Paper No. ____
`Filed: March 31, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`INNOPHARMA LICENSING, INC., INNOPHARMA LICENSING LLC,
`INNOPHARMA INC., INNOPHARMA LLC,
`MYLAN PHARMACEUTICALS INC., and MYLAN INC.,
`Petitioner
`
`v.
`
` SENJU PHARMACEUTICAL CO., LTD.,
`Patent Owner
`
`_________________
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`PATENT OWNER’S MOTION TO EXCLUDE
`UNDER 37 C.F.R. § 42.64(C)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Filed: March 31, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`INNOPHARMA LICENSING, INC., INNOPHARMA LICENSING LLC,
`INNOPHARMA INC., INNOPHARMA LLC,
`MYLAN PHARMACEUTICALS INC., and MYLAN INC.,
`Petitioner
`
`v.
`
` SENJU PHARMACEUTICAL CO., LTD.,
`Patent Owner
`
`_________________
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`PATENT OWNER’S MOTION TO EXCLUDE
`UNDER 37 C.F.R. § 42.64(C)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I.
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`TABLE OF CONTENTS
`
`Dr. Laskar’s Opinions and Testimony Regarding any Issue of Organic
`or Medicinal Chemistry Should Be Excluded Under FRE 702......................... 1
`
`A.
`
`B.
`
`Senju Timely Objected to and Challenged Dr. Laskar’s
`Qualifications During Cross Examination ................................................. 1
`
`Dr. Laskar Is Not Qualified to Offer Opinions on Organic or
`Medicinal Chemistry, or Challenge Those Opinions of Senju’s
`Qualified Expert ............................................................................................. 2
`
`II.
`
`Portions of the Reply Declaration of Dr. Laskar, and Eight New
`Accompanying Exhibits Should be Excluded Under FRE 402 and 403 ......... 8
`
`A.
`
`B.
`
`Senju Timely Objected to the Laskar Reply Declaration and
`Accompanying Exhibits, Upon Which Petitioner Relied in Its
`Reply ................................................................................................................. 8
`
`Dr. Laskar’s Reply Declaration and Supporting Exhibits
`Exceed the Proper Scope of Petitioner’s Reply under 37 C.F.R.
`§ 42.23(b) and Thus Lack Relevance under FRE 402 and Are
`Prejudicial Under FRE 403 .......................................................................... 8
`
`III. Dr. Laskar’s Testimony on Redirect After Consultation with
`Petitioner’s Counsel Should Be Excluded .......................................................... 10
`
`IV. Conclusion ................................................................................................................ 11
`
`
`
`
`
`ii
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`Pursuant to 37 C.F.R. §§ 42.64(c) and 42.61(a), and the Federal Rules of
`
`Evidence, Patent Owner Senju first moves to exclude the Reply Declaration of
`
`Paul Laskar, Ph.D. (EX1104), specifically at least paragraphs 8, 10-13, and 17-19,
`
`and the testimony of Dr. Laskar (EX2114 and EX2272), because Dr. Laskar
`
`completely lacks expertise in organic or medicinal chemistry and, thus, Dr. Laskar
`
`is not qualified by knowledge, skill, experience, training or education necessary to
`
`form an opinion under FRE 702. Second, Senju moves to exclude paragraphs 4-34
`
`of Ex. 1104, and allegedly supporting EX1089, 1092, 1093, 1105, 1106, 1091,
`
`1094 and 1148, because these exhibits lack relevance under FRE 402, as they
`
`exceed the proper scope of Petitioner’s Reply under 37 C.F.R. § 42.23(b), and
`
`because they are prejudicial under FRE 403 to Senju, as Senju is unable to respond
`
`to them. Senju further moves to exclude Dr. Laskar’s testimony at his first cross
`
`examination on redirect, Ex. 2114, 258:14-263:1, because that testimony was
`
`unreliable, having been elicited after consultation with Petitioner’s counsel during
`
`a break, and in light of Dr. Laskar’s repeated refusal to provide responsive,
`
`accurate answers on cross-examination during his cross examination.
`
`I. Dr. Laskar’s Opinions and Testimony Regarding any Issue of Organic or
`Medicinal Chemistry Should Be Excluded Under FRE 702
`A.
`
`Senju Timely Objected to and Challenged Dr. Laskar’s
`Qualifications During Cross Examination
`
`Senju timely objected to Ex. 1104, specifically paragraphs 8, 10-13, and 17-
`
`
`
`1
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`19, under FRE 702 and 37 C.F.R. § 42.65 in objections filed and served March 25,
`
`2016. (Paper 56.) Further, during Dr. Laskar’s cross-examination on his
`
`Declaration (Ex. 2114, 25:21-32:17; 257:14-18) and on his Reply Declaration
`
`(EX2272, 14:10-25:7), Senju extensively challenged and objected to Dr. Laskar’s
`
`lack of qualifications necessary to form an opinion under FRE 702.
`
`B. Dr. Laskar Is Not Qualified to Offer Opinions on Organic or
`Medicinal Chemistry, or Challenge Those Opinions of Senju’s
`Qualified Expert
`
`In his declarations in support of the petition and the reply, Dr. Laskar offers
`
`opinions on, among other things, organic and medicinal chemistry issues to argue
`
`that the instituted claims are allegedly obvious and to challenge the declarative
`
`evidence on secondary considerations submitted by Patent Owner. Dr. Laskar,
`
`however, completely lacks expertise in organic and medicinal chemistry—the
`
`central technology of this proceeding. Accordingly, and as discussed below, Dr.
`
`Laskar’s opinions should be excluded.
`
`Dr. Laskar was cross-examined twice during this proceeding, and each time,
`
`Patent Owner explored his complete lack of relevant expertise. At the outset, Dr.
`
`Laskar held himself out to be an expert in “the field of formulations and drug
`
`delivery, specifically pharmaceutical formulations for ophthalmic administration
`
`including topical aqueous liquid preparations.” (EX2114, 24:3-14.) But Dr.
`
`Laskar has never practiced medicine (EX2114, 28:4-23) and is no longer “an active
`
`
`
`2
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`registered pharmacist” (EX2272, 14:22-15:2). In fact, Dr. Laskar has not
`
`dispensed a drug since the mid-1970s, has never dispensed any bromfenac product,
`
`and does not recall ever dispensing an ophthalmic product containing tyloxapol.
`
`(EX2272, 14:13-15:22.) Since 1982, he has formulated drug products, but he has
`
`never formulated products with bromfenac and has never formulated any NSAID
`
`product containing tyloxapol. (EX2272, 22:1-13.) Nor has Dr. Lasker conducted
`
`any research on bromfenac products. (EX2114, 28:25-29:5.)
`
`Dr. Laskar’s formal education is in general science, pharmacy, and
`
`pharmaceutical sciences, not in chemistry. (EX2272, 22:17-23-15.) He has never
`
`held a faculty position in any chemistry department and never held any faculty
`
`position at all beyond associate professor. (EX2272, 20:10-16.) Dr. Laskar has
`
`only ever submitted two patent applications, and neither is relevant to the ’290 or
`
`’431 patents. (EX2114, 26:3-27:1; EX2272, 16:1-18:7.) He has only authored
`
`eight peer reviewed publications in his entire career, the last one in 1993 related to
`
`sunscreen products, and the most recent one before that in 1977. (EX2272, 18:13-
`
`19:15.) None of his publications relates to antioxidants, a topic on which he opines
`
`extensively in his Reply Declaration. (EX2272, 19:11-15, 20:6-9.) Dr. Laskar is
`
`not a member of the American Chemical Society and has never published anything
`
`in the Journal of the American Chemical Society. (EX2272, 24:1-8.) To date, he
`
`has only ever given four presentations—none on the use of antioxidants—and the
`
`
`
`3
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`most recent was 24 years ago. (EX2272, 20:20-21:9.) After an extensive review
`
`of his credentials during his cross examination on his Reply Declaration, Dr.
`
`Laskar readily admitted that he was not an expert in medicinal or organic
`
`chemistry, including antioxidant chemistry. (EX2272, 20:17-21:5.) As a result,
`
`with respect the central issues Dr. Laskar and Petitioners have raised in this
`
`proceeding, Dr. Laskar has no experience whatsoever, and therefore he is
`
`unqualified to provide expert testimony in this proceeding.
`
`Dr. Laskar not only is unqualified to offer his own opinions but also is
`
`unqualified to challenge the opinions of Patent Owner’s expert Dr. Davies. For
`
`example, Dr. Laskar contends that the compound tyloxapol is an “alkylphenol,”
`
`like those disclosed in the Doi patent (EX2025). (EX1104 at ¶ 17.) A phenol,
`
`however, is by definition a compound having one or more hydroxy (-OH) groups
`
`attached to a phenyl ring. Tyloxapol is therefore by definition not an alkylphenol
`
`and is not taught by Doi, contrary to Dr. Laskar’s opinions.
`
`In addition, Dr. Laskar agrees that polysorbate 80 is an oxidizing agent
`
`because it degrades to produce peroxides and hydroperoxides, citing Dr. Davies’
`
`declaration, but then contends that tyloxapol somehow is an antioxidant. (EX1104
`
`at ¶¶ 8,10-11, n.6.) Contrary to Dr. Laskar’s opinion, the portion of Dr. Davies’
`
`declaration to which Dr. Laskar cites establishes with literature support (see
`
`EX2097) that both polysorbate 80 and tyloxapol degrade to produce peroxides and
`
`
`
`4
`
`
`
`hydroperoxides because they both contain polyoxyethylene chains. (EX2105 at ¶¶
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`71-74.) Dr. Laskar admits that tyloxapol is an “ethoxylated” surfactant which
`
`contains a polyoxyethylene chain. (EX1104 at ¶ 2.) Given his agreement that
`
`polysorbate 80 is an antioxidant rather than an oxidizing agent, and the fact
`
`polysorbate 80 and tyloxapol share the same ethoxylated chain in common, Dr.
`
`Laskar cannot credibly contend that tyloxapol somehow is an antioxidant rather
`
`than an oxidizing agent. Dr. Laskar’s reliance on Dr. Davies’ opinion regarding
`
`polysorbate 80’s polyoxyethylene chain, coupled with his unsupported rejection of
`
`Dr. Davies’ opinion regarding tyloxapol’s polyoxyethylene chain, demonstrates
`
`Dr. Laskar’s complete lack of expertise in this area and the unreliability of his
`
`opinions.
`
`Moreover, Dr. Laskar’s reliance on a series of wholly irrelevant references
`
`that teach the use of tyloxapol in biological systems to prevent biologic injury (see
`
`EX1092, EX1093, EX1094, EX1105, EX1148) further establishes that Dr. Laskar
`
`is unqualified to offer opinions regarding organic or medicinal chemistry. As Dr.
`
`Davies explained in the parallel district court litigation regarding the ’431 and ’290
`
`patents, bromfenac is subject to oxidation in aqueous ophthalmic solutions in the
`
`presence of oxygen (O2). (EX2267.) EX1092 and EX1093 cited by Dr. Laskar
`
`study the ability of tyloxapol to prevent biologic injury from “partially reduced O2
`
`species,” which Dr. Laskar agrees are not oxygen. (EX2267 at ¶ 29; EX2272,
`
`
`
`5
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`130:4-8.) “Partially reduced O2 species” are simply not present in bromfenac
`
`ophthalmic solutions. (Id.) Dr. Davies further explained that EX1094 similarly
`
`studies the use of tyloxapol in biological systems to “inhibi[t] activation of the
`
`transcription factor nuclear factor-kappa B . . .,” as well as tyloxapol’s ability to
`
`serve as an antioxidant for hydroxyl radicals, generated in the presence of ferrous
`
`ions, and hypochlorous acid, generated from ‘leukocyte myeloperoxidase.” (Id.)
`
`Hydroxyl radicals and hypochlorous acid are also not oxygen and are similarly not
`
`present in bromfenac ophthalmic solutions. (Id.) These references cited by Dr.
`
`Laskar are therefore not relevant to bromfenac’s oxidative degradation, and
`
`nothing in these references establishes that tyloxapol would behave as an
`
`antioxidant for O2 in an aqueous solution of bromfenac. (Id.) Indeed, if tyloxapol
`
`did inhibit O2, its administration as a therapeutic agent by aerosol treatment to the
`
`lungs as in EX1093 (see 3:2-5) would be potentially fatal in vivo. In sum, it is not
`
`surprising that Dr. Laskar’s opinions in his reply declaration (EX1104) are
`
`inconsistent with the opinions offered by Dr. Davies, an undisputed expert in
`
`organic and medicinal chemistry.
`
`To qualify as an expert, a witness must have “knowledge, skill, experience,
`
`training, or education” relevant to the evidence or facts at issue. Fed. R. Evid. 702.
`
`In addition, an expert must be more than simply “qualified” in any discipline. The
`
`expert must be qualified in the subject matter about which he or she proposes to
`
`
`
`6
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`testify. See Sundance, Inc. v. DeMonte Fabricating Ltd., 550 F.3d 1356, 1362
`
`(Fed. Cir. 2008) (expert who may have been qualified to testify as to patent office
`
`procedures not qualified to testify on patent validity because of a lack of
`
`experience and training in the pertinent art). The Federal Circuit has stated that
`
`“[a]dmitting testimony from a [witness], with no skill in the pertinent art, serves
`
`only to cause mischief and confuse the factfinder.” Sundance, 550 F.3d at 1362.
`
`Under Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 597 (1993) and
`
`Fed. R. Evid. 702, courts and the Board are charged with a “gatekeeping role,” the
`
`objective of which is to ensure that expert testimony admitted into evidence is both
`
`reliable and relevant. Because Dr. Laskar, by his own admission, has no training or
`
`experience in organic or medicinal chemistry, which is the very subject matter Dr.
`
`Laskar and Petitioners have placed at issue in this proceeding, Dr. Laskar’s
`
`opinions fail to comply with Fed. R. Evid. 702. Dr. Laskar plainly lacks both the
`
`knowledge and experience required to express the opinions he provides in EX1003
`
`and EX1104.
`
`Dr. Laskar’s purported expertise in the fields of formulation and drug
`
`delivery does not qualify him as an expert in the specific chemical technology at
`
`issue. See Extreme Networks, Inc. v. Enterasys Networks, Inc., 395 F. App’x 709,
`
`715 (Fed. Cir. 2010) (“General experience in a related field may not suffice when
`
`experience and skill in specific product design are necessary to resolve patent
`
`
`
`7
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`issues.”). And because he is unqualified, Dr. Laskar’s opinions expressed in
`
`EX1104, specifically at least paragraphs 8, 10-13, and 17-19, 2114, and EX2272
`
`regarding organic or medicinal chemistry are unreliable and cannot assist the trier
`
`of fact as Fed. R. Evid. 702 requires. Accordingly, the Board should exclude his
`
`testimony from evidence. Likewise, Dr. Laskar’s opinions expressed in his
`
`opening declaration (EX1003) involving organic and medicinal chemistry should
`
`be afforded no weight given Dr. Laskar’s admitted lack of expertise in these fields.
`
`II. Portions of the Reply Declaration of Dr. Laskar, and Eight New
`Accompanying Exhibits Should be Excluded Under FRE 402 and 403
`A.
`
`Senju Timely Objected to the Laskar Reply Declaration and
`Accompanying Exhibits, Upon Which Petitioner Relied in Its
`Reply
`
`In objections filed and served March 25, 2016, Senju objected to EX1104,
`
`specifically ¶¶ 4-34, and allegedly supporting EX1089, 1092, 1093, 1105, 1106,
`
`1091, 1094 and 1148, under FRE 402 and 403 as being directed to improper new
`
`testimony from Dr. Laskar that tyloxapol allegedly is an antioxidant. (Paper 56.)
`
`B. Dr. Laskar’s Reply Declaration and Supporting Exhibits Exceed
`the Proper Scope of Petitioner’s Reply under 37 C.F.R. § 42.23(b)
`and Thus Lack Relevance under FRE 402 and Are Prejudicial
`Under FRE 403
`
`In its Reply (Paper 56), Petitioner relies upon the Laskar Reply Declaration
`
`(EX1104) for an entirely new argument for why a person of ordinary skill in the art
`
`allegedly would have reason to modify Ogawa in view of Sallmann, relying on
`
`
`
`8
`
`
`
`eight new references. (Reply, Paper 56 at 11.) In EX1104, Dr. Laskar posits, for
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`the first time, that:
`
`Knowing that polysorbate 80 was the cause of oxidative degradation, the
`skilled artisan would have replaced the polysorbate 80 with another non-
`ionic surfactant that did not share polysorbate 80’s liability. The skilled
`artisan would have known that tyloxapol, like polysorbate 80, is not only a
`non-ionic surfactant commonly used in ophthalmic formulations but, unlike
`polysorbate 80, it also has antioxidant properties.
`
`(EX1104, ¶ 7 (emphasis added).) In Dr. Laskar’s opening declaration (EX1003),
`
`his first deposition, and the Petition, however, not once did Dr. Laskar or Petitioner
`
`argue that a person of ordinary skill in the art would replace polysorbate 80 with
`
`tyloxapol because tyloxapol allegedly is an antioxidant. This is an entirely new
`
`argument, to which Patent Owner has had no opportunity to respond. In
`
`connection with this new argument, Dr. Laskar cites eight new references and
`
`discusses each reference in detail, blatantly mischaracterizing each reference. (See
`
`EX1089, EX1106, EX1091, EX1094, EX1080, EX1105, EX1148, EX1092,
`
`EX1093.) In fact, Dr. Laskar devotes 30 paragraphs of his 39-paragraph reply
`
`declaration to this entirely new argument. (EX1104, ¶¶ 4-34.)
`
`These portions of EX1104 and the exhibits listed above should be excluded
`
`because they lack relevance under FRE 402, as they exceed the proper scope of
`
`Petitioner’s Reply under 37 C.F.R. § 42.23(b). Arguments in support of a reply
`
`
`
`9
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`“may only respond to arguments raised in the corresponding . . . patent owner
`
`response.” Id. As explained in the Trial Practice Guide, “new evidence necessary
`
`to make out a prima facie case for [] unpatentability” and “new evidence that could
`
`have been presented in a prior filing” are improper. 77 Fed. Reg. 48767. “[A]
`
`reply that raises a new issue or belatedly presents evidence will not be considered
`
`and may be returned.” Id. Moreover, these portions of EX1104 and the exhibits
`
`listed above should be excluded under FRE 403 because they were first presented
`
`at the Reply stage and Patent Owner is prejudiced by being unable to respond to
`
`the untimely evidence and arguments therein.
`
`III. Dr. Laskar’s Testimony on Redirect After Consultation with Petitioner’s
`Counsel Should Be Excluded
`
`
`
`During cross examination, Dr. Laskar was generally non-responsive and
`
`gave inconsistent testimony on even the most basic questions, requiring Patent
`
`Owner to repeatedly impeach him with his prior sworn testimony. In some cases,
`
`Dr. Laskar provided non-responsive comments that failed to actually answer the
`
`question that was presented to him the first, second or even third time. (See, e.g.,
`
`EX2114, 48:19-50:4; 98:4-22; 101:13-102:10; 103:12-24; 104-2-20; 115:24-
`
`116:17; 134:11-135:9; 136:16-137:19; 220:14-25.) In other cases, he did not
`
`answer questions presented to him about disclosures in references, but rather
`
`admitted only that the “wording” referenced by Patent Owner’s counsel appeared
`
`in the reference. (See, e.g., id., 53:1-13 (“I see that wording.”); 54:9-55:15 (“That’s
`
`
`
`10
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`what’s stated there.”); 136:2:15.) In still other cases, Dr. Laskar gave testimony
`
`inconsistent with his prior sworn testimony, and Patent Owner’s counsel repeatedly
`
`was forced to impeach Dr. Laskar with that prior testimony to get an accurate
`
`response. (See, e.g., id., 85:17-88:1; 172:7-173:4, 187:2-188:23; 253:18-254:17.)
`
`
`
`On redirect, the opposite was true. When barely prompted by Petitioner’s
`
`counsel, Dr. Laskar gave lengthy answers in a contrived attempt support his
`
`statements in his Declaration. (Id., 258:14-263:1.) Yet on recross, Dr. Laskar
`
`readily admitted that prior to redirect and during a break, he and Petitioner’s
`
`counsel discussed “the areas in which [Petitioner’s counsel] would ask questions.”
`
`(Id. at 264:16-20). Patent Owner timely objected to this improper tactic and
`
`moved to strike the entirety of Dr. Laskar’s redirect testimony. (Id., 264:21-23.)
`
`
`
`In light of Dr. Laskar’s repeated refusals on cross examination to provide
`
`responsive, accurate answers, and in light of the discussions between Dr. Laskar
`
`and Petitioner’s counsel prior to redirect, Dr. Laskar’s testimony elicited on
`
`redirect should be excluded as unreliable. In sum, in light of Dr. Laskar’s evasive
`
`tactics during his cross examination, Dr. Laskar’s redirect testimony should be
`
`excluded as prejudicial, under FRE 403.
`
`IV. Conclusion
`For the reasons stated herein, Patent Owner respectfully requests that
`
`EX1104, paragraphs 4-34, the testimony of Dr. Laskar (EX2114 and EX2272), and
`
`
`
`11
`
`
`
`EX1089, 1092, 1093, 1105, 1106, 1091, 1094 and 1148 be excluded from these
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`By: /Bryan C. Diner/
`Bryan C. Diner, Lead Counsel
`Registration No. 32,409
`
`
`
`
`12
`
`proceedings.
`
`
`
`Date: March 31, 2016
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing PATENT
`
`
`
`OWNER’S MOTION TO EXCLUDE UNDER 37 C.F.R. § 42.64(C) was
`
`served on March 31, 2016, via email directed to counsel of record for the Petitioner
`
`at the following:
`
`Jitendra Malik, Ph.D
`Jitty.malik@alston.com
`
`Bryan Skelton, Ph.D.
`Bryan.skelton@alston.com
`
`Lance Soderstrom
`Lance.soderstrom@alson.com
`
`Hitetada James Abe
`James.abe@alston.com
`
`Joseph M. Janusz
`Joe.janusz@alston.com
`
`
`
`
`
`/Bradley J. Moore/
`Bradley J. Moore
`Litigation Legal Assistant
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`
`
`
`Dated: March 31, 2016
`
`
`
`13
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
