`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`COALITION FOR AFFORDABLE DRUGS VI LLC,
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`PETITIONER
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`V.
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`CELGENE CORPORATION,
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`PATENT OWNER
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`___________________
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`CASE IPR2015-01096
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`PATENT NO. 6,315,720
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`___________________
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`DECLARATION OF SADAF R. ABDULLAH
`IN SUPPORT OF PETITIONER’S UNOPPOSED MOTION FOR PRO HAC
`VICE ADMISSION OF SADAF R. ABDULLAH AS BACK-UP COUNSEL
`
`CFAD VI 1071 - 0001
`CFAD VI v. CELGENE
`IPR2015-01096
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`
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`I, Sadaf R. Abdullah, declare as follows:
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`1.
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`I am a member of good standing with the Texas State Bar (2014) (Bar
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`No. 24093500), New York State Bar (2010) (Bar No. 4781225), and the
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`Commonwealth of Massachusetts Bar (2006) (Bar No. 666865). I am admitted to
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`practice in the U.S. Courts of Appeals for the Federal Circuit.
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`2.
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`I have applied to appear pro hac vice before the Office in one other
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`proceeding within the last three years. On February 19, 2016, I applied to appear
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`pro hac vice in Coalition for Affordable Drugs II LLC v. Cosmo Technologies
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`LTD., IPR2015-00988, and that application was granted on March 1, 2016 (see
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`IPR2015-00988, Paper 26).
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`3.
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`I have never been disbarred or suspended from practice before any
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`court or administrative body.
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`4.
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`I have never had any sanctions or contempt citations imposed on me
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`from any court or administrative body.
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`5.
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`I have never been denied any application for admission to practice
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`before any court or administrative body.
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`6.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in 37 C.F.R. § 42 et.
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`seq.
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`1
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`CFAD VI 1071 - 0002
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`
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`7.
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`I agree to be subject to the USPTO Rules of Professional
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`Responsibility set forth in 37 C.F.R. 11.101 et. seq., and disciplinary jurisdiction
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`under 37 C.F.R. 11.19(a).
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`8.
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`CFAD’s lead counsel in this proceeding, Ms. Sarah Spires, is a
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`Partner at Skiermont Derby LLP, and is a registered patent practitioner. She is
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`expected to take maternity leave in the next several months.
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`9.
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`I am an experienced patent litigation attorney with over 9 years of
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`litigation experience, including 9 years of experience litigating pharmaceutical-
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`related patent cases, including cases where the patentability of claims under 35
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`U.S.C. §§ 102 and 103 was or is at issue. This experience includes serving as
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`counsel (including at trial) in the following representative pharmaceutical patent
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`matters:
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` Novartis Pharmaceuticals Corporation v. Actavis LLC et al., C.A. No. 2:13-
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`cv-01028-SDW-MCA (District of New Jersey);
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` Enzo Life Sciences Inc. v. Becton Dickson and Company et al., C.A. No.
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`1:12-cv-00275-LPS (District of Delaware);
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` Somaxon Pharmaceuticals Inc. v. Actavis Elizabeth LLC et al., C.A. No.
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`1:11-cv-00402 (District of Delaware);
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` Warner Chilcott Company et al v. Teva Pharmaceuticals USA Inc., C.A. No.
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`1:08-cv-00627-LPS (District of Delaware);
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`
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`2
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`CFAD VI 1071 - 0003
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`
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` Abbott GmbH & Co., KG et al v. Centocor Ortho Biotech, Inc., C.A. No.
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`4:09-cv-11340 (District of Massachusetts);
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` Apotex Inc. v. Cephalon Inc. et al., C.A. No. 2:06-cv-02768 (Eastern District
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`of Pennsylvania)
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` Mitsubishi Chemical Corp., et al. v. Barr Laboratories Inc., C.A. No. 1:07-
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`cv-11614 (Southern District of New York)
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` Braintree Laboratories, Inc. v. Schwarz Pharma Inc., C.A. No. 1:03-cv-
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`00477-SLR (District of Delaware)
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` Coalition for Affordable Drugs II LLC v. Cosmo Technologies LTD.,
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`IPR2015-00988
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`10.
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`I have established deep familiarity with the subject matter at issue in
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`this proceeding. In addition to my work on the subject matter at issue in this
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`proceeding described in the following paragraphs, I am counsel in litigation against
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`Celgene (Patent Owner) in Andrulis Pharmaceuticals Corp. v. Celgene Corp., C.A.
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`No. 13-cv-01644-RGD (District of Delaware) (currently on appeal to the Federal
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`Circuit; Case No. 2015-1962). Celgene’s REMS distribution program that is the
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`subject matter of U.S. Patent No. 6,315,720 (“’720 Patent”) is relevant to the
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`Andrulis.
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`11.
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`I have reviewed and analyzed the ’720 Patent and its prosecution
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`history.
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`3
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`CFAD VI 1071 - 0004
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`
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`12.
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`13.
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`I have reviewed and analyzed the Petition and supporting materials.
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`I have reviewed and analyzed the Patent Owner Preliminary Response
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`and the Decision regarding the Institution of Inter Partes Review.
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`14. On behalf of CFAD, I worked with the expert (Jeffrey Fudin) in
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`preparation for his deposition regarding his declaration in support of CFAD’s
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`Petition, and I attended that deposition.
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`Under penalty of perjury, I declare the above statements are true and
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`accurate to the best of my knowledge. I have been warned that willful false
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`statements and the like are punishable by fine or imprisonment, or both. (18 U.S.C.
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`§ 1001.)
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`DATED this 14th day of March, 2016.
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`By: /s/ Sadaf R. Abdullah _
`Sadaf R. Abdullah
`(TX Bar No. 24093500)
`SKIERMONT DERBY LLP
`2200 Ross Avenue, Suite 4800W
`Dallas, TX 75201
`Phone: (214) 978-6600
`Fax: (214) 978-6601
`sabdullah@skiermontderby.com
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`
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`4
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`CFAD VI 1071 - 0005