`Patent Owners’ Objections to Evidence
`Filed on behalf of Patent Owners Genentech, Inc. and City of Hope by:
`
`David L. Cavanaugh
`Reg. No. 36,476
`Heather M. Petruzzi
`Reg. No. 71,270
`Robert J. Gunther, Jr.
`Pro Hac Vice
`Wilmer Cutler Pickering
`Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`
`Adam R. Brausa
`Reg. No. 60,287
`Daralyn J. Durie
`Pro Hac Vice
`Durie Tangri LLP
`217 Leidesdorff Street
`San Francisco, CA 94111
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________________
`
`SANOFI-AVENTIS U.S. LLC AND
`REGENERON PHARMACEUTICALS, INC.,
`Petitioners,
`
`v.
`
`GENENTECH, INC. AND CITY OF HOPE,
`Patent Owners.
`____________________________________________
`
`Case IPR2015-01624
`Patent 6,331,415
`____________________________________________
`
`PATENT OWNERS’ OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64
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`IPR2015-01624
`Patent Owners’ Objections to Evidence
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`Pursuant to 37 C.F.R. § 42.64, Patent Owners Genentech, Inc. and City of
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`Hope serve the following objections to evidence served with the Petition of Sanofi-
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`Aventis U.S. LLC and Regeneron Pharmaceuticals, Inc. (collectively
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`“Petitioners”).
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`Genentech/City of Hope object to Exhibit 1006, Declaration of Jefferson
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`Foote, Ph.D., in Support of Sanofi And Regeneron’s Petition for Inter Partes
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`Review of U.S. Patent No. 6,331,415. Genentech/City of Hope specifically object
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`to ¶¶ 25, 42-47, 52-60, 67, 68, 70-73, 78, 80, 84, 90-93, 97, 100-04, 106, 107, 109-
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`14, and all paragraphs that rely on those paragraphs as inadmissible hearsay (FRE
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`802); and ¶¶ 25, 42, 43, 47, 49, 52-53 & n.6, 56-60, 63-73, 76, 78-80, 83-84, 87-
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`97, 99-114, and all paragraphs that rely on those paragraphs as lacking a disclosed
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`basis of sufficient facts or data (FRE 705; 37 C.F.R. § 42.65), not being based on
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`sufficient facts or data, the product of reliable principles and methods, and/or a
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`reliable application of the principles and methods to the facts (FRE 702, 703), and
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`being misleading and/or confusing (FRE 403).
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`Genentech/City of Hope object to Exhibit 1044, ReoPro® Prescribing
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`Information, as irrelevant (FRE 402), misleading and/or confusing (FRE 403),
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`lacking authentication (FRE 901), and inadmissible hearsay (FRE 802).
`
`Genentech/City of Hope object to Exhibit 1045, Genentech v. Centocor, No.
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`94-01379 (N.D. Cal.), Affidavit of John Ghrayeb, Ph.D., as inadmissible hearsay
`- 1 -
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`IPR2015-01624
`Patent Owners’ Objections to Evidence
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`(FRE 802), lacking a disclosed basis of sufficient facts or data (FRE 705; 37
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`C.F.R. § 42.65), not being based on sufficient facts or data, the product of reliable
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`principles and methods, and/or a reliable application of the principles and methods
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`to the facts (FRE 702, 703), and containing improper expert testimony by a lay
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`witness (FRE 701).
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`
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`Date: February 22, 2016
`
`
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`Respectfully submitted,
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`/David L. Cavanaugh/
`David L. Cavanaugh
`Registration No. 36,476
`Counsel for Patent Owners
`
`
`WILMER CUTLER PICKERING HALE AND DORR LLP
`1875 PENNSYLVANIA AVENUE NW
`WASHINGTON, DC 20006
`TEL: 650-600-5036
`FAX: 650-858-6100
`EMAIL: david.cavanaugh@wilmerhale.com
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`- 2 -
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`IPR2015-01624
`Patent Owners’ Objections to Evidence
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`CERTIFICATE OF SERVICE
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`I hereby certify that, on February 22, 2016, I caused a true and correct copy of the
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`foregoing materials:
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`
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` Patent Owners’ Objections to Evidence Pursuant to 37 C.F.R. § 42.64
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`to be served via electronic mail on the following attorneys of record:
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`Richard McCormick
`Lisa M. Ferri
`Brian W. Nolan
`Mayer Brown LLP
`1675 Broadway
`New York, NY 10019
`Rmccormick@mayerbrown.com
`LFerri@mayerbrown.com
`BNolan@mayerbrown.com
`MB-Cabilly-IPR@mayerbrown.com
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`
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`/Owen K. Allen/
`Owen K. Allen
`Registration No. 71,118
`Wilmer Cutler Pickering Hale and Dorr LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`
`- 3 -
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