`
`
`
`May 2, 2014
`
`VIA ECF
`
`Hon. Joel A. Pisano, U.S.D.J.
`U.S. District Court for the District of New Jersey
`Clarkson S. Fisher Building & U.S. Courthouse
`402 East State Street
`Trenton, New Jersey 08608
`
`RE: Claim Construction for the ’285 Patent
`AstraZeneca AB, et al. v. Dr. Reddy’s Laboratories, Inc., et al.,
`Civ. Action No. 3:11-cv-02317-JAP-DEA;
`AstraZeneca AB, et al. v. Watson Laboratories, Inc. – Florida, et al.,
`Civ. Action No. 3:13-cv-03038-JAP-DEA; and
`AstraZeneca AB, et al. v. Mylan Pharmaceuticals Inc., et al.,
`Civ. Action No. 3:13-cv-04022-JAP-DEA_______________________
`
`
`Dear Judge Pisano:
`
`We write on behalf of Plaintiffs in the above-captioned ANDA matters.
`
`Pursuant to Paragraph 9 of the proposed Joint Scheduling Order agreed to by
`Plaintiffs and Defendants Mylan, Watson, and Lupin (see ECF Nos. 221 and 221-1
`filed in 3:11-cv-02317-JAP-DEA), Plaintiffs do not believe that any claim term from
`U.S. Patent No. 8,557,285 (the “’285 patent”) needs construction by the Court at this
`time. Instead, claim terms from the ’285 patent should be given their ordinary
`meaning or the meaning consistent with or already identified by the Court for claim
`terms from U.S. Patent No. 6,926,907 (see ECF No. 142 filed in 3:11-cv-02317-JAP-
`DEA). Any claim construction disputes may be addressed through summary
`judgment as the Court has previously held with respect to the ’907 patent (see ECF
`No. 165 filed in 3:11-cv-02317-JAP-DEA).
`
`
`
`Respectfully,
`
`s/ John E. Flaherty
`
`John E. Flaherty
`
`cc: Hon. Douglas E. Arpert, U.S.M.J. (via ECF)
` Counsel of Record (via email)
`
`Thank you for your consideration.
`
`John E. Flaherty
`Partner
`T. 973-639-7903
`F. 973-297-3971
`jflaherty@mccarter.com
`
`
`McCarter & English, LLP
`Four Gateway Center
`100 Mulberry Street
`Newark, NJ 07102-4056
`T. 973.622.4444
`F. 973.624.7070
`www.mccarter.com
`
`BOSTON
`
`HARTFORD
`
`NEW YORK
`
`NEWARK
`
`PHILADELPHIA
`
`STAMFORD
`
`WASHINGTON, DC
`
`WILMINGTON
`
`Page 1
`
`Dr. Reddy's Exh. 1018
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
