Transcript of DeForest McDuff, Ph.D.
`
`December 8, 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: 67494
`
`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 1/190
`
`
`
`December 8, 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: 67494
`
`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 1/190
`
`
`
`DeForest McDuff, Ph.D.
`
`December 8, 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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` Thursday, December 8, 2016
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` Deposition of DEFOREST MCDUFF, 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 8:48 a.m.,
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`Thursday, December 8, 2016, and the proceedings being
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`taken down by Stenotype by MARY GRACE CASTLEBERRY,
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`RPR, and transcribed under her 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. 2193 - 2/190
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`
`
`DeForest McDuff, Ph.D.
`
`December 8, 2016
`
`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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` EMILY KVESELIS, 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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` and
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` DEREK FAHNESTOCK, ESQ.
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` Morris, Nichols, Arsht & Tunnell
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` 1201 North Market Street, 16th Floor
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` Wilmington, Delaware 19899-1347
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` (302) 351-9347
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 3/190
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`APPEARANCES: (Continued)
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`Page 3
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` On behalf of Mylan:
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` JAD A. MILLS, ESQ.
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` Wilson Sonsini Goodrich & Rosati
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` 701 5th Avenue, Suite 5100
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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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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`DeForest McDuff, Ph.D.
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`December 8, 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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`DEFOREST MCDUFF, Ph.D. PETITIONER RESPONDENT
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` BY MS. REISTER 7
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` BY MR. DOWD 158
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` BY MS. REISTER 185
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` AFTERNOON SESSION -125
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` E X H I B I T S
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`EXHIBIT PAGE
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`NO. 1: Excerpt from Acorda vs. Alkem 45
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` September 21, 2016 trial transcript
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`NO. 2: Excerpt from UCB vs. Accord 69
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` November 13, 2015 trial transcript
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`PREVIOUSLY MARKED EXHIBITS REFERENCED
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` NO. 1086: 9
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` NO. 1088: 9
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` NO. 1099: 132
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` NO. 1158: 9
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` NO. 1170: 68
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` NO. 1172: 82
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` NO. 1181: 104
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 5/190
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`
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`PREVIOUSLY MARKED EXHIBITS REFERENCED
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`Page 5
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` NO. 2142: 143
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` NO. 2145: 155
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` NO. 2149: 145
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` NO. 2152: 156
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` NO. 2155: 139
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` NO. 2156: 146
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` NO. 2161: 148
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` NO. 2174: 59
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` NO. 2182: 50
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 6
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` P R O C E E D I N G S
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`Whereupon,
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` DEFOREST MCDUFF, 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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` MR. DOWD: Can we get a roll call of who's
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`on the line?
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` MS. REISTER: Please.
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` MR. DOWD: This is Matthew Dowd
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`representing the petitioner, Argentum. And I believe
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`we have on the conference call counsel for some of
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`the joint petitioners, and if you could, please
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`introduce yourself.
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` (Inaudible.)
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` MR. DOWD: I'm sorry, can you just repeat
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`that? It sounds like you might be on your cellphone
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`so if you could just speak up a little bit.
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` MR. MILLS: Yes, sorry. This is Jad
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`Mills with the law firm of Wilson Sonsini
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`representing Joinder Petitioner Mylan.
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` MR. DOWD: Perfect. Thank you, Jad. And
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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
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`
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`we recognize Jad is on the West Coast so we recognize
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`Page 7
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`it is quite early for you.
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` Is there anyone else?
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` I think that's all we have for now. And
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`it may be that an attorney or so from the other joint
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`petitioners join later and they'll introduce
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`themselves as they join.
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` MS. REISTER: Okay. All right.
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` EXAMINATION BY COUNSEL FOR RESPONDENT
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`BY MS. REISTER:
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` Q. Good morning, Dr. McDuff.
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` A. Good morning.
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` Q. Could you please state and spell your
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`complete name for the record?
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` A. Robert DeForest McDuff, R-o-b-e-r-t, D-e
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`capital F-o-r-e-s-t. M-c capital D-u-f-f.
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` Q. Thank you. You appreciate that you are
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`under oath today for your testimony?
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` A. Yes.
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` Q. Is there anything that might interfere
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`with your ability to testify truthfully and
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`accurately today?
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 8/190
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 8
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` A. No.
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` Q. Any medications?
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` A. No.
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` Q. Any illness?
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` MR. DOWD: Objection, form.
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` THE WITNESS: No.
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`BY MS. REISTER:
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` Q. I understand you're familiar with the
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`deposition process but I just want to go over a few
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`ground rules so that we understand each other today.
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`This is a question and answer format. I ask the
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`questions, you provide the answer. Your attorney may
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`object but you still need to answer the question.
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`And if you let me know if you need a break, we'll
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`take one at the next available moment that we can,
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`okay?
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` A. Okay.
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` MR. DOWD: Objection.
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` MS. REISTER: Excuse me?
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` MR. DOWD: Objection.
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` MS. REISTER: What objection, Mr. Dowd?
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` MR. DOWD: Is there a question or is it a
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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
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`
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 9
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`form or --
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` MS. REISTER: I was just making sure that
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`the witness understood the ground rules.
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`BY MS. REISTER:
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` Q. Do you understand the ground rules,
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`Dr. McDuff?
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` A. Yes.
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` Q. I see you have some documents in front of
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`you?
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` A. Yes.
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` Q. Could you identify what those documents
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`are, please?
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` A. These are clean copies of the declaration
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`that I submitted along with my expert CV and
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`attachments. Those are Argentum Exhibits 1086, 1088
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`and 1158.
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` Q. And for each of those exhibits that you've
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`just identified, 1086, 1088 and 1158, do they have
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`any markings on them at all?
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` A. No.
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` Q. I think you can set those aside for the
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`time being. I don't think you'll need them for any
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`of the questions that we're going to have initially.
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` MR. DOWD: I'll object to that as your
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`Page 10
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`commentary.
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`BY MS. REISTER:
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` Q. Dr. McDuff, how many times have you been
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`deposed in a patent litigation proceeding?
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` A. Around 20.
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` Q. And how many times of that 20 were you
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`representing the patentholder?
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` MR. DOWD: Objection, form.
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` THE WITNESS: I don't have an exact count
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`for you. I could refer to my CV and try to determine
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`that.
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`BY MS. REISTER:
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` Q. You've testified that approximately 20
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`times you've been deposed in a patent litigation
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`proceeding and I'm asking you, do you recall any time
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`that you have represented the patentholder side of
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`those 20?
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` MR. DOWD: Objection, asked and answered,
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`form.
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` THE WITNESS: Yes.
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`www.aldersonreporting.com
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`Alderson Court Reporting
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`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 11
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`BY MS. REISTER:
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` Q. And could you identify for me on your CV,
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`which I believe is Exhibit 1088, which one that was?
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` A. Starting on page 5 of my CV, number 5, DNA
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`Genotek vs. Spectrum; number 12, NCR Corporation vs.
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`Documotion Research; number 15, CH2O vs. Meras
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`Engineering; number 21, DNA Genotek vs. Spectrum DNA;
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`number 27, VStream vs. LG Electronics; number 32,
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`Invensas vs. Rensas; number 37, Aqua-Lung vs.
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`American Water Products and others.
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` There may be others but those are the ones
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`that come to mind.
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` Q. You identified number 5, the DNA Genotek
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`case, and number 21, which is another case, DNA
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`Genotek. I understand that those are two different
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`litigations?
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` MR. DOWD: Objection, form.
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` THE WITNESS: Yes.
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`BY MS. REISTER:
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` Q. And in the number 5 case, you were
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`providing testimony on behalf of the patentholder,
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`correct?
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 12
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` A. Yes.
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` Q. Were you asked to consider the question of
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`commercial success in that case?
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` MR. DOWD: Objection, form, foundation.
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` THE WITNESS: No, I don't believe so.
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`BY MS. REISTER:
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` Q. In the case number 12, NCR Corporation,
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`were you asked to consider commercial success in that
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`case?
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` MR. DOWD: I object to that question based
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`on the form of the question, foundation and the
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`relevance.
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` THE WITNESS: As I think about it, and to
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`clarify, I was not asked to evaluate commercial
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`success as a secondary consideration specifically. I
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`did evaluate the commercial sales and success to some
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`degree of products there as well as in the DNA
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`Genotek. That evaluation may have been used by the
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`patentholder for secondary considerations but I did
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`not provide a specific opinion on commercial success
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`as a secondary consideration.
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` That's true for the NCR case as well as
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Washington, D.C.
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`Page 13
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`the DNA Genotek case.
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`BY MS. REISTER:
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` Q. And when you refer to the DNA Genotek case
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`in the answer you just provided, that's with respect
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`to the DNA Genotek case identified as number 5 on
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`your CV?
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` A. Yes.
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` Q. With reference to the DNA Genotek case
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`identified as number 21 on your CV, were you asked to
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`consider commercial success?
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` A. Not as a secondary consideration for
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`obviousness.
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` Q. Were you asked to consider commercial
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`success for any reason?
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` MR. DOWD: I object to that question based
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`on form and foundation and the relevance of the
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`question.
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` THE WITNESS: Similar to the other cases,
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`part of my evaluation was related to commercial
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`performance of products, so it related to commercial
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`success to some degree. Yet, as a secondary
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`consideration, I was not asked to opine on that
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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`Page 14
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`specifically.
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`BY MS. REISTER:
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` Q. Have you ever testified that a commercial
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`product of any kind was a commercial success?
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` MR. DOWD: Object to that question based
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`on the form of the question, lack of foundation and
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`the relevance of the question.
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` THE WITNESS: I would have to go back and
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`think about that in terms of which cases have gotten
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`to deposition and trial.
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`BY MS. REISTER:
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` Q. In any of the cases that you identified on
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`your CV where you represented and provided testimony
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`on behalf of the patentholder, in any of those cases,
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`did you testify that the product was a commercial
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`success?
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` MR. DOWD: I'll object to that question
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`based on the form of the question, based on the lack
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`of foundation for the question and based on the lack
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`of relevancy for the question.
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` THE WITNESS: I did evaluate the
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`commercial performance of those products and I would
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`need to think about whether I provided an opinion
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`that those were commercially successful. But as a
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`secondary consideration for obviousness, I did not
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`provide an opinion in those cases, to my
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`Page 15
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`recollection.
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`BY MS. REISTER:
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` Q. Dr. McDuff, have you been deposed in an
`
`IPR proceeding prior to today?
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` A. Yes.
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` Q. How many times?
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` A. Twice.
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` Q. And can you identify on your CV, please,
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`which IPR proceedings those were?
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` A. Yes. Starting on page 5, number 2, in the
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`IPR of U.S. Patent RE 44,186, that is not marked with
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`a deposition because it occurred last week which was
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`subsequent to the filing of this declaration. On my
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`current CV, I have a deposition marked on that.
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` And number 14, in the IPR of U.S. Patent
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`No. 8,822,438.
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` Q. With reference to item 2 that you just
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`identified, you prepared an expert declaration in
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`that case, correct?
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` A. Yes.
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` Q. And did you prepare that expert
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`declaration on behalf of the patentholder?
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` A. No.
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` Q. So that declaration was prepared on behalf
`
`of the patent challenger, correct?
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` A. Yes.
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` Q. And it says on your CV you provided an
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`evaluation of commercial success related to the
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`products at issue, correct?
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` MR. DOWD: I object to that based on the
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`relevance and the foundation of the question and the
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`relevance of the question.
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` THE WITNESS: Yes.
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`BY MS. REISTER:
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` Q. And did you find that either of those
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`products were a commercial success?
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` MR. DOWD: I'll repeat my objections to
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`the last question.
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` THE WITNESS: In that case, I was asked to
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`review and respond to an expert declaration submitted
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`by patentholder. I don't believe I reached an
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`ultimate conclusion as to commercial successor not,
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`but I did provide certain critiques of the opposing
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`Page 17
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`expert's opinions.
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`BY MS. REISTER:
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` Q. With respect to the inter partes review
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`identified as item 14 on page 6 of your CV, were you
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`submitting a declaration on behalf of the
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`patentholder in that case?
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` MR. DOWD: I'll object to that question
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`based on the relevance of the question and lack of
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`foundation for the question.
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`BY MS. REISTER:
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` Q. So on item 14 on page 6 of your CV, do I
`
`understand correctly you submitted your expert
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`declaration on behalf of the patent challenger,
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`correct?
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` A. Yes.
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` Q. And that expert declaration evaluated the
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`commercial success related to Zytiga, correct?
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` A. Yes.
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` Q. And in that evaluation of commercial
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`success, did you find that Zytiga was a commercial
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`Page 18
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`success?
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` MR. DOWD: I'll object to that question
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`based on foundation and relevance.
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` THE WITNESS: I don't believe I provided a
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`conclusion of commercial success one way or the
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`other, yet I did provide opinions related to the
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`applicability or economic inference of alleged
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`commercial success on obviousness of the patent at
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`issue.
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`BY MS. REISTER:
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` Q. So in your previous answer, Dr. McDuff,
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`you stated that you provided opinions related to the
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`applicability or economic inference of alleged
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`commercial success on obviousness of the patent at
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`issue.
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` Can you help me understand what you mean
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`by "economic inference"?
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` MR. DOWD: I will object to that question
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`as mischaracterizing the witness' testimony and the
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`relevance of the question.
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` THE WITNESS: What I was referring to in
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`Page 19
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`my previous response is the economic purpose of
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`commercial success which is to make an inference
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`about whether the market would have brought a product
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`to development sooner had it been obvious, and so I
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`provided certain opinions related to that economic
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`inference.
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`BY MS. REISTER:
`
` Q. You testified at trial on the same patent
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`that's at issue in the present IPR proceeding, is
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`that correct?
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` MR. DOWD: I will object to that question
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`based on the foundation and the relevance of the
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`question.
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` THE WITNESS: Yes.
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`BY MS. REISTER:
`
` Q. And other than testimony at the trial
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`about the same patent that's at issue here, how many
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`other times have you testified at trial in a patent
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`case?
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` A. Five times with respect to claims of
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`patent infringement and an additional time related to
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`evaluation of a patent portfolio evaluation. So six
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`Page 20
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`in total as I think of it.
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` Q. And having now just reviewed your CV, when
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`was the last time that you testified at trial?
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` A. That was on -- in the case identified on
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`page 6 of my CV, number 6, Acorda Therapeutics and
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`others vs. Aurobindo and others.
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` Q. And do you recall when that occurred?
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` A. Earlier this year, sometime in summer or
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`fall.
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` Q. Dr. McDuff, in preparing for your
`
`deposition today, did you meet with counsel?
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` A. Yes.
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` Q. And with whom did you meet?
`
` A. I met with Mr. Dowd in person and I met
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`with Mr. Jad Mills and Mr. Steve Parmelee by
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`telephone.
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` Q. And Mr. Jad Mills, is he counsel for
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`Mylan?
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` A. Yes, that's my understanding.
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` Q. And Mr. Parmelee, is he counsel for
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`Breckenridge?
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` A. No. My understanding is that he is also
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`counsel for Mylan.
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` Q. Did you meet with any counsel for Alembic?
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`Page 21
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` A. No, I don't believe so.
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` Q. Did you meet with any counsel for
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`Breckenridge?
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` A. No, I don't believe so.
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` Q. Did you meet with Mr. Jenkins?
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` A. No.
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` Q. How about Mr. Liu?
`
` MR. DOWD: I'll object to that question
`
`based on form of the question and I'll also object to
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`the current question based on the form of the
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`question.
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`BY MS. REISTER:
`
` Q. Did you meet with Mr. Tyler Liu?
`
` A. No, not in preparation for my deposition.
`
` Q. Have you met with Mr. Tyler Liu for other
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`purposes?
`
` A. No.
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` Q. Prior to today, have you ever met
`
`Mr. Tyler Liu before?
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` A. No.
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`DeForest McDuff, Ph.D.
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`December 8, 2016
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` Q. When did you find out that you would be
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`deposed in the IPR proceeding?
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` MR. DOWD: I will object to that question
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`based on the form of the question, the relevance of
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`the question and I will also instruct the witness not
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`to divulge any information that would be considered
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`attorney-client privilege.
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` THE WITNESS: I don't recall specifically
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`but sometime in the last few months. Had some
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`understanding that I might be deposed in the case
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`prior to submitting the declaration. Subsequent to
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`the declaration, understand that I was asked to be
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`deposed.
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`BY MS. REISTER:
`
` Q. And who first contacted you about the
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`declaration that you would prepare in the case?
`
` MR. DOWD: And I'm going to object to that
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`question, one, based on relevance and, two, this is
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`getting awfully close to line of questioning that we
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`dealt with when you deposed Dr. Wang in terms of
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`getting into specifics about the preparation and
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`drafting of declarations. And we've addressed this
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`with the Board previously.
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` And so to the extent that you can
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`establish some relevance to this line of questioning,
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`I will permit it but if you want to get into the
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`particulars of drafting and working with counsel with
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`respect to the declaration, I won't permit it and we
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`will call the Board.
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` Now, if you want to ask questions that go
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`to the merits of the case, I'm happy to answer those
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`questions all day long.
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`BY MS. REISTER:
`
` Q. Dr. McDuff, I asked a very simple question
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`that's a factual question about who first contacted
`
`you. Could you just please provide me with a name?
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` MR. DOWD: I'm going to repeat my
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`objections.
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` MS. REISTER: Your objection is on the
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`record, Mr. Dowd. I'm asking for a name.
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` MR. DOWD: Understood.
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` MS. REISTER: I understand your points.
`
` MR. DOWD: And I'll allow this one
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`question on this point. But I'm asking you, for the
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`purposes of facilitating the deposition and
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`facilitating your case, I'll allow the witness to
`
`answer this question and that's it.
`
` THE WITNESS: Mr. Jad Mills contacted me
`
`on behalf of Mylan and the other petitioners.
`
`BY MS. REISTER:
`
` Q. And approximately when was that?
`
` MR. DOWD: The same objections. And this
`
`is the last question on this topic.
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` THE WITNESS: It was sometime over the
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`last few months, obviously prior to November 14th,
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`2016 but I don't have specific recollection of the
`
`timing.
`
`BY MS. REISTER:
`
` Q. But was it in 2016?
`
` A. Yes.
`
` Q. And sometime prior to the time that you
`
`filed your declaration?
`
` MR. DOWD: Same objections.
`
` THE WITNESS: Yes.
`
`BY MS. REISTER:
`
` Q. In preparing for your deposition today,
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`did you review any documents?
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` MR. DOWD: I will object to that question
`
`based on the form of the question and the relevance
`
`of the question and the foundation of the question.
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`Page 25
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` THE WITNESS: Yes.
`
`BY MS. REISTER:
`
` Q. And what documents were those?
`
` MR. DOWD: Same objections.
`
` THE WITNESS: Generally I reviewed my
`
`declaration that I submitted in this proceeding. I
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`reviewed the declaration submitted by Dr. Vellturo
`
`and I reviewed some of the underlying sources and
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`materials cited by myself and by Dr. Vellturo in our
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`respective declarations.
`
`BY MS. REISTER:
`
` Q. And one of the exhibits that you reviewed
`
`in preparation for your deposition today would be
`
`Exhibit 1158 that you have there in front of you, is
`
`that correct?
`
` A. Yes.
`
` Q. Did you review any documents that were not
`
`cited in your declaration or Dr. Vellturo's
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`declaration?
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` MR. DOWD: I'll object to that question
`
`based on the form of the question and the relevance
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`of the question.
`
` THE WITNESS: The only one I recall is
`
`reviewing my trial testimony from the District Court
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`litigation. That may be an exhibit cited in my
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`declaration. I know it is to some extent.
`
`BY MS. REISTER:
`
` Q. So sitting here today, do you recall any
`
`other documents that were not cited in your
`
`declaration or Dr. Vellturo's declaration that you
`
`reviewed in preparation for your deposition today?
`
` A. Nothing else comes to mind sitting here.
`
` Q. In preparing for your deposition, did you
`
`talk with anyone other than the attorneys you had
`
`identified previously?
`
` MR. DOWD: I'll object to that question
`
`based on the form of the question.
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` THE WITNESS: No.
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`BY MS. REISTER:
`
` Q. You didn't consult with any of your
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`colleagues at Intensity in preparation for the
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`deposition?
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` MR. DOWD: Same objections.
`
` THE WITNESS: I discussed the fact of the
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`deposition occurring and the fact that I would be out
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`of the office, but did not consult them with respect
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`to preparation for the deposition.
`
`BY MS. REISTER:
`
` Q. Dr. McDuff, I would like you to look at
`
`page 2 of your CV, which I believe you have in front
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`of you as Exhibit 1088.
`
` A. Yes.
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` Q. And the top of your CV has a section
`
`labeled education, correct?
`
` A. Yes.
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` Q. And it omits the dates in that section at
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`which you earned each of those degrees, correct?
`
` MR. DOWD: I will object to that question
`
`based on mischaracterizing the document itself and
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`based on the relevance of the question and the lack
`
`of foundation for the question.
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` THE WITNESS: The dates are not listed
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`1-800-FOR-DEPO
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`here in my CV. I'm happy to answer questions about
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`Page 28
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`those if you like.
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`BY MS. REISTER:
`
` Q. Is there a particular reason you don't
`
`include the dates on your CV?
`
` MR. DOWD: I will object to that question
`
`based on the relevance of the question and the lack
`
`of foundation for the question.
`
` THE WITNESS: It's not standard practice
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`for our CV template in my firm.
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`BY MS. REISTER:
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` Q. So when did you earn your Ph.D.?
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` A. 2009.
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` Q. And what was the subject of your Ph.D.
`
`thesis?
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` A. It studied economic substitution and
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`aspects of financial economics in housing markets,
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`higher education and geography.
`
` Q. Is it fair to say that it didn't have
`
`anything to do with pharmaceutical products and
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`research and development relating to pharmaceutical
`
`products?
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`1-800-FOR-DEPO
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`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`Argentum Pharm. v. Research Corp. Techs., IPR2016-00204
`RCT EX. 2193 - 29/190
`
`
`
`DeForest McDuff, Ph.D.
`
`December 8, 2016
`
`Washington, D.C.
`
` MR. DOWD: I will object to that question
`
`based on the relevance of the question and lack of
`
`Page 29
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`foundation.
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` THE WITNESS: I wouldn't say it that way.
`
`Clearly my trainin
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