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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`Case IRP2015-00990 and IPR2015-01093
`Patent 7,056,886
`-----------------------------------x
`COALITION FOR AFFORDABLE DRUGS II LLC,
`Petitioner,
`
`- against -
`
`NPS PHARMACEUTICALS, INC.,
`Patent Owner.
`-----------------------------------x
`March 30, 2016
`9:55 a.m.
`
`** HIGHLY CONFIDENTIAL **
`
`Videotaped Deposition of JOHN
`CARPENTER, Ph.D., taken by Petitioner,
`pursuant to Notice, held at the offices of
`Troutman Sanders LLP, 875 Third Avenue,
`New York, New York, before Jineen Pavesi,
`a Registered Professional Reporter,
`Registered Merit Reporter, Certified
`Realtime Reporter and Notary Public of the
`State of New York.
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`212-279-9424
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`Veritext Legal Solutions
`www.veritext.com
`
`CFAD Exhibit 1043
`CFAD v. NPS
`IPR2015-01093
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`212-490-3430
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`A P P E A R A N C E S :
`MERCHANT & GOULD P.C.
`1701 Duke Street
`Suite 310
`Alexandria, Virginia 22314
` Attorneys for Petitioner
`BY: MATTHEW L. FEDOWITZ, ESQ.
` mfedowitz@merchantgould.com
` MARY BRAM, ESQ.
` mbram@merchantgould.com
`
`TROUTMAN SANDERS LLP
`875 Third Avenue
`New York, New York 10022
` Attorneys for Patent Owner
`BY: JOSEPH R. ROBINSON, ESQ.
` joseph.robinson@troutmansanders.com
` HEATHER MOREHOUSE ETTINGER, Ph.D.,
` ESQ.
` heather.ettinger@troutmansanders.com
`
`ALSO PRESENT:
`MARGO FURMAN, Ph.D, JD, Shire
`GEORGE LIBBARES, The Video Technician
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`www.veritext.com
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` THE VIDEO TECHNICIAN: I am
`George Libbares, certified video
`specialist representing Veritext New York,
`the date today is March 30, 2016, and the
`time is 10:02 a.m.
` This deposition is being held
`at Troutman Sanders, LLP, located at 875
`Third Avenue, New York, New York, and is
`being taken by counsel for the petitioner.
` The caption of this case is
`Coalition for Affordable Drugs II LLC,
`petitioner, versus NPS Pharmaceuticals,
`Inc., patent owner, this case is filed
`before the U.S. Patent and Trademark
`Office, before the Patent Trial and Appeal
`Board, Case No. IPR 2015-00990.
` The name of the witness is John
`Carpenter, Ph.D. --
` MR. ROBINSON: This is a
`deposition combined IPRs, there is another
`one also, 1093.
` THE VIDEO TECHNICIAN: I
`didn't have that information, thank you.
` At this time the attorneys will
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`Page 4
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`state their appearances and our court
`reporter, Jineen Pavesi representing
`Veritext New York, will swear in the
`witness and we can proceed.
` MR. FEDOWITZ: Matthew Fedowitz
`from Merchant & Gould, Washington, on
`behalf of petitioner.
` MS. BRAM: Mary Bram on behalf
`of petitioner.
` MR. ROBINSON: Joe Robinson,
`Heather Ettinger and Margo Furman on
`behalf of patent owner NPS.
` I would like to designate this
`transcript highly confidential.
`J O H N C A R P E N T E R,
`having first been duly sworn by a Notary
`Public of the State of New York, was
`examined and testified as follows:
`EXAMINATION BY
`MR. FEDOWITZ:
` Q. Good morning, Dr. Carpenter.
` A. Morning.
` Q. Could you please state your
`full name for the record?
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` CARPENTER - HIGHLY CONFIDENTIAL
` A. John Frank Carpenter.
` Q. Before we get started, a few
`ground rules; I'm going to ask you
`questions, you'll respond to the best of
`your ability.
` If you answer yes or no, please
`articulate yes or no, don't nod, the
`stenographer has to be --
` A. Yes.
` Q. If you have a question, I'll
`happily clarify for you and it should go
`smoothly.
` A. Okay.
` Q. How did you prepare for this
`deposition?
` A. For this particular event, I
`read through all the documents, read
`through my declaration, read through the
`deposition for Dr. Palmieri and reviewed
`several of the different papers that we --
`have been included from both declarations.
` Q. When did you start that
`process?
` A. For this specific event?
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` Q. Yes.
` A. Probably Friday last week.
` Q. Before that, did you start
`preparing at all?
` A. I have been obviously working
`on this case, looking at the literature
`quite a bit, but specifically preparing
`for this event, no, I think I started
`Friday.
` Q. Did you meet with any
`attorneys?
` A. Yesterday afternoon.
` Q. Just yesterday afternoon?
` A. Yes.
` Q. When did -- you're from
`Colorado, is that correct?
` A. Right.
` Q. When did you arrive in New
`York?
` A. What time did I get here, 2
`o'clock yesterday afternoon.
` Q. Who did you meet with?
` A. I met with Joe and Heather.
` Q. Anybody else?
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` CARPENTER - HIGHLY CONFIDENTIAL
` A. No.
` Q. I am not interested in any of
`your conversations with them.
` Did you review any documents
`during that meeting?
` A. There was one paper that was
`missing from my file that I looked at
`briefly and then there were a couple of my
`own research papers I had sent over in
`advance of this that I pulled out, but I
`didn't really go through them.
` Q. You mentioned one paper that
`was missing from your file?
` A. Yes.
` Q. What paper was that?
` A. Lomize, I believe.
` Q. Why did you look at that?
` A. It was discussed in
`Dr. Palmieri's deposition and I didn't
`have it in my notebook of things that I
`reviewed.
` Q. Any other reasons?
` A. No.
` I just wanted to see what was
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` CARPENTER - HIGHLY CONFIDENTIAL
`in it, it was physically missing from the
`notebook.
` Q. So you never saw it before
`yesterday?
` A. No, I hadn't looked at it
`before.
` Q. Then you mentioned that there
`were a couple of other of your research
`papers that you took a look at.
` What were those?
` A. One of them is a paper on
`insulin analogs by Teska et al., and the
`other one is a paper on glucagon
`freeze-dry.
` Q. For Teska -- how do you spell
`Teska?
` A. T-E-S-K-A.
` Q. The Teska et al., what was that
`paper?
` A. On insulin analogs, stability
`of insulin analogs.
` Q. Why did you take a look at
`that?
` A. Just to remind myself what --
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` CARPENTER - HIGHLY CONFIDENTIAL
`which ones we studied and kind of the
`relative stabilities.
` Q. When did you study those?
` A. We probably started three or
`four years ago as part of a thesis.
` Q. Whose thesis?
` A. Teska, Brandon Teska.
` Q. Is there anything else about
`that article that you thought was
`important?
` A. It is an example of how
`changing a residue or two in a peptide or
`protein can greatly alter its
`physiochemical properties and its
`stability.
` Q. So you're saying changing a
`residue or two can greatly alter chemical
`properties?
` A. Physiochemical properties, in
`this case storage stability.
` Q. I think you mentioned a moment
`ago that you also looked at another paper.
` A. Right.
` Q. One of your research papers?
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` CARPENTER - HIGHLY CONFIDENTIAL
` A. It is a research paper, the
`first author is Wei-Jie Fang, F-A-N-G,
`former post-doc.
` Q. Why did you review that paper?
` A. It is a paper on glucagon
`stabilization during freeze-drying and
`storage.
` Q. Do you recall when that was
`published?
` A. Probably two years ago, I am
`not positive.
` Q. So within the last two years?
` A. Yeah, it could be a little
`earlier though.
` Q. You said Fang was one of your
`students?
` A. He is a former post-doc.
` Q. Why did you review that paper?
` A. I wanted to remind myself what
`assays we used and what degradation
`pathways we studied in glucagon.
` Q. Did you look at any other
`papers?
` A. I don't recall, I don't think
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` CARPENTER - HIGHLY CONFIDENTIAL
`so.
` Q. I am going to give you a
`document that we're going to mark as
`Carpenter Exhibit 94.
` MR. FEDOWITZ: Just for the
`record, this has also been previously
`marked as NPS Exhibit 2043 in IPR
`2015-9900, and I believe there is a
`corresponding exhibit that's identical in
`the 1093 IPR.
` Is that correct? John Carpenter
`CV.
` MR. ROBINSON: Yes.
` (Carpenter Exhibit 94, John
`Carpenter CV, was marked for
`identification, as of this date.)
` Q. Dr. Carpenter, you recognize
`this document?
` A. Yes.
` Q. Did you prepare this document?
` A. Yes.
` Q. What is this document?
` A. This is my CV.
` Q. When did you prepare this?
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` CARPENTER - HIGHLY CONFIDENTIAL
` A. I have to look at it to tell
`you which version it is.
` (Witness perusing document.)
` A. Well, the last papers are from
`2013, so it was probably either late 2013
`or early 2014.
` Q. How do you recognize that?
` A. If you go to page 39 and look
`above commentaries, for example, there is
`Middaugh et al. paper and Hassett et al.,
`these were papers we were preparing at
`that time, so I'm guessing it is late
`2013.
` Q. Do you have a more recent
`version of your CV?
` A. I don't think so.
` Q. Is that because there is
`nothing new to add to it or you just
`haven't updated it?
` A. I just haven't updated it, I
`haven't been forced to update it by the
`university.
` Q. Since 2013, and this version of
`this paper, have you published or been
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` CARPENTER - HIGHLY CONFIDENTIAL
`named as an author on any additional
`papers?
` A. Oh, yes, several.
` Q. How many?
` A. Guessing, maybe 15 or 20.
` Q. Do any of those 15 or 20 papers
`relate to glucagon?
` A. Yes, let's look here, let's see
`if the Fang paper shows up on here.
` (Witness perusing document.)
` A. One of them is probably that
`glucagon paper -- no, wait, here it is,
`sorry, 187 is the glucagon paper, so,
`yeah, none of the new ones would relate to
`glucagon.
` Q. Do any of the new ones relate
`to GLP-2?
` A. No.
` Q. Do any of the new ones relate
`to lyophilization?
` A. Probably.
` Q. Can you tell me more about
`that.
` A. That's what I have to think
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` CARPENTER - HIGHLY CONFIDENTIAL
`about -- lyophilization studies come and
`go in the lab, so I'm just trying to think
`in the last three years, besides -- I
`mean, we've got several we've completed,
`at least one of them I'm ready to revise
`the final draft of the paper; I really
`don't remember, I could check on PubMed
`real quick and tell you, but I don't
`remember.
` Q. Maybe at one of the breaks you
`can do that.
` A. Yes, I will do that.
` Q. Do any of these 15 or 20 papers
`since 2013 relate to stabilization of
`proteins or peptides?
` A. Yes.
` Q. Can you tell me about these.
` A. There would be several.
` Most of them, many of them
`would relate to stabilization of
`monoclonal antibodies.
` Peptides, the insulin paper at
`this point -- well, yeah, manuscript
`under review, so Teska et al., 2013, was
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` CARPENTER - HIGHLY CONFIDENTIAL
`being reviewed by the sponsor of the
`project, so that one would have been
`submitted after this point, after this CV
`was prepared and was published later, so
`that's on insulin.
` We had another paper from Teska
`on insulin in which we actually just
`studied a size exclusion chromatography
`method.
` Based on what's formally
`defined as peptides, I think that's all
`the peptide papers.
` We had several
`other -- we had some other vaccine papers
`that were -- I mean, Hassett et al., for
`example, has been posed as a freeze-dry
`paper, those vaccines were recombinant
`protein base but they were large enough
`proteins that would probably not be
`considered peptides.
` And I'll look during a break,
`to remind myself if we had others.
` Q. I would appreciate that.
` A. Yeah, I will.
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` CARPENTER - HIGHLY CONFIDENTIAL
` Q. We're taking a look at your CV
`again, let's start from the top.
` You're still in the department
`of pharmaceutical sciences at the
`University of Colorado, Denver?
` A. Yes.
` Q. Is that different than
`University of Colorado, Boulder?
` A. Yes.
` Q. Can you tell me the difference.
` A. University of Colorado,
`Boulder, is located in Boulder; University
`of Colorado, Denver, encompasses the
`downtown Denver campus and the Anschutz
`medical campus.
` Q. Is there a relationship between
`the two?
` A. Well, yeah, they are both under
`the same central administration, same
`president's office, we have independent
`chancellors, we obviously have research
`and education programs between the two
`campuses.
` Q. Does the University of
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` CARPENTER - HIGHLY CONFIDENTIAL
`Colorado, Denver, house the College of
`Pharmacy?
` A. The Anschutz medical campus
`does.
` Q. Does the Boulder campus have a
`College of Pharmacy?
` A. No.
` Q. Do they have a medical school?
` A. No.
` Q. Any health science professional
`programs?
` A. No.
` Q. Then we go down below that and
`you have listed under Roman II your
`education, it says here you received your
`B.S. in zoology in 1978 from Duke, magna
`cum laude.
` Can you tell me about the
`courses that you took for your zoology
`degree.
` A. Sure.
` It was initially a focus on
`botony and zoology with specialization in
`marine biology, but just the way the
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` CARPENTER - HIGHLY CONFIDENTIAL
`credits worked out it was easier to
`graduate on time through zoology.
` So typically you would take a
`curriculum, very similar to what premeds
`would, you would have freshman chemistry,
`calculus, sophomore year you would have
`organic chemistry, cell biology, there
`were some specific botony/zoology courses,
`biochemistry, genetics, things like that.
` Q. Certain electives in that
`department as well?
` A. Certain electives.
` Q. Focusing on zoology?
` A. Yeah, one in particular was
`invertebrate zoology that we focused on
`and that was actually a special course
`offered to teach scientific writing, so it
`was a small number of students working
`closely with the professor.
` Q. Did you have a minor at all?
` A. No, not at Duke.
` Q. Then you followed that with a
`master's degree from Oregon State
`University?
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` CARPENTER - HIGHLY CONFIDENTIAL
` A. Yes.
` Q. What prompted you to go all the
`way across the country to Oregon?
` A. There was a professor there
`working on aspects of metabolism for
`organisms that are called brine shrimp,
`sea monkeys you might have seen on the
`back of comic books.
` Anyways, I was really
`interested in how organisms adapt to
`extreme environments and he studied that
`so I wanted to go work with him.
` Q. Can you tell me about your
`course work during your master's program.
` A. A lot of biochemistry, almost
`in part repeating the biochemistry series
`that we had at Duke, but more intensive.
` And some independent study, I
`was working on amino acids at the time, so
`I had independent study with the
`biochemistry professor.
` There we had immunology, again
`more advanced zoology study courses,
`outstanding vertebrate biology course, so
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` CARPENTER - HIGHLY CONFIDENTIAL
`it was kind of a combination of
`biochemistry, biology, zoology classes.
` Q. Here you have a biochemistry
`minor?
` A. Right.
` Q. There is a lot of biochemistry
`courses, can you just give me a quick
`overview of the difference between the
`courses you took.
` A. If you're familiar with
`biochemistry classes, which you might be
`from your background, there is a textbook
`called Lehninger that's used a lot in
`undergraduate and graduate biochemistry
`classes, we pretty much went through
`Lehninger, so that would encompass kind of
`basic classes on amino acids, protein
`structure function, DNA, transcription
`translation, a lot on metabolism,
`metabolic pathways, an awful lot,
`glycolysis, kreb's cycle, things like
`that.
` Q. You finished that in three
`years?
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` A. Right.
` Q. Then after that you have listed
`here you pursued your doctorate in biology
`in Louisiana, so you came back sort of to
`the middle.
` Are you from the east coast --
` A. I'm from Texas.
` Q. So what prompted you to go to
`the University of Louisiana at Lafayette
` A. Well, in the interim there I
`worked for a lab in Texas and then
`Professor Steve Hahn was a graduate
`student, senior graduate student, when I
`was working on my master's, and he had
`become a professor in Louisiana.
` Again, he was working in areas
`where I was really interested and I was
`tired of being a shrimp farmer and he had
`just started his lab and I went and became
`his grad student.
` Q. Can you tell me about your
`experiences, course work, research, while
`you were there at the University of
`Louisiana?
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` A. Sure.
` The course work was in the
`department primarily focused on biology,
`evolutionary and environmental biology.
` So classes on everything from
`crustation evolution to ecology classes,
`so it was much more biology.
` And then the classes that I
`took, elective classes, things like
`physical chemistry, trying to think of the
`other chemistry classes, I remember that
`one in particular, and then -- oh, did
`you ask about research or just classes?
` Q. Sort of in series, classes,
`course work and your experience.
` A. Okay.
` The experience, that was more
`biochemistry research, I did enzyme
`purification and characterization on both
`ischemic heart tissue, I had a grant
`funded -- a fellowship funded by the
`American Heart Association, local chapter.
` Also more metabolic work on
`brine shrimp, and some papers, studies
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` CARPENTER - HIGHLY CONFIDENTIAL
`also that weren't part of my thesis, but I
`worked with Dr. Hahn that we published on
`enzyme behavior in vitro.
` Sow the research was mostly
`biochemistry and enzymology.
` Near the end of that time is
`when I met and got recruited by Professor
`Crowe at U.C. Davis, so while I was
`wrapping up things for my Ph.D. I started
`working on my project for him, which
`involved enzyme stabilization during
`freeze stalling and freeze-drying.
` So I started that in Louisiana
`just to get a jump on things.
` Q. When you say you started it,
`how long before you finished your Ph.D.
`did you start that?
` A. I'm thinking I was wrapping up
`at the end of '85, probably three or four
`months before we left Louisiana to go to
`California I started working on enzyme
`stabilization.
` Q. What was your thesis on?
` A. It was on -- well, the effects
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` CARPENTER - HIGHLY CONFIDENTIAL
`really of acidic pH environments on
`metabolism and enzyme function using
`ischemic heart tissue and what's called
`the assisted embryo of brine shrimp as
`model systems.
` Q. Heart tissue, what type of
`organism is heart tissue?
` A. That was rat heart work.
` Q. So under Roman III you have
`your professional experience listed in
`chronological order starting when you were
`a graduate student at Oregon State all the
`way to '92.
` I guess a moment ago you hinted
`at shrimp farming and that was after you
`finished your master's --
` A. Correct.
` Q. -- and was that while you
`were getting your Ph.D.?
` A. No, that was before.
` Q. And that related to I guess you
`applied what you knew from your master's
`and bachelor's degree?
` A. No, not actually.
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` CARPENTER - HIGHLY CONFIDENTIAL
` When I was a senior at Duke, I
`was recruited by a group of investors from
`Texas to go to Costa Rica to work at a
`shrimp farm there they had invested in and
`the contacts I made there led to the job.
` Q. What is a shrimp farm?
` A. You get mommy and daddy shrimp,
`in Costa Rica they would go out in the
`ocean, catch them, bring them in, breed
`them, they produce eggs and larvae that
`grow up in tanks and in Texas we did all
`that part in a big greenhouse and they
`would get big enough you would drop them
`in large ten, 15 acre ponds and you would
`feed them purina shrimp chow until they
`grow up and then you harvest them and sell
`them.
` Q. That sounds like quite an
`experience.
` A. It was interesting, but it was
`farming.
` Q. Understood.
` Following that you had a
`graduate student experience while you were
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` CARPENTER - HIGHLY CONFIDENTIAL
`in Louisiana and then you had your
`post-doctoral associate experience at U.C.
`Davis?
` A. Yes.
` Q. And in that position, can you
`tell me about what your job duties were
`and also -- let's just start with what
`your duties were.
` A. My duties were to perform
`research on protein stabilization under an
`NSF grant that Professor Crowe had, to
`hypothesize and elucidate and test
`mechanisms for stabilization of proteins
`during freezing and freeze-drying.
` Q. And did you have any other
`duties?
` A. As part of that time I also
`taught a class, physiology for nonscience
`majors, I was asked to teach, so I taught
`that part of the time.
` Other duties would include
`preparing -- helping prepare grant
`proposals, working with visiting
`scientists.
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` Q. Were any of those grant
`proposals or work with visiting
`scientists, did any of that encompass
`working with glucagon?
` A. No.
` Q. Did any of that encompass
`working with the lyophilization of
`proteins and peptides?
` A. Yes.
` Q. Can you tell me about that.
` A. The work was usually -- not
`usually, always -- with model enzymes, so
`we could easily measure activity before
`and after and one of the original goals
`was just to understand what different
`components, additives, would work or fail
`as stabilizers.
` Then we also did a more
`mechanistic study where we used -- this
`is more biophysical research -- where we
`used infrared spectroscopy to understand
`the structure of proteins in the dried
`state and to understand the interaction
`between stabilizers and the protein.
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` CARPENTER - HIGHLY CONFIDENTIAL
` Q. Did you operate a bench scale
`lyophilizer?
` A. At that time we had a small
`bench scale, not industrial style
`lyophilizer.
` Q. Have you ever operated an
`industrial scale lyophilizer?
` A. We have pilot scale
`lyophilizers in my lab now, so I think we
`acquired those, the first one I think we
`got in 1995, I believe, these are the
`proper small scale lyophilizers that we
`used in the pharmaceutical company for
`research purposes.
` Q. Just so I understand, there is
`bench scale lyophilizer, small scale
`lyophilizer?
` A. Yes, there are lyophilizers, so
`often a lyophilizer used in just an
`academic lab doesn't have a lot of the
`control features that a pilot scale
`freeze-dryer would in industry, so a lab
`scale lyophilizer, you would not have a
`shelf control -- temperature control, for
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` CARPENTER - HIGHLY CONFIDENTIAL
`example.
` Whereas if you buy what we
`have -- got in 1995, you have something
`that's a scaled-down version of what an
`industrial freeze-dryer would look like,
`so it has pressure control, it has
`temperature control.
` Q. And then the third type is an
`industrial scale lyophilizer?
` A. Well, there is the small
`research industrial lyophilizers, and they
`come in a range of sizes, but they are
`like the size of a refrigerator.
` And then if you're working in a
`company where you're actually going to
`make products, there is intermediate scale
`for clinical trials, and then large scale,
`very large sometimes.
` Q. So have you ever operated a
`large scale lyophilizer?
` A. No.
` Q. Have you ever operated a medium
`scale lyophilizer?
` A. No, we've got the smaller one,
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` CARPENTER - HIGHLY CONFIDENTIAL
`the smaller industrial units in our labs.
` Q. On the first page here, last
`thing you have is from 1988 to '92 you
`were a senior scientist at CryoLife, Inc.,
`in Marietta, Georgia.
` A. Yes.
` Q. Can you tell me what your job
`duties as a senior scientist at CryoLife
`were?
` A. There were several.
` One of the main focus areas was
`on tissue and cell cryopreservation,
`viable cryopreservation.
` At that time I also continued
`working on enzyme stabilization and
`continued collaboration I had formed in
`California with scientists from Amgen,
`trying to understand mechanisms of protein
`stabilization during freezing and drying.
` I also had funding from the
`U.S. Navy to study nonfreezing cold
`injury, which is a battlefield problem.
` Q. What is that?
` A. It is when you are exposed to
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` CARPENTER - HIGHLY CONFIDENTIAL
`low temperature, you don't get frostbite,
`but your body shuts off circulation to the
`periphery and there may or may not be
`thrombosis and you end up not having
`circulation to your periphery, like your
`hands and your feet, for example.
` Q. First duty you said was
`cryopreservation?
` A. Yes, freezing; one area I had
`funding from the Navy to freeze red blood
`cells, so if you have blood, store it for
`emergency use, you can freeze it.
` The company itself is still in
`existence with donated tissues, they --
`at that point they were viably freezing
`human heart valves for transplantation, we
`also worked on veins and orthopedic
`tissues.
` Q. So this is literally freezing?
` A. Yes.
` Q. Tissues?
` A. Yes.
` Q. Cells?
` A. Yes.
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` Q. Not freeze-drying?
` A. Not -- not for tissues and
`cells, just proteins at that point.
` Q. If we turn over to page 2, I
`guess we have a little bit of overlap
`between the professional experience and
`academic appointments.
` Was this as a visiting lecturer
`at U.C.?
` A. Correct.
` Q. After CryoLife, it looks like
`you moved to the University of Colorado?
` A. Correct.
` Q. Started your career there?
` A. Yes.
` Q. This is all at the Denver
`Health Sciences?
` A. Right, at the time I got there
`it was called University of Colorado
`Health Sciences Center, that was in
`Denver.
` We moved several years ago to
`Aurora, at the former Fitzsimmons Army
`Base, so it is called -- some still call
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`it Health Sciences, the formal name is
`University of Colorado, Anschutz Medical.
` Q. Where is Aurora compared to
`Denver?
` A. Aurora is east of Denver.
` Q. So it is in the metropolitan
`area?
` A. Right.
` Q. You started there as an
`assistant professor of pharmaceutical
`biotechnology?
` A. Correct.
` Q. You're on the graduate faculty
`from 1993 to the present; 1997 until now
`you've been the co-founder and co-director
`of the Center of Pharmaceutical
`Biotechnology?
` A. Correct.
` Q. Can you tell me what that is?
` A. That's a center that started
`initially as collaboration --
`collaborative research between my
`department and the department of chemical
`engineering in Boulder, the professor up
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` CARPENTER - HIGHLY CONFIDENTIAL
`there and I and another guy did a lot of
`work together, so we decided to start
`training students between the two
`campuses, so we offered courses between
`the two campuses, we did a lot of research
`together.
` We formed the center to just
`kind of bring recognition to the
`collaborative nature of work between
`chemical engineers and pharmaceutical
`scientists.
` Q. Is this center housed in a
`specific school or college?
` A

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