`
`_______________________________
`
`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
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
