` Filed: January 20, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`COALITION FOR AFFORDABLE DRUGS IX LLC,
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`Petitioner.
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`BRISTOL-MYERS SQUIBB PHARMA COMPANY
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`Patent Owner
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` Case No.: IPR2015-01723
`Patent No. 6,967,208
`________________
`Title: LACTAM-CONTAINING COMPOUNDS AND DERIFATIVES
`THEREOF AS FACTOR XA
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`PETITIONER’S UPDATED MANDATORY
`NOTICE PURSUANT TO 37 C.F.R. § 42.8
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`I. Introduction
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`Petitioner Coalition for Affordable Drugs IX LLC (“CFAD IX”)
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`respectfully submits this Updated Mandatory Notice Pursuant to 37
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`C.F.R. 42.8(a)(3) and (b)(1). On December 31, 2015 the ownership of
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`CFAD IX changed from being solely owned by Hayman Credes Master
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`Fund, L.P. (“Credes”) to being jointly owned by Credes, Hayman Orange
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`Fund SPC-Portfolio A (“HOF”) and Hayman Capital Master Fund, L.P.
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`(“HCMF”). All of these entities were set forth in the original Mandatory
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`Notices, therefore there have been no additions to, or deletions of, any of
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`the entities originally named as real parties in interest.
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`II. 37 C.F.R. 42.8(b)(1) Real party-in-interest
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`Pursuant to 37 C.F.R. § 42.8(b)(1), Petitioner certifies that
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`Coalition For Affordable Drugs IX LLC (“CFAD IX”), Hayman Credes
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`Master Fund, L.P. (“Credes”), Hayman Orange Fund SPC – Portfolio A
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`(“HOF”), Hayman Capital Master Fund, L.P. (“HCMF”), Hayman
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`Capital Management, L.P. (“HCM”), Hayman Offshore Management,
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`Inc. (“HOM”), Hayman Investments, L.L.C. (“HI”), nXn Partners, LLC
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`(“nXnP”), IP Navigation Group, LLC (“IPNav”), J. Kyle Bass, and Erich
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`Spangenberg are the real parties in interest (collectively, “RPI”). The RPI
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`hereby certify the following information: CFAD IX is a jointly owned by
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`Credes, HCMF and HOF. Credes is a limited partnership. HOF is a
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`segregated portfolio company. HCMF is a limited partnership. HCM is
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`the general partner and investment manager of Credes and HCMF. HCM
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`is the investment manager of HOF. HOM is the administrative general
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`partner of Credes and HCMF. HI is the general partner of HCM. J. Kyle
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`Bass is the sole member of HI and sole shareholder of HOM. CFAD IX,
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`Credes, HOF and HCMF act, directly or indirectly, through HCM as the
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`general partner and/or investment manager of Credes, HOF and HCMF.
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`nXnP is a paid consultant to HCM. Erich Spangenberg is the Manager
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`and majority member of nXnP. IPNav is a paid consultant to nXnP.
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`Erich Spangenberg is the Manager and majority member of IPNav. Other
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`than HCM and J. Kyle Bass in his capacity as the Chief Investment
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`Officer of HCM and nXnP and Erich Spangenberg in his capacity as the
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`Manager/CEO of nXnP, no other person (including any investor, limited
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`partner, or member or any other person in any of CFAD IX, Credes,
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`HOF, HCMF, HCM, HOM, HI, nXnP or IPNav) has authority to direct or
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`control (i) the timing of, filing of, content of, or any decisions or other
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`activities relating to this Petition or (ii) any timing, future filings, content
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`of, or any decisions or other activities relating to the future proceedings
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`related to this Petition. All of the costs associated with this Petition will
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`be borne by HCM, CFAD IX, Credes, HOF and/or HCMF.
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`Respectfully submitted,
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`/s/ Thomas C. Wright
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`Thomas C. Wright
`Reg. No. 47189
`Cunningham Swaim, LLP
`7557 Rambler Road, Suite 440
`Dallas, Texas 75231
`Telephone: 214-646-1495
`Direct: 469-729-7010
`Facsimile: 214-613-1163
`twright@cunninghamswaim.com
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`CERTIFICATE OF SERVICE
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`I certify that, on January 20, 2016, I caused a true and correct copy
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`of the foregoing to be served via electronic mail to counsel for the Patent
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`Owner, Heather Petruzzi and David Cavanaugh.
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` /s/ Thomas C. Wright
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`Thomas C. Wright
`Reg. No. 47189
`Cunningham Swaim, LLP
`7557 Rambler Road, Suite 440
`Dallas, Texas 75231
`Telephone: 214-646-1495
`Direct: 469-729-7010
`Facsimile: 214-613-1163
`twright@cunninghamswaim.com
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