`FOR THE DISTRICT OF DELAWARE
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`ASTRAZENECA AB,
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`Plaintiff.
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`v.
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`AUROBINDO PI-IARMA LTD. and
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`AUROBINDO PI-IARMA U.S.A., INC,
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`Defendants.
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`\./\J\/%/&r\_/\_/\./\/\/\/\/
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`C .A. No. I4-cv-664-GMS
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`(CONSOLIDATED)
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`OPENING EXPERT REPORT OF JAMES C. POWERS, Ph.D.
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`Dated:
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`28‘ I 2,0lé
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` C
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`James C. Powers. Ph.D.
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`1.
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`I have been retained by Defendants (i) Aurobindo Pharma Ltd. and Aurobindo
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`Pharma U.S.A., Inc. (“Aurobindo”); (ii) Wockhardt Ltd. and Wockhardt USA LLC
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`(“Wockhardt”); (iii) Actavis Laboratories FL, Inc. and Watson Laboratories, Inc. (“Actavis”);
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`(iv) Mylan Pharmaceuticals Inc. (“Mylan); (v) Sun Pharma Global FZE and Sun Pharmaceutical
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`Industries Ltd. (“Sun”); and (vi) Amneal Pharmaceuticals LLC (“Amneal”) (collectively
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`“Defendants”) to provide my opinions regarding invalidity of U.S. Patent No. RE 44,186 (“the
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`RE ’186 patent”).
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`2.
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`This report contains my opinions concerning obviousness under 35 U.S.C. § 103;
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`as well as technical background information; the bases for my opinions; data or other
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`information considered by me in forming those opinions; my qualifications; and compensation
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`for my services. My opinions and the facts set forth in this report are based upon information I
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`reviewed and upon my fifty-plus years of education, knowledge and experience in chemistry,
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`biochemistry, medicinal chemistry, pharmaceutical chemistry and related fields.
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`3.
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`If called upon to testify at trial, I expect to testify about:
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` my background, qualifications, and experience;
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`technical background related to the RE ‘186 patent;
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`the knowledge and level of skill of a person of ordinary skill in the art of
`pharmaceutical chemistry as of the earliest alleged effective filing date of the RE ‘186
`patent;
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`the patent-in-suit and its claims, specifications, and prosecution history;
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`the teachings of various pieces of prior art;
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` my opinions concerning the invalidity of claims 8, 9, 25 and 26 of the RE ’186 patent
`under 35 U.S.C. § 103 as obvious; and
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` other issues related to the patent-in-suit.
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`4.
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`I may also testify in rebuttal to expert(s) testifying on behalf of Plaintiff. I reserve
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`the right to amend or supplement my opinions in light of evidence presented by Plaintiff or
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`2
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