`
`_______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`LUPIN LTD. and LUPIN PHARMACEUTICALS INC.
`Petitioners
`
`v.
`
`SENJU PHARMACEUTICAL CO., LTD., BAUSCH & LOMB, INC., and
`BAUSCH & LOMB PHARMA HOLDINGS CORP.
`Patent Owner
`
`____________________
`
`
`
`IPR2015-01097 (US Patent No. 8,751,131)
`IPR2015-01099 (US Patent No. 8,669,290)
`IPR1015-01100 (US Patent No. 8,927,606)
`IPR2015-01105 (US Patent No. 8,871,813)1
`____________________
`
`
`
`DECLARATION OF CHIEMI SUZUKI
`
`
`
`
`
`
`
`
`1 The word-for-word identical paper is filed in each proceeding identified in the
`heading.
`
`
`
` LUPIN EX 1075
`
`
`
`
`
`
`I, Chiemi Suzuki, declare as follows:
`
`1.
`
`I am a counsel at the firm Crowell & Moring, LLP, where my practice
`
`focuses on patent-related matters, and in particular, patent litigation in the
`
`pharmaceutical field.
`
`2.
`
`I am a member in good standing of the State Bars of New York and
`
`California.
`
`3.
`
`I have over 11 years’ experience litigating patents in the pharmaceutical
`
`field, including the following cases in the U.S. District Court for the District of
`
`Delaware, and the U.S. District Court for the Northern District of California:
`
`(cid:120) Noven Pharmaceuticals, Inc. v. Actavis Laboratories UT, Inc., No.
`
`15-249-LPS (D. Del.),
`
`(cid:120) Cephalon, Inc. v. Actavis Laboratories FL, Inc. et al., No. 14-776 (D.
`
`Del.),
`
`(cid:120) Pfizer Inc. et al. v. Actavis Laboratories FL, Inc., No. 11-914 (D.
`
`Del.),
`
`(cid:120) Par Pharmaceutical, Inc. & Handa Pharmaceuticals, LLC v. Takeda
`
`Pharmaceutical Co., Ltd. et al., No. 5:13-1927 (N.D. Cal.),
`
`(cid:120) Takeda Pharmaceutical Co., Ltd. et al. v. Handa Pharmaceuticals,
`
`LLC and Par Pharmaceutical, Inc., No. 3:11-840 (N.D. Cal.), and
`
`
`
` LUPIN EX 1075
`
`
`
`
`
`Cephalon, Inc. v. Watson Pharmaceuticals, Inc. et al., Nos. 08-330
`
`and 09-724 (D. Del.).
`
`4.
`
`I have not been suspended or disbarred from practice before any court or
`
`administrative body.
`
`5.
`
`I have not been denied admission to practice before any court or
`
`administrative body.
`
`6.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`7.
`
`I have not applied to appear pro hac vice for any proceeding before the
`
`Office in the last three (3) years.
`
`8.
`
`I am familiar with the subject matter of these proceedings. I have read,
`
`reviewed and am familiar with the subject matter in U.S. Pat. Nos. 8,751,131 (“the
`
`‘131 patent”), 8,669,290 (“the ‘290 patent”), 8,927,606 (“the ‘606 patent”) and
`
`8,871,813 (“the ‘813 patent”). In addition, I am familiar with the underlying
`
`technology. Additionally, I have read and am familiar with the Petitions and
`
`exhibits filed by Petitioners relating to these four patents.
`
`9. Given my familiarity with the underlying facts and my litigation
`
`experience, I have experience and expertise important to representing Petitioners
`
`Lupin Ltd. and Lupin Pharmaceuticals Inc. in these proceedings.
`
`
`
` LUPIN EX 1075
`
`
`
`
`
`10.
`
`I have read and will comply with the Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`11.
`
`I will comply with and be subject to the United States Patent and
`
`Trademark Office Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101
`
`et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`I declare that all statements made herein of my knowledge are true and that all
`
`statements made on information and belief are believed to be true, and further that
`
`these statements are made with knowledge that willful false statements and the like
`
`are punishable by fine or imprisonment, or both, under § 1001 of Title 18 of the
`
`United States Code.
`
`
`DATE
`
`
`
`
`
`Respectfully submitted,
`
`
`Chiemi Suzuki
`CROWELL & MORING LLP
`590 Madison Ave., Floor 20
`New York, NY 10022
`
`
`
` LUPIN EX 1075