`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` U.S. Patent No. 6,331,415
`
` Inter Partes Review No: IPR2016-00710
`
` MYLAN PHARMACEUTICALS INC.
` AND MERCK SHARP & DOHME
` CORP.,
` Petitioners,
`vs.
` GENENTECH, INC. AND CITY OF
` HOPE,
`
` Patent Owners.
`__________________________________/
`
` BILZIN SUMBERG PRICE & AXELROD,
` LLP
` 1450 BRICKELL AVENUE
` SUITE 3200
` MIAMI, FL 33131
` Friday, March 3, 2017
` 9:00 a.m. - 1:40 p.m.
`
` DEPOSITION OF REINER GENTZ, PH.D
`
` Taken on behalf of the Petitioners before
` Elizabeth Cordoba, RMR, CRR, FPR, Notary Public in
` and for the State of Florida at Large, pursuant to
` Petitioners' Notice of Taking Deposition in the above
` cause.
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`www.veritext.com
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`Mylan v. Genentech
`IPR2016-00710
`Merck Ex. 1114, Pg. 1
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`
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`Page 2
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`A P P E A R A N C E S :
`A T T O R N E Y S F O R P E T I T I O N E R S M Y L A N :
` E R I C R . H U N T , E S Q .
` N E I L M C L A U G H L I N , P H . D .
` R A K O C Z Y M O L I N O M A Z Z O C H I S I W I K , L L P
` 6 W E S T H U B B A R D S T R E E T
` C H I C A G O I L 6 0 6 3 4
` 3 1 2 - 2 2 2 - 6 3 1 4
` E h u n t @ r m m s l e g a l . c o m
` N m c l a u g h l i n @ r m m s l e g a l . c o m
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`A T T O R N E Y S F O R P E T I T I O N E R S M E R C K :
` M A T T H E W A . T R A U P M A N , E S Q .
` Q U I N N E M A N U E L
` 5 1 M A D I S O N A V E N U E
` 2 2 N D F L O O R
` N E W Y O R K N Y 1 0 0 1 0
` 2 1 2 - 8 4 9 - 7 3 2 2
` M a t t h e w t r a u p m a n @ q u i n n e m a n u e l . c o m
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`A T T O R N E Y S F O R P A T E N T O W N E R S :
`
` A D A M R . B R A U S A , E S Q .
` D U R I E T A N G R I
` 2 1 7 L E I D E S D O R F F S T R E E T
` S A N F R A N C I S C O C A 9 4 1 1 1
` 4 1 5 - 3 6 2 - 6 6 6 6
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`Merck Ex. 1114, Pg. 2
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`Page 3
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` I N D E X
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`WITNESS PAGE
`
` REINER GENTZ, PH.D
`
` Direct Examination by Mr. McLaughlin 5
`
` Cross-Examination by Mr. Brausa 152
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` E X H I B I T S
`
`NUMBER DESCRIPTION PAGE
`
` Exhibit 1079, 1982 Stueber Article, 77
`
` Exhibit 1080, 1984 Stueber Article, 82
`
` Exhibit 1081, US Patent Number 6,541,224, 143
`
` PREVIOUSLY MARKED EXHIBITS
`
` Exhibit 2021, 6
`
` Exhibit 1005, 51
`
` Exhibit 2079, 57
`
` Exhibit 2078, 75
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` Exhibit 1002, 118
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` Exhibit 2005, 133
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` Exhibit 2070, 136
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` Exhibit 2071, 138
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` Exhibit 2067, 141
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`Merck Ex. 1114, Pg. 3
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`Page 4
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`Thereupon,
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` REINER GENTZ, PH.D,
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`having been first duly sworn or affirmed and responded,
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`"Yes," was examined and testified as follows:
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` MR. MCLAUGHLIN: Good morning, Dr. Gentz. I
`
` just want to start by saying this is a deposition
`
` being taken in Inter-Partes Review Proceeding
`
` IPR2016-00710. It is an IPR between Mylan and Merck
`
` and Genentech and City of Hope.
`
` Do you understand that you are here to provide
`
` testimony?
`
` THE WITNESS: I understand.
`
` MR. MCLAUGHLIN: In this IPR?
`
` THE WITNESS: Yes.
`
` MR. MCLAUGHLIN: We will do counsel appearances
`
` now. I am Neil McLaughlin from the law firm Rakoczy
`
` Molino, on behalf of the Mylan defendant/petitioner.
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` MR. HUNT: Eric Hunt, also from Rakoczy Molino
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` Mazzochi Siwik, on behalf of the Mylan petitioner.
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` MR. TRAUPMAN: Matt Traupman from Quinn
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` Emanuel, representing petitioner Merck.
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` MR. BRAUSA: Adam Brausa, from Durie Tangri, on
`
` behalf of respondents Genentech, City of Hope, as
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` well as the witness Dr. Gentz.
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` THE WITNESS: And I am Reiner Gentz, from Gentz
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`Veritext Legal Solutions
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`Merck Ex. 1114, Pg. 4
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`Page 5
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` Biotechnology Consultants.
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` DIRECT EXAMINATION
`
`BY MR. MCLAUGHLIN:
`
` Q. So you were deposed last year in another IPR.
`
`So you probably heard these same instructions, but I will
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`just go over them briefly again. Let's try not to talk
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`over each other. I will ask questions. If you could wait
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`until my question is finished and then provide your
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`answer, that way we will have a clear record and the court
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`reporter will have a clear time today.
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` We will take breaks from time to time.
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` A. Okay.
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` Q. Usually about every hour. But any time you
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`need a break, feel free to let us know. I just ask that
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`you not take a break while a question is pending.
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` A. I know.
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` Q. Your counsel will object from time to time.
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`You are still obligated to answer the question, unless of
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`course it is a privilege objection and then you have been
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`instructed not to answer.
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` Do you understand these --
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` A. I understand.
`
` Q. -- instructions? Okay.
`
` So since the deposition last year, have you
`
`been deposed in any other matter?
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`www.veritext.com
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`Veritext Legal Solutions
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`Merck Ex. 1114, Pg. 5
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` A. No.
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` Q. Have you been deposed in connection with a
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`Page 6
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`Cabilly patent?
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` A. No.
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` Q. Have you provided any other declarations or
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`affidavits since that time?
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` A. No, no declarations.
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` Q. How would you define the word "gene"?
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` A. A gene is, in code, something that can be
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`either protein or an RNA.
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` Q. Okay. So like an open reading frame?
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` A. In most cases, if you talk about protein. But
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`a gene can also be an RNA. It doesn't have to be a DNA in
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`the new definitions. Originally, one said one gene, one
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`protein and then it was modified. Today the RNA molecules
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`include it too because they can have function too.
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` Q. So it is something that is expressed, something
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`that would be expressed?
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` MR. BRAUSA: Objection to form.
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` THE WITNESS: Yes.
`
` (Previously marked Exhibit 2021, was referred
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` to.)
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`BY MR. MCLAUGHLIN:
`
` Q. I am going to hand you what has already been
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`marked in this IPR as Exhibit 2021. Do you recognize this
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`www.veritext.com
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`Merck Ex. 1114, Pg. 6
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`Page 7
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`as your declaration submitted in IPR2016-00710?
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` A. Yes, I recognize.
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` Q. I understand you submitted one in a prior IPR
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`dealing with Sanofi; is that correct?
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` A. That is correct.
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` Q. Were you asked to review this before signing
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`and dating again?
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` A. Yes.
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` Q. And did you review this before signing and
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`dating?
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` A. Yes, I reviewed.
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` Q. Did you make any changes?
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` A. In this declaration?
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` Q. Correct.
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` A. No, not in this declaration.
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` Q. Since the previous one in this --
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` A. Since the first one had some very minor words.
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` Q. Okay.
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` A. It is 99 percent definitely.
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` Q. Okay. Were you asked to make any changes?
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` A. No.
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` Q. Did you ask the attorneys to make any changes?
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` MR. BRAUSA: Objection. I am going to instruct
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` the witness not -- you can answer that question.
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` Actually, I am going to instruct you not to answer.
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`www.veritext.com
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`Veritext Legal Solutions
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`Merck Ex. 1114, Pg. 7
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` It is invading attorney-client privilege or work
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` product.
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` THE WITNESS: Okay.
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`BY MR. MCLAUGHLIN:
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` Q. Are you going to follow that instruction?
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` A. Hmm?
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` Q. Are you going to follow that instruction?
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` A. I had no instruction.
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` MR. BRAUSA: He is referring to the instruction
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` I just gave you, not to answer on the basis of work
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` product.
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` THE WITNESS: If my lawyer says, then I follow.
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`BY MR. MCLAUGHLIN:
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` Q. Okay. I noticed in the declaration that was
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`submitted in IPR2016-00710, I notice there was no CV
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`attached to this declaration. Do you know why that is?
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` A. My CV?
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` Q. Right. There was no CV attached to this
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`declaration.
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` A. Okay.
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` Q. Do you know why that is?
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` A. No. I forgot. I gave you a CV in the other,
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`Sanofi, I know there was a CV.
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` Q. There was. There was. But there was not one
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`in this case. Do you know why?
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`Merck Ex. 1114, Pg. 8
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` A. No.
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` Q. Do you know, have there been any changes to
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`Page 9
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`your CV --
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` A. No.
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` Q. -- since the one that you --
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` A. In the last year, no changes.
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` Q. Okay. There is also not a list of materials
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`considered attached to this declaration. Do you know why
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`that is?
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` A. No. I don't know. I have a list. I have got
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`a list of what I considered.
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` Q. So you understand, in the previous -- I will
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`call it the Sanofi IPR, so you will understand I am
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`referring to the previous IPR -- in that IPR, attached to
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`your declaration was a list of materials that you had
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`considered.
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` Do you recall that?
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` A. Okay. Yes.
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` Q. There was not one attached to the declaration
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`submitted in this IPR. Do you know why that is?
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` A. No, I don't know.
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` Q. There was no discussion with your attorneys
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`regarding the attachment of the list of materials
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`considered?
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` MR. BRAUSA: And that is a "yes" or "no"
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`Merck Ex. 1114, Pg. 9
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` question.
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` THE WITNESS: Can you repeat? I didn't get it,
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` really. Why there was no list attached? I don't
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`Page 10
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` know.
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`BY MR. MCLAUGHLIN:
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` Q. Okay. Were there any additional materials that
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`you reviewed since signing --
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` A. No. No.
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` Q. If you would let me finish my question, I would
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`appreciate it.
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` A. Sorry.
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` Q. Were there any additional materials that you
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`considered since signing your declaration in the Sanofi
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`IPR made in 2015 and when you submitted this declaration
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`in December of last year?
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` A. Not really. But I make some searches according
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`to the protein of multimer, but we didn't include
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`anything.
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` Q. Did you say you did some searches?
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` A. Yeah.
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` Q. What kind of searches?
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` A. Searches related to antibodies in this time
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`frame from 1981 to '83.
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` Q. And were there additional materials from that
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`search that you reviewed?
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`Merck Ex. 1114, Pg. 10
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`Page 11
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` A. No. It was not made in order to change
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`anything in my declaration, no.
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` Q. And who initially drafted your declaration?
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`Was that you or the attorneys?
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` A. Well, that is my declaration. I didn't type
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`it, no.
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` Q. Who chose the words that went into your
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`declaration?
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` A. They are my wordings.
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` Q. I'm sorry. I didn't catch that.
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` A. These are my words in this declaration.
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` Q. Okay. Also, your hourly rate is not included
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`in the declaration. What is your hourly rate for the
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`consulting work that you are doing in this IPR?
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` A. It is 400 per hour. And travelling, always the
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`whole day.
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` Q. Okay. I would like to ask you to turn to
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`paragraph eight. And here you say, "I have also been
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`asked to give my views on how a scientist with a PhD in
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`molecular biology or a related discipline as of April 8,
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`1983 would have interpreted the work done by my group at
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`the Bujard lab, as disclosed in the publication Gentz, et
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`al."
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` Do you see that?
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` A. Yes, I see.
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` Q. So you have been asked to give your opinions
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`from the perspective of someone with a PhD as of 1983; is
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`Page 12
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`that correct?
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` A. Yes.
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` Q. In 1983 you were still a student; isn't that
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`correct?
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` A. In 1983 I had finished my PhD in the fall. I
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`had done the work and I was writing my thesis, to be
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`exact.
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` Q. So you weren't done with your PhD as of April
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`of 1983, correct?
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` MR. BRAUSA: Objection to form.
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` THE WITNESS: As I said, I had done the work
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` and I was writing.
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`BY MR. MCLAUGHLIN:
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` Q. You had not been awarded your PhD as of April
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`of 1983?
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` A. I think I got it in the beginning of '84, the
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`document.
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` Q. Okay. And what did you do after that?
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` A. After my PhD?
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` Q. Yes.
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` A. Well, Hermann Bujard, he in '83 he accepted a
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`position at Hoffman La Roche as head of biological
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`research. And he had offered me and other people in the
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`www.veritext.com
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`Merck Ex. 1114, Pg. 12
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`Page 13
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`group if we would be interested to join him there.
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`Because he was building up a completely new department.
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`And originally I would have thought I would make a post
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`doc directly. But I was very good and I was promised you
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`can go after a few years somewhere and make a sabbatical,
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`which I made later on.
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` So I went to Roche. Bujard was the head of the
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`pick unit, probably 150, 200 people. And some of his
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`students during that time '84, '85 and '86, his students
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`to finish the PhD. Because I had started in Heidelberg
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`making the PhD, in the process I was leaving. So he kept
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`his labs there, but the people that already had started
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`went to Roche.
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` Q. And how long were you at Roche?
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` A. I left in '93.
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` Q. Did you work with Dr. Bujard that entire time?
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` A. Well, Bujard left after about three years. He
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`was replaced by Michael Steinmetz, which you might know.
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` Q. Okay. So Dr. Bujard left Roche in
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`approximately 1987; is that correct?
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` A. Yeah, must have been that time. To the best of
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`my knowledge, it was '87, yes.
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` Q. Okay. And what kind of work did you do at
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`Roche?
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` A. At Roche, initially -- let's exit. I had one
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`Merck Ex. 1114, Pg. 13
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`Page 14
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`that they gave you about 30 percent of the time to work on
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`what you want to do. No? So I worked on secretion
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`mechanisms. Then our group supported various groups that
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`Bujard either had set up or they were already existing.
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`There was a malaria vaccine group. There was a TNF
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`receptor group. We did cloning TNF receptors. There was
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`a group working in mainly interferon gamma.
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` So on one side I make new work, at Roche was
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`all of the patents for prokaryotic and eukaryotic. And I
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`supported groups making proteins or helping them
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`screening, things like that. So it was on one side
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`supporting the company and one side it was Bujard, he
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`wanted to do exploratory and he chose to. He directed
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`good people by doing this. His work was more important.
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`He was actually the one I worked most with.
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` Q. Okay. And was Bujard in that time, was he also
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`interested in helping groups make proteins?
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` A. Helping proteins? Well, he oversaw. We made
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`proteins. Not like we made vaccine candidates, for
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`example. I expressed soluble TNF receptors.
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` Q. And so the secretion mechanisms that you
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`referred to that you were working on at Roche, was that in
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`relation to recombinant protein expression?
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` A. Yes. We tried a little bit to understand,
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`though I used the signal peptide, the synthetic one, and
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`tested various genes, prokaryotic and eukaryotic. So I
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`had found by accident the mutant. Actually, the mutant is
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`two publications because we understood more or less what
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`happened during the secretion process.
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` Q. Why were you interested in looking at secretion
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`mechanisms?
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` A. Well, I think it is obvious that we were
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`interested if it is possible to make some protein in a
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`soluble form.
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` Q. So secretions --
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` A. In E. Coli.
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` Q. So the secretion mechanism would assist in
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`maintaining the protein in soluble form?
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` A. Could if you are lucky, yeah. The ones I tried
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`were not.
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` Q. So what would happen to those proteins?
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` A. The protein stuck in the membrane.
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` Q. Did you ever --
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` A. Let's say you can probably not secrete
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`cytoplasmic proteins, but even proteins in the CM gamma
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`don't secrete any.
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` Q. So you said they would get stuck in the
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`membrane?
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` A. They are very fast degraded, so they don't even
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`appear in the cytoplasm. Not cytoplasm, the periplasm.
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` Q. Did you ever experience inclusion bodies?
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` MR. BRAUSA: Objection to form.
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` THE WITNESS: In general bacterium?
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`BY MR. MCLAUGHLIN:
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` Q. In the protein expression work that you were
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`doing in E. Coli or bacteria.
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` A. Lots, yes.
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` Q. And in your experience what was it possible to
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`do with those inclusion bodies?
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` MR. BRAUSA: Objection. Form.
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`BY MR. MCLAUGHLIN:
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` Q. Let me back up. Did you ever solubilize
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`inclusion bodies in order to obtain or attempt to obtain
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`active --
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` A. Well, the issue is not the solubilization. I
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`think you can solubilize all proteins in a strong
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`detergent. You can use 6a molar urea, you can use
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`guanidine. So solubilization is not the issue. The issue
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`is that you can leave the protein in the correct form,
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`which in most cases is not simple. Each protein is
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`different.
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` So I had proteins that refolded, that were not
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`homogeneous. I would have the right forms and wrong forms
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`and it was difficult to separate. And some simple
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`proteins, I have a patent on the refolding of chemokines.
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`I could refold some chemokines and it would be the same as
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`several ones because they are folded, pretty simple. If
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`you are folding with many cysteines, the number of
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`refolded proteins, they had heterogenetic increases if the
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`number of cysteine residues increases, there are many
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`cysteines. And if there are more than four already, you
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`get some problems.
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` Q. What kind of mechanisms did you use to refold
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`proteins?
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` MR. BRAUSA: Objection. Form.
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` THE WITNESS: Well, to name one or two, the
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` simplest one would be dilute, to make something, you
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` dilute in one step, which works in rare cases.
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` During the years we were involved by either
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` protecting the cysteines, to slow down the problem.
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` One side you make it fast and the other you make it
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` slow and give time. People add glutathione,
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` cysteines, whatever they do to give more time.
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` In the last 15 years many, many different
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` methodologies have been developed. But you cannot
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` predict which one you have to use. You have to test
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` it.
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`BY MR. MCLAUGHLIN:
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` Q. And were methodologies for that known as of
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`April 1983?
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` MR. BRAUSA: Objection. Form.
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` THE WITNESS: All of them, of course not. I
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` was more aware of the insulin gene that had been the
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` alpha and the better genes that have been refolded.
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`BY MR. MCLAUGHLIN:
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` Q. Okay. As of April of 1983, which mechanisms
`
`were you aware of for the refolding of proteins?
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` MR. BRAUSA: Objection. Form.
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` THE WITNESS: 1983? So that's more what was --
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` because at that time I didn't purify any proteins
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` myself. Bujard at that time was studying promoters
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` in the first. It's mostly solubilizing in detergent,
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` you know.
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`BY MR. MCLAUGHLIN:
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` Q. Okay.
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` A. There might be sulfonating or something like
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`that.
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` Q. Could you repeat the last part of what you said
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`regarding the sulfonating?
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` A. Yes. Either sulfonating or you protect the
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`cysteines, and before solubilizing in a detergent.
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` Q. Was denaturing using urea and guanidine known
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`as of 1983?
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` A. That, I don't recall now.
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` Q. Did you ever use a technique employing urea and
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`guanidine to denature proteins during your refolding step?
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` MR. BRAUSA: Objection to form.
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` THE WITNESS: I did later on, when I was
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` responsible at Hoffman La Roche for purifying, and
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` later on at Human Genome Sciences we purified more
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` than 200 proteins from E. Coli too. Initially, we
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` tested different detergents there, different
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` concentrations, especially.
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`BY MR. MCLAUGHLIN:
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` Q. Okay. After Roche you went to Human Genome
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`Sciences; is that correct?
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` A. Yes.
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` Q. And what did you do at Human Genome Sciences?
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`Can I call it HGS?
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` A. HGS.
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` Q. What did you do at HGS?
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` A. Well, at HGS I was responsible for a department
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`that was called protein expression, later protein
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`development, which included to make proteins in bacteria,
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`insect cells. We did a lot using the baculovirus system.
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`We used Escherichia and we used mammalian cells or CHO and
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`NSO cells, especially for antibodies.
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` I was also responsible for the boarding
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`characteristic. I was responsible for formulation and
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`stability. I was responsible for the clinical
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`manufacturing. We brought very quickly, within the first
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`two years, phase one clinical studies. Initially, we
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`built small phase one suites, both mammalian and E. Coli.
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`Later, we built the big pilot plant, it had already a
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`2,000 liter mammalian bioreactor and 750 liter for E.
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`Coli.
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` I was for a while responsible for this plant.
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`And later on also the supervisor reported to me of this
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`plant. And the last two years I was involved in the
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`design and construction of the commercial manufacturing
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`plant, but I left in 2002, when this construction had
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`already started.
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` Q. You said some of this work was in relation to
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`antibodies?
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` A. Yeah. Human Genome Sciences developed several
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`antibodies, as you may know, not that you have to prove,
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`Benlysta in the area of lupus, the anthrax antibodies.
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`This was a project that started in my department. So
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`let's say a design of the target, everything, which
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`protein to use, which area to use the antibody against.
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`It was all made in my department, we made the protein.
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` The screening later was made in collaboration
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`with a group that was set up special for this monoclonal
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`antibody group. It had nothing to do, but I tell you,
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`the head of the laboratory who makes antibodies was my
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`wife. So I know what an antibody is.
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` Q. Okay. So how familiar would you say you are
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`Page 21
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`with antibody structure?
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` A. In '83?
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` Q. Sure. Let's start with '83. Were you familiar
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`with antibody structure as of 1983?
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` A. Well, everybody should know at least an
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`antibody is a heterodynamic molecule, has heavy in the
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`light chain, and that two of them form a tetramer, and so
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`the simple things that you know. You know that the hinge
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`region and the constant region and the variable region and
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`you know the binding sites. Just I think a scientist as
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`it is described here knew.
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` Q. Okay. And are you familiar with what a Fab
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`fragment?
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` A. Fab fragment, I know that.
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` Q. Are you familiar with what an Fv fragment is?
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` A. Yes.
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` Q. Okay. Going back to paragraph eight in your
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`declaration, you reference "work done by my group at the
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`Bujard lab."
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` What do you mean when you are referencing your
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`group?
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` A. Where are you?
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` Q. In the middle of paragraph eight, where it says
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`"the work done by my group."
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` A. Well, that is mainly me and might be in some
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`cases the technician that helped to set up some things.
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` Q. Were there other PhD scientists in your group?
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` A. At that time I had no PhDs.
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` Q. So it was just technicians mainly that you were
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`overseeing?
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` A. Right.
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` Q. Okay. How many people were in Dr. Bujard's lab
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`at the time that you were there?
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` A. At the University of Heidelberg he had at the
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`max ten. He had two post docs, he had two or three
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`doctoral students, and then three, four master students.
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`But a relatively small laboratory. There were two boxes
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`with two and two and two and two, plus one left for
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`electron microscope.
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` Q. After Dr. Bujard left Roche in 1987, did you
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`maintain contact with him?
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` A. I had some contact with him, but not
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`tremendous. He visited me at Human Genome Sciences, for
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`example. I visited Bujard. I visited in Germany. We
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`went for dinner. He invited everybody that was still in
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`Heidelberg. So I talked to him a few times. He was very
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`interested in what we were doing at Human Genome Sciences,
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`due to the sequencing of trying to get all human expressed
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`genes.
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` Q. When was the last time you were in
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`communication with Dr. Bujard?
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` A. That's a long time. Ever since I am in Brazil,
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`I have not talked with Bujard, I think. And he is
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`85 years old now, I think, or 86.
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` Q. Ever since you were in Brazil, you said?
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` A. Yeah, I think.
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` Q. Did you maintain contact with anybody else in
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`the Bujard lab after leaving Dr. Bujard's lab in
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`Heidelberg?
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` A. Well, I mentioned that Bujard took several
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`people. There was Dietrich Stueber, who was the most
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`senior student. He was still at Roche when I left in
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`1993. He was a friend of mine, you know. We lived quite
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`a while one block apart from each other, no?
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` Then he had students. If you look at the
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`papers, we had added Ulrich Deuschle, Mick Camera, Ursula
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`Peschke and Emanuel Peron. They came all to Roche and I
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`even oversaw them until they finished the PhD thesis.
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`Remember, I mentioned Bujard had barely any time to look
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`for the students . That is why I am on many papers of the
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`Bujard group from 1985, '86 and also '87.
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` Q. And of all those people that you just listed,
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`did you maintain contact with them after leaving Roche?
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` A. On a more loose basis. I was more than once in
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`Basel and I dropped in the company and said hello, you
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`know. Yes, I did. And some people, remember me as a
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`professor in Heidelberg to know. I have some people in
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`Facebook, but we don't talk so much --
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` Q. Sure.
`
` A. -- of science.
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` Q. So at the end of paragraph eight, you reference
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`the Bujard patent. That is US patent number 4495280. Do
`
`you see that?
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` A. Yes.
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` Q. So if I refer to -- if I say "the Bujard
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`patent" throughout the deposition today, you will know
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`that I am referring to the 280 patent?
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` A. Mm-hmm.
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` Q. Okay.
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` A. Yes.
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` Q. Did you ever discuss the 280 patent with any
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`members of the Bujard lab?
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` A. No.
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` Q. Did you ever discuss the 280 patent with
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`Dr. Bujard?
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` A. No.
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` Q. Did you draft any portions of the Bujard
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`patent?
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` A. No.
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` Q. How much interaction did you have with Stanley
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`Cohen prior to the filing of the Bujard patent?
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` A. More loose contact. In a sense that he
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`visited, I think it is two times that he visited
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`Heidelberg, especially after we had the promoters cloned.
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`And also Annie Chang, who also visited once the
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`laboratories that we talked about.
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` He was very pleased that we could do this. And
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`at that time I had the idea I would make my post doc in
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`his lab because Bujard told me once that there wouldn't be
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`any problem to do it. And then he changed my direction.
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` Q. So did you ever discuss the Bujard patent with
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`Stanley Cohen?
`
` A. No.
`
` Q. Did you ever discuss the Bujard patent with
`
`Annie Chang?
`
` A. No. I did not discuss the patent with anybody.
`
` Q. What was Annie Chang's status at the time in
`
`Stanley Cohen's lab?
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` MR. BRAUSA: Objection to form.
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` THE WITNESS: She had, to my knowledge, no PhD.
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` She was, everybody knew, a great scientist. So you
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` cannot say she was a technician. I think she worked
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` like a scientist without a PhD, I would assume.
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`BY MR. MCLAUGHLIN:
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` Q. Okay.
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` A. I cannot know the title she had.
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` Q. And did you have any interaction with Dr. Cohen
`
`or Annie Chang during the drafting --
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` A. No.
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` Q. -- of the application that would become the
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`Bujard patent?
`
` A. No.
`
` Q. Did you ever have any interaction with a patent
`
`attorney that was drafting the Bujard patent?
`
` A. No.
`
` Q. Did you reach out to anyone, any of the listed
`
`inventors on the Bujard patent, during the process of
`
`drafting the declaration that you submitted in the Sanofi
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`IPR?
`
` A. Could you please repeat? I didn't get it.
`
` Q. Sure. Did you reach out to anyone, any of the
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`listed inventors on the Bujard patent, during the process
`
`of drafting the declaration that you submitted in the
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`Sanofi IPR?
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` A. No, I didn't talk with anybody.
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` Q. Did you re