`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`LUPIN LTD. and LUPIN PHARMACEUTICALS INC.
`Petitioner,
`
`v.
`
`SENJU PHARMACEUTICAL CO., LTD.
`Patent Owner.
`
`__________________
`
`IPR2015-01097 (US Patent No. 8,754,131)
`IPR2015-01099 (US Patent No. 8,669,290)
`IPR2015-01100 (US Patent No. 8,927,606)
`IPR2015-01105 (US Patent No. 8,871,813)*
`__________________
`
`
`
`
`
`JOINT LIST OF OBJECTIONS TO DEMONSTRATIVES
`
`
`* IPR2016-00089 has been joined with IPR2015-01097; IPR2016-00091
`
`has been joined with IPR2015-01100; and IPR2016-00090 has been joined with
`
`IPR2015-01105. Each of these joined proceedings includes Petitioners
`
`InnoPharma Licensing, Inc., InnoPharma Licensing LLC, InnoPharma Inc., Mylan
`
`Pharmaceuticals Inc., and Mylan Inc. (collectively, “InnoPharma”) in addition to
`
`the parties identified above.
`
`
`
`
`
`
`
`IPR2015-01097; IPR2015-01099
`IPR2015-01100; IPR2015-01105
`
`Patent Owner’s Objections: Patent Owner objects to the following slides.
`
`
`
`Slides 14 and 38-39 contain arguments not supported by the citations listed on
`
`each slide or elsewhere in the record. Slide 15 mischaracterizes the cited
`
`references and uses them in a manner that is entirely unsupported by the record.
`
`Slides 26-27 improperly reference new arguments on the slides and reflect new
`
`grounds of motivation to combine that exceed the proper scope of a Reply and
`
`could have been made in the Petition, see IPR2015-01097, -01100, -01105, Paper
`
`46, IPR2015-01099, Paper 45, and should be struck, under Dell Inc. v. Acceleron,
`
`LLC, 818 F.3d 1293, 1301 (Fed. Cir. 2016).
`
`Petitioner’s Objections: Petitioners’ object to the following slides. Slides
`
`6, 10, 12, 15-18, 25-29, 34, 35, and 58 contain arguments that are misleading
`
`and/or mischaracterize the record. Slides 16, 19, 25, and 27 contain arguments or
`
`statements that are not supported by the record. Accordingly, slides 6, 10, 12, 15-
`
`19, 25-29, 34, 35 and 58 should be struck.
`
`Respectfully submitted,
`
`FINNEGAN, HENDERSON,
`FARABOW, GARRETT &
`DUNNER LLP
`
`By: /Bryan C. Diner/
`
`Bryan C. Diner, Lead Counsel
`Reg. No. 32,409
`Counsel for Patent Owner
`
`
`
`2
`
`Date: June 6, 2016
`
`CROWELL & MORING LLP
`
`
`
`By: /Deborah Yellin/
`
`Deborah Yellin, Lead Counsel
`Reg. No. 45,904
`Counsel for Petitioners
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Joint List of
`
`Objections to Demonstratives was served on June 6, 2016, via email directed to
`
`counsel of record for the Petitioner at the following:
`
`Deborah Yellin
`dyellin@crowell.com
`
`Jonathan Lindsay
`jlindsay@crowell.com
`
`Teresa Stanek Rea
`TRea@crowell.com
`
`Chiemi Suzuki
`CSuzuki@crowell.com
`
`Shannon Lentz
`slentz@crowell.com
`
`Jitendra Malik
`jitty.malik@alston.com
`
`Bryan Skelton, Ph.D.
`Bryan.skelton@alston.com
`
`Lance Soderstrom
`Lance.soderstrom@alston.com
`
`Hitetada James Abe
`James.abe@alston.com
`
`Joseph M. Janusz
`Joe.janusz@alston.com
`
`
`
`
`
`
`
`
`
`Date: June 6, 2016
`
`
`
`/Bradley J. Moore/
`Bradley J. Moore
`Litigation Legal Assistant
`
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, LLP
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