Transcript of Binghe Wang, Ph.D.
`
`December 10, 2016
`
`Argentum Pharmaceuticals LLC v. Research Corporation Technologies, Inc.
`
`Alderson Reporting
`1-800-367-3376
`info@aldersonreporting.com
` http://www.aldersonreporting.com
`
`Alderson Reference Number: 67493
`
`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2194 - 1/254
`
`
`
`December 10, 2016
`
`Argentum Pharmaceuticals LLC v. Research Corporation Technologies, Inc.
`
`Alderson Reporting
`1-800-367-3376
`info@aldersonreporting.com
` http://www.aldersonreporting.com
`
`Alderson Reference Number: 67493
`
`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2194 - 1/254
`
`
`
`Binghe Wang, Ph.D.
`
`December 10, 2016
`
`Washington, D.C.
`
` UNITED STATES PATENT AND TRIAL APPEAL BOARD
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`Page 1
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` - - - - - - - - - - - - - - - X
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` ARGENTUM PHARMACEUTICALS LLC, :
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` Petitioner, : Case No.
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` v. : IPR2016-00204
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` RESEARCH CORPORATION : Patent No.
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` TECHNOLOGIES, INC., : RE 38,551
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` Respondent. :
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` - - - - - - - - - - - - - - - X
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` Washington, D.C.
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` Saturday, December 10, 2016
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` Deposition of BINGHE WANG, Ph.D., a
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`witness herein, called for examination by counsel for
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`Respondent in the above-entitled matter, pursuant to
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`notice, the witness being duly sworn by MARY GRACE
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`CASTLEBERRY, a Notary Public in and for the District
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`of Columbia, taken at the offices of Covington, 850
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`10th Street, N.W., Washington, D.C., at 7:58 a.m.,
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`Saturday, December 10, 2016, and the proceedings
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`being taken down by Stenotype by MARY GRACE
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`CASTLEBERRY, RPR, and transcribed under her
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`direction.
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2194 - 2/254
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`
`
`Binghe Wang, Ph.D.
`
`December 10, 2016
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`Washington, D.C.
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`APPEARANCES:
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`Page 2
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` On behalf of the Petitioner:
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` MATTHEW J. DOWD, ESQ.
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` Dowd PLLC
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` 1717 Pennsylvania Avenue, N.W.
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` Washington, D.C. 20006
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` (202) 573-3853
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` On behalf of Respondent:
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` ANDREA G. REISTER, ESQ.
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` EVAN KRYGOWSKI, ESQ.
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` Covington & Burling
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` 850 Tenth Street, N.W.
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` Washington, D.C. 20001
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` (202) 662-6000
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`
`
`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 3
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`APPEARANCES: (Continued)
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` On behalf of Mylan:
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` STEVE PARMELEE, ESQ. (Telephonically)
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` GRACE A. WINSCHEL, ESQ. (Telephonically)
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` Wilson Sonsini Goodrich & Rosati
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` 701 5th Avenue
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` Seattle, Washington 98104
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` (206) 883-2554
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` ALSO PRESENT:
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` TYLER LIU, ESQ.
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` Argentum
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 4
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` C O N T E N T S
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`WITNESS EXAMINATION BY COUNSEL FOR
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`BINGHE WANG, Ph.D. PETITIONER RESPONDENT
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` BY MS. REISTER 7
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` BY MR. DOWD 226
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` AFTERNOON SESSION 140
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` E X H I B I T S
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`SECOND WANG EXHIBIT PAGE
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`NO. 1: Drawing of chemical compound 28
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`NO. 2: Drawing of chemical compound 126
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`NO. 3: Organic Chemistry, 8th Edition, 140
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` L.G. Wade, Jr.
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 5
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` P R O C E E D I N G S
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`Whereupon,
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` BINGHE WANG, Ph.D.,
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`was called as a witness by counsel for Respondent,
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`and having been duly sworn by the Notary Public, was
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`examined and testified as follows:
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` EXAMINATION BY COUNSEL FOR RESPONDENT
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`BY MS. REISTER:
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` Q. Good morning, Dr. Wang.
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` A. Good morning.
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` Q. I believe you understand that you're now
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`under oath?
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` A. Yes.
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` Q. And this is a question and answer format
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`similar to the format that we used before.
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` Is there anything that might interfere
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`with your ability to tell the truth today?
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` A. No.
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` Q. You're not on any medications that would
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`inhibit your ability to tell the truth?
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` A. No.
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` Q. You're not suffering from any illness or
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 6
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`anything like that?
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` A. Things that will not interfere with this
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`function.
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` Q. Okay. I'm going to endeavor to make my
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`questions clear today. If the questions aren't
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`clear, please let me know and I will try to clarify
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`them. Otherwise I will assume that you understand
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`the question. Agreed?
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` A. Yes.
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` Q. And if you need a break at any time,
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`please let me know and we'll endeavor to take a break
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`at the next available opportunity, all right?
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` A. Sure.
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` Q. Now, Dr. Wang, I see that you have a
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`number of documents in front of you, is that correct?
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` A. Correct.
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` Q. Could you identify what those documents
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`are, please?
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` A. So the first one, looking at this, it's a
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`declaration in response -- this is Roush's
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`declaration.
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` Q. Excuse me, I didn't hear what your answer
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 7
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`was.
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` A. So this is the --
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` MR. DOWD: You might want to identify the
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`exhibit number.
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` THE WITNESS: Okay. So we have
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`IPR 2016-0024, Argentum Exhibit 1084; and I have
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`Petitioner's updated exhibit list; and I have the
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`summary of protective indices of all FAA compounds
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`Dr. Kohn's references.
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`BY MS. REISTER:
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` Q. And what is the exhibit number on that,
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`please?
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` A. 1218. And a summary of FAAs in Dr.
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`Kohn's references. This one doesn't have an exhibit
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`number. 21? Oh, 2172.
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` Okay. Another one is 1002, Exhibit 1002.
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`This one, okay. Yeah, that's all I have right now.
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`Let's see. I have two Petitioner's updated exhibit
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`lists.
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` Q. And, Dr. Wang, could you then hand me all
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`of those documents, please, so that I can inspect
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`them?
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` MS. REISTER: And what I propose is that
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`to the extent we're going to use those documents,
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`Page 8
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`that we enter them as separate exhibits.
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` MR. DOWD: That's fine.
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` As separate exhibits?
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` MS. REISTER: Yes. These are -- and for
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`the record, I'm going to object to the fact that
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`Exhibit 1218 is even in this stack because that is
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`not an exhibit that is in the record.
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` MR. DOWD: Your objection is noted. It's
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`misplaced but it's in the record. You've been
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`provided with a copy of it.
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` Now, I don't think it makes sense to enter
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`these as additional exhibits. These are exhibits
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`that are already in the record. And I believe under
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`the rules, there is no basis to include these as new
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`exhibits and it would just further confuse the
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`record. If you want to make copies of those at break
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`for your record, that is fine, but these are the
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`exhibits that are in the record already and so they
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`shouldn't be marked separately.
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` MS. REISTER: And I am inspecting each and
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 9
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`every one of these. It is not standard procedure for
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`the deponent to show up with a set of exhibits and
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`then say that those are the exhibits that are going
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`to be used for the proceeding. So please afford me
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`the opportunity to look at these exhibits and we'll
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`determine how we're going to proceed.
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` MR. DOWD: Well, okay. Let's step back
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`for a second. I disagree with your position that it
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`is not standard procedure, quote. I'm not really
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`sure what you're referring to as, quote, standard
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`procedure. I have examined and cross-examined many,
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`many witnesses and when they are being examined and
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`cross-examined, they have their documents in front of
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`them that they've relied on for their testimony. And
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`that's why Dr. Wang brought these documents. These
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`are documents that you know are part of the record
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`and that Dr. Wang has relied upon.
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` To the extent you want to -- like I said,
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`to the extent you want to make copies, confirm that
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`they are the same exhibits, that is fine. There is
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`no reason, though, to mark those documents as new
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`exhibits because they are the same exhibits that are
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 10
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`already in the record.
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` MS. REISTER: I would like to clarify that
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`one of the documents that Dr. Wang brought into the
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`room appears to be Petitioner's updated exhibit list
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`with a date on it of December 6, 2016.
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` I would also like to clarify that one of
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`the documents that Dr. Wang brought into the room
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`appears to be Patent owner's updated exhibit list
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`with a date of December 7, 2016.
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` MR. DOWD: And which exhibit numbers are
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`those?
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` MS. REISTER: Those are papers. They do
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`not have exhibit numbers.
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` MR. DOWD: Exactly.
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` MS. REISTER: I will note for the record
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`that what appears to be page 69 in the exhibit label
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`of Exhibit 1002 is completely illegible.
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` MR. DOWD: I will object to your
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`characterization of the document.
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` MS. REISTER: Could you read back what
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`Dr. Wang identified in terms of the declarations?
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` THE REPORTER: "Answer: So the first one,
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 11
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`looking at this, it's a declaration in response --
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`this is Roush's declaration."
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` MS. REISTER: And was there an exhibit
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`number identified for that?
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` THE REPORTER: "Answer: So we have IPR
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`2016-0024, Argentum Exhibit 1084."
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` MS. REISTER: And I would like to clarify
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`for the record that Argentum Exhibit 1084 is the
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`response declaration of Dr. Binghe Wang in support of
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`the reply.
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` MR. DOWD: That's correct. And if you had
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`asked some questions to clarify his answer, you would
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`have received that answer.
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` MS. REISTER: Thank you.
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`BY MS. REISTER:
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` Q. Dr. Wang --
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` MR. DOWD: Excuse me, can the witness have
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`his documents back?
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` MS. REISTER: Then we need to come to an
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`agreement as to what happens with those documents at
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`the end of the day.
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` MR. DOWD: Please return the documents to
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 12
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`the witness and we can discuss agreement. That's
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`fine. But you can't hold the documents hostage.
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` MS. REISTER: So we need to come to an
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`agreement in terms of how we're going to handle the
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`exhibits and then I will return the documents to
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`Dr. Wang.
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` MR. DOWD: No, no --
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` MS. REISTER: To the --
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` MR. DOWD: No.
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` MS. REISTER: Matthew --
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` MR. DOWD: I'm happy to come to an
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`agreement but we don't hold documents hostage.
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` MS. REISTER: They're not hostage.
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`They're right here.
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` MR. DOWD: Then please return them to the
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`witness.
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` MS. REISTER: I am handing back to the
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`witness Exhibit 1084; Exhibit 1002, Patent owner's
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`updated exhibit list, December 7, 2016; Petitioner's
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`updated exhibit list, December 6, 2016; Argentum
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`Exhibit 1218; Argentum Exhibit 2182. These documents
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`are being returned to the witness.
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` THE WITNESS: Thank you.
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` MR. DOWD: Thank you. That's all I asked
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`Page 13
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`for.
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` And to the extent that you suggested that
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`I refused to come to some agreement with you
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`regarding the document, that's not accurate. You've
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`never asked me what to do with the documents at the
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`end of this deposition. What would you propose?
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` MS. REISTER: You didn't allow me to ask
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`you. You just insisted that I return the documents
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`to the witness, which I have done.
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` Now, my question is --
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` MR. DOWD: No, no, exactly. I insisted
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`because --
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` MS. REISTER: May I finish?
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` MR. DOWD: No. No, we're going to make
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`sure the record is clear on that because I first
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`asked you, while you were asking a question, to
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`return the documents to the witness because you
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`started asking questions of the witness prior to
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`returning the documents to the witness.
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` MS. REISTER: The documents have been
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 14
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`returned to the witness.
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` MR. DOWD: Then you responded to me that
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`you're not returning them until we come to some
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`agreement, thereby suggesting that I refused to agree
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`with you concerning a proposal about the documents at
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`the end of the deposition.
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` I'm clarifying that you've never offered
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`any proposal about the documents at the end of the
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`deposition. What I'm saying is, please tell me what
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`you propose and I'm sure we can come to an agreement
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`but we don't hold documents hostage.
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` MS. REISTER: The documents have been
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`returned to the witness and they were done so before
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`I was able to make the proposal. You did not allow
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`me to make the proposal.
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` MR. DOWD: And --
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` MS. REISTER: Mr. Dowd --
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` MR. DOWD: We are going to go back and
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`forth --
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` MS. REISTER: Mr. Dowd --
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` MR. DOWD: We are going to go back and
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`forth --
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` MS. REISTER: Do not interrupt me.
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` MR. DOWD: We are going to go back and
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`forth on this. I did not preclude you from offering
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`any proposal. And I want this to go as smoothly as
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`possible today because there is no reason to waste
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`people's time. So please do not suggest that I did
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`not give you the time to offer a proposal. All I did
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`was simply ask you to return the documents before you
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`start deposing the witness. And your response -- and
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`I'll say this one more time, otherwise, we'll read it
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`back from the record -- is that you wouldn't return
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`the documents until we came to some agreement.
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` Simply tell me what your proposal is and
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`we can move on.
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` MS. REISTER: To the extent that there are
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`questions on any document that we've identified that
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`the witness has in front of him, then we will make a
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`copy of that particular document so that the court
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`reporter has a copy of what document, the precise
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`document that the witness was looking at.
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` MR. DOWD: That's fine. And actually, if
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`you'll go back and look at the transcript, I offered
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 16
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`earlier to you the opportunity to make copies of the
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`documents. So we're on the same page. And I had
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`that proposal to you, so I think we're on the same
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`page.
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` MS. REISTER: And I would like a
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`representation from you on the record that each of
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`those documents is a true and correct copy of what it
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`purports to be.
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` MR. DOWD: It is.
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` MS. REISTER: Thank you.
`
`BY MS. REISTER:
`
` Q. Dr. Wang, in preparing for your deposition
`
`today, did you review all of the documents that you
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`have in front of you?
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` A. Yes, I did.
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` Q. Did you review any other documents?
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` A. Some exhibits were provided to me.
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` Q. Provided to you by whom?
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` A. By my counsel.
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` Q. Your counsel, Mr. Dowd?
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` A. By Mr. Dowd, yes.
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` Q. And what exhibits were those?
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`Alderson Court Reporting
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`
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` MR. DOWD: Objection, form.
`
` THE WITNESS: I don't remember exactly but
`
`the exhibits that were used to prepare these
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`Page 17
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`declarations.
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`BY MS. REISTER:
`
` Q. So were all the documents that you
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`reviewed in preparation for your deposition today
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`documents that are cited in your second declaration?
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` MR. DOWD: Objection. I'll object to that
`
`based on the form of the question.
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` THE WITNESS: I think so.
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`BY MS. REISTER:
`
` Q. And sitting here today, you don't recall
`
`what exhibits those were?
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` A. Not --
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` MR. DOWD: I will object to the question
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`based on the form of the question and to the extent
`
`it mischaracterizes the witness' testimony.
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` You can answer.
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` THE WITNESS: Okay. I cannot give you a
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`list in the sense of I know all the numbers, but
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`they're all from the list that's included in the
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`Alderson Court Reporting
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 18
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`record.
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` (Interruption.)
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`BY MS. REISTER:
`
` Q. Sorry, Dr. Wang. I apologize for --
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` A. No problem.
`
` Q. -- for having to stop for a minute while
`
`we addressed the water. So I'm just going to repeat
`
`the question.
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` I had asked whether all the documents that
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`you reviewed in preparation for your deposition today
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`were documents that were cited in your second
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`declaration, and you indicated that you thought so.
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`And then I said, and sitting here today, you don't
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`recall what exhibits those were, correct?
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` MR. DOWD: I object to the question based
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`on the form of the question, the relevance of the
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`question and to the extent it mischaracterizes the
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`evidence.
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` THE WITNESS: I can give you some examples
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`of that and I did not memorize exactly the list. So
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`Kohn 91 and Kohn 93, '729 and LeGall's thesis and
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`'301. I do not remember all the others.
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`
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`BY MS. REISTER:
`
` Q. Did you meet with counsel in preparation
`
`Page 19
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`for today's deposition?
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` A. Yes, I did.
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` Q. And with whom did you meet?
`
` A. So Mr. Dowd and Steve -- we did not meet.
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`We were on the phone, Steve Parmelee. And Grace.
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`Grace, I don't -- I actually don't know her last
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`name.
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` Q. And that's the same Grace that is on the
`
`telephone today, correct?
`
` A. That's correct.
`
` Q. Was there anybody else?
`
` A. No.
`
` Q. In preparation for today's deposition, did
`
`you meet with Mr. Jenks?
`
` A. No.
`
` Q. Did you meet with Mr. Tyler Liu?
`
` A. No. I assume that's Tyler Liu?
`
` Q. Yes, Tyler Liu is the other gentleman in
`
`the room here today.
`
` A. I met him the first time today.
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` Q. Did you meet with any other counsel for
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`Page 20
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`Mylan?
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` A. No.
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` Q. Did you meet or talk with any counsel for
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`Alembic?
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` A. No.
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` Q. Did you meet or talk with any counsel for
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`Breckenridge?
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` A. No.
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` Q. And when was your meeting with Mr. Dowd?
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` A. It was yesterday about 1:30.
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` Q. And approximately how long did it last?
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` MR. DOWD: I'll object to the form of the
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`question and this is a general objection to the
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`extent that the question or any questions along this
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`line of questioning elicits privileged or
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`confidential information.
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` THE WITNESS: So about two and a half
`
`hours.
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`BY MS. REISTER:
`
` Q. And that was the only meeting you had with
`
`Mr. Dowd regarding the preparation for the deposition
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`today?
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` MR. DOWD: Objection to the form of the
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`question and I'll repeat my objections to the
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`previous question.
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` THE WITNESS: In person, that's the only
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`time. But we had a phone conversation maybe three or
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`four days ago for about half an hour.
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`BY MS. REISTER:
`
` Q. And is that the only phone conversation
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`you had with Mr. Dowd in preparation for your
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`deposition today?
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` MR. DOWD: I will repeat my previous
`
`objections.
`
` THE WITNESS: As far as I can remember.
`
`BY MS. REISTER:
`
` Q. When was your telephone conversation with
`
`Steve and Grace regarding the deposition?
`
` A. About 2:00 p.m. yesterday.
`
` Q. And was that the only conversation
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`yesterday that you had with Steve and Grace, Mylan's
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`counsel?
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` A. That's correct.
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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` MR. DOWD: Same objections as to form.
`
`Page 22
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`BY MS. REISTER:
`
` Q. Dr. Wang, do you understand that Mylan
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`Pharmaceutical, Breckenridge Pharmaceutical and
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`Alembic Pharmaceuticals are now joined as petitioners
`
`in the present proceeding?
`
` A. That's what I was told.
`
` MR. DOWD: I will object to the question
`
`based on the relevance of the question, based on the
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`form of the question and based on the scope of the
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`question. And object to the extent that it elicits
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`any privileged, confidential information.
`
`BY MS. REISTER:
`
` Q. Dr. Wang, have you been retained by Mylan
`
`Pharmaceuticals with respect to the preparation of
`
`your second declaration?
`
` MR. DOWD: I will object to the question
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`based on the relevance of the question, based on the
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`form of the question, based on going beyond the scope
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`of direct examination and object to the extent that
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`it elicits privileged and/or confidential
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`information.
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 23
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` THE WITNESS: No.
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`BY MS. REISTER:
`
` Q. And have you been retained by Breckenridge
`
`or Alembic with respect to your second declaration?
`
` MR. DOWD: I'll repeat my previous
`
`objections.
`
` THE WITNESS: No.
`
`BY MS. REISTER:
`
` Q. Have you ever done any work for Mylan
`
`Pharmaceuticals?
`
` MR. DOWD: I will object to the question
`
`based on the scope of the question, lack of relevance
`
`of the question and the form of the question and to
`
`the extent it elicits privileged, confidential
`
`information. And I'll instruct the witness not to
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`answer to the extent it would require him to divulge
`
`prior confidential information.
`
` THE WITNESS: My counsel instructed me not
`
`to answer so I'll just not answer.
`
`BY MS. REISTER:
`
` Q. That's not correct. Your counsel
`
`instructed you not to answer if the yes or no answer
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`whether you've done work implicates confidential
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`information, and it can't. Whether you've done work
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`or not is a factual question.
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` MR. DOWD: No. I will repeat the
`
`objections and clarify that to the extent Dr. Wang
`
`discloses a relationship between himself and another
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`company, with specifically Mylan, the question about
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`any work, then it may be privileged or confidential.
`
`BY MS. REISTER:
`
` Q. So Dr. Wang, I repeated my question.
`
` A. As far as I remember, no.
`
` Q. Have you ever done any work for
`
`Breckenridge Pharmaceutical?
`
` MR. DOWD: The same objections.
`
` THE WITNESS: As far as I can remember,
`
`no.
`
`BY MS. REISTER:
`
` Q. Have you done any work for Alembic
`
`Pharmaceutical?
`
` MR. DOWD: Same objections.
`
` THE WITNESS: As far as I know, no.
`
` I'm going to go to the other side and get
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`1-800-FOR-DEPO
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 25
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`some water.
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` MS. REISTER: That's fine.
`
` THE WITNESS: Thank you.
`
`BY MS. REISTER:
`
` Q. Dr. Wang, approximately how many hours did
`
`you spend working on your second declaration?
`
` MR. DOWD: I will object to the form of
`
`the question, the scope of the question, the
`
`relevance of the question and I'll object on the
`
`basis that it seeks to elicit information about the
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`drafting of the declaration which, as you know,
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`Counsel, from our discussion on Thursday and our
`
`first deposition of Dr. Wang, is not a proper line of
`
`questioning.
`
` THE WITNESS: I can only estimate, and
`
`probably 40, 50 hours.
`
`BY MS. REISTER:
`
` Q. And in preparing your declaration, did you
`
`also prepare a list of documents that you considered
`
`in preparing your declaration?
`
` MR. DOWD: I will object to the form of
`
`the question, the scope of the question, the
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`relevance of the question. I'll object on the basis
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`that it seeks to elicit information about the
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`drafting of the declaration and it goes to drafts of
`
`declarations, so I'm instructing the witness not to
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`answer the question.
`
` MS. REISTER: I disagree with your
`
`characterization of the question and it is a simple
`
`question of whether he prepared a list of documents.
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`It's a yes/no question. I don't believe you have a
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`basis for instructing the witness not to answer.
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` MR. DOWD: Okay. Counsel, with respect,
`
`again, the question goes to what drafts of the
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`documents -- for example, a possible list of
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`exhibits -- drafts of his declaration may have been
`
`prepared by Dr. Wang or not.
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` MS. REISTER: Your objection is on the
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`record, Mr. Dowd.
`
` MR. DOWD: Okay.
`
`BY MS. REISTER:
`
` Q. Now, Dr. Wang, one of the documents that
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`we had looked at in your stack of documents there is
`
`a document with Exhibit Number 1084 that was entitled
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Response Declaration of Dr. Binghe Wang in Support of
`
`Page 27
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`Reply. Do you see that?
`
` A. Yes.
`
` Q. And that's the declaration that you
`
`prepared and reviewed and signed for filing in this
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`proceeding, correct?
`
` MR. DOWD: Objection to the form of the
`
`question.
`
` THE WITNESS: That's correct.
`
`BY MS. REISTER:
`
` Q. And if you turn to the very last page of
`
`the declaration, that's your signature on that page,
`
`correct?
`
` A. That's correct.
`
` Q. And that's your complete response
`
`declaration, correct?
`
` MR. DOWD: Objection to the form of the
`
`question and the relevance of the question and scope.
`
` THE WITNESS: As far as I know, yes.
`
`BY MS. REISTER:
`
` Q. And sitting here today, are you aware of
`
`any errors you need to correct in your declaration?
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`Binghe Wang, Ph.D.
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`December 10, 2016
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`Washington, D.C.
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`Page 28
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` A. I think there was one that I saw on
`
`page -- at the lower right-hand corner, it says
`
`page 47 but in the middle, it says page 44.
`
` Q. Okay.
`
` A. And right on top of paragraph 111, the
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`structure itself and the beta position of the carbon
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`that's connected to the one that's connected to X,
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`and then there should be a parentheses and then at
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`the lower right-hand part of the subscript of N, that
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`would designate different analogs that N can be an
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`integer.
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` Q. To make the record clear, Dr. Wang, as to
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`the correction that you would like to make to your
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`declaration, what I would like to do is hand you a
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`piece of paper so that you can draw the correct
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`structure to make it clear.
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` A. That would be fine.
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` Q. So we will mark this as Second Wang
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`Exhibit 1.
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` (Second Wang Exhibit No. 1 was
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` marked for identification.)
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`
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