` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF NEW JERSEY
` Civil Action No. 1:14-cv-00667-JBS-KMW
` CONSOLIDATED (04:49; 05144; 00335;
` 06893 and 03240)
`_______________________________________
`SENJU PHARMACEUTICAL CO. LTD., )
`BAUSCH & LOMB, INCORPORATED and )
`BAUSCH & LOMB PHARMA HOLDINGS CORP., )
` Plaintiffs, )
` v. )
`LUPIN, LTD. and LUPIN )
`PHARMACEUTICALS, INC., )
` Defendants. )
`INNOPHARMA LICENSING, INC., INNOPHARMA )
`LICENSING, LLC, INNOPHARMA, INC., )
`INNOPHARMA, LLC, )
` Defendants. )
`_______________________________________ )
`
` DEPOSITION OF JOHN JAROSZ
` Washington, D.C.
` February 17, 2016
`Reported by: Mary Ann Payonk
`
`The Little Reporting Company
` (646) 650-5055 | www.littlereporting.com
`
`IPR2015-01097
`IPR2015-01099
`IPR2015-01100
`IPR2015-01105
`
`Lupin EX1182
`Page 1
`
`
`
` J. JAROSZ
`
`2
`
` February 17, 2016
` 9:00 a.m.
`
` Deposition of JOHN JAROSZ, held at the
`law offices of Finnegan, 901 New York Avenue,
`N.W., Washington, D.C., pursuant to Notice
`before Mary Ann Payonk, Nationally Certified
`Realtime Reporter and Notary Public of the
`District of Columbia, Commonwealth of Virginia,
`and State of New York.
`
`The Little Reporting Company
` (646) 650-5055 | www.littlereporting.com
`
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`IPR2015-01097
`IPR2015-01099
`IPR2015-01100
`IPR2015-01105
`
`Lupin EX1182
`Page 2
`
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` J. JAROSZ
` A. No, I'm not aware of any particular
`line of demarcation that comes from the law or
`from economics, and I don't work with a
`particular line of demarcation that requires
`more quantitative precision than would be
`possible I think in a setting like this.
`BY MS. DAUGHTREY:
` Q. So it's not really possible to
`identify -- let me rephrase that.
` Are you saying that it's not possible
`to quantify what percentage of which factors
`are causing a product to have commercial
`success?
` MS. LEBEIS: Objection to the
` extent it mischaracterizes prior
` testimony, and vague and ambiguous.
` A. Yes, I don't think that's what I
`said. But it would be very difficult to say
`that factor X has a quantitative weight of Y
`and A has a quantitative weight of B. These
`things are less clear and unequivocal than your
`question appears to presume.
`BY MS. DAUGHTREY:
` Q. Companies do conduct market research
`
`The Little Reporting Company
` (646) 650-5055 | www.littlereporting.com
`
`IPR2015-01097
`IPR2015-01099
`IPR2015-01100
`IPR2015-01105
`
`Lupin EX1182
`Page 3
`
`
`
`172
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` J. JAROSZ
` A. Yes. I forget the precise words, but
`I remember what concept you're talking about.
` Q. What's the shelf life of Prolensa?
` A. In terms of number of months or
`years, I don't know.
` Q. Do you know the shelf life of any of
`the products that are NSAID ophthalmic products
`described in your report?
` A. I may have known those, but I haven't
`committed those to memory.
` Q. Is your opinions related to shelf
`life dependent upon other experts' testimony,
`like Dr. Trattler?
` A. More specifically, I think it relies
`on Dr. Williams.
` Q. Thank you.
` A. And Dr. Trattler may have some
`opinions on that, but I do believe that the
`first source for that is Dr. Williams.
` Q. I guess more generally, your opinions
`about the characteristics of Prolensa like pH
`or shelf life come from your understanding of
`other technical experts; right?
` A. In part, yes.
`
`The Little Reporting Company
` (646) 650-5055 | www.littlereporting.com
`
`IPR2015-01097
`IPR2015-01099
`IPR2015-01100
`IPR2015-01105
`
`Lupin EX1182
`Page 4
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