q. Q. And then let's look at the '182
`
` Q. Q.
` on page 15. Is that your signature there?
`
` A. A. Yes, it is.
`
` A. A.
`
` Q. Q. Okay. Put that aside for now.
`
` Q. Q.
` The '988, if you go to page 29. Is that
` your signature there?
`
` A. A. Yes, it is.
`
` A. A.
`
` Q. Q. Okay. The '730, go to page 23.
`
` Q. Q.
` Is that your signature there?
`
` A. A. Yes, it is.
`
` A. A.
`
` Q. Q. The '106, go to page 24. Is
`
` Q. Q.
` that your signature there?
`
` A. A. Yes, it is.
`
` A. A.
`
` Q. Q. And then the '107, go to page
`
` Q. Q.
` 23. Is that your signature there?
`
` A. A. It is.
`
` A. A.
`
`Page 21
`
` BRYAN BERGERON, M.D.
`
` Q. Q. So for the most part of today
`
` Q. Q.
` I'm going to be referring to the '059
` report, and as necessary, we'll go through
` the other ones to compare to the extent
` necessary, but you can kind of leave the
` five aside and concentrate on the '059, if
` you don't mind.
`
` A. A. Got it.
`
` A. A.
`
` Q. Q. Okay. So in the '059 Exhibit
`
` Q. Q.
` 2047, let's go to Exhibit 1, which is your
` CV. It starts on page 26.
`
` A. A. Okay, I'm there.
`
` A. A.
`
` Q. Q. Do you see it's dated November
`
` Q. Q.
` 2015?
`
` A. A. Yes.
`
` A. A.
`
` Q. Q. Is that still accurate today?
`
` Q. Q.
`
` A. A. Some minor changes on page 3,
`
` A. A.
` the top of the page, the patent that was
` pending, the second-to-last patent has
` been granted. It's no longer pending.
` I'm sure I've got a few more publications
` distributed through here. That's about
` it.
`
` Q. Q. No changes in Academic
`
` Q. Q.
`
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`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` PAR1053
`IPR of U.S. Patent No. 7,668,730
` Page 6 of 63
`
`

`
`Bryan Bergeron, MD, FACMI - January 21, 2016
`
`Page 22
`
` BRYAN BERGERON, M.D.
` Appointments?
`
` A. A. Same.
`
` A. A.
`
` Q. Q. No changes in Other Professional
`
` Q. Q.
` Positions and Work Experience?
`
` A. A. Work experience, no.
`
` A. A.
`
` Q. Q. So let's go to page 1 under
`
` Q. Q.
` Licensure and Certification, page 1 of the
` CV. Under Licensure and Certification,
` the first one listed there is, "General
` Radiotelephone with Radar Endorsement, FCC
` Extra." Do you see that?
`
` A. A. I do.
`
` A. A.
`
` Q. Q. What is that?
`
` Q. Q.
`
` A. A. That is a license from the FCC
`
` A. A.
` to practice electronics. The first one is
` for telecommunications for it and the
` radar endorsement is to work on radar
` systems, which is what -- I have a
` background in electronics and computers
` prior to my academic work. And the FCC
` Extra is another license and also in
` electronics.
`
` Q. Q. So then in 1984, it says
`
` Q. Q.
` "Medicine and Surgery." I imagine that's
`
`Page 23
`
` BRYAN BERGERON, M.D.
` somewhat different than the first one.
` What is "Medicine and Surgery"?
`
` A. A. It's a license to practice
`
` A. A.
` medicine.
`
` Q. Q. And then in 1990, it says,
`
` Q. Q.
` "Fellow, American College of Medical
` Informatics." What is that?
`
` A. A. Medical informatics is the -- I
`
` A. A.
` did a post-doctoral fellowship in medical
` informatics. And medical informatics is
` the use of computers in medicine, in
` various aspects of medicine.
` And I was elected a fellow in
` 1990.
`
` Q. Q. And what does that mean?
`
` Q. Q.
`
` A. A. Recognized by my peers as a
`
` A. A.
` fellow of the college, so it's an honor.
` It's a certification, as it would be in
` 1990.
`
` Q. Q. When you say "medical
`
` Q. Q.
` informatics is the use of computers in
` medicine," what do you mean by that?
`
` A. A. Well, medical informatics is a
`
` A. A.
` field that involves -- people in the field
`
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