UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MYLAN PHARMACEUTICALS INC., TEVA PHARMACEUTICALS USA,
`INC. and AKORN INC.,1
`Petitioners,
`
`v.
`
`ALLERGAN, INC.
`
`Patent Owner.
`
`
`Case IPR2016-01127 (8,685,930 B2)
`Case IPR2016-01128 (8,629,111 B2)
`Case IPR2016-01129 (8,642,556 B2)
`Case IPR2016-01130 (8,633,162 B2)
`Case IPR2016-01131 (8,648,048 B2)
`Case IPR2016-01132 (9,248,191 B2)
`
`
`DECLARATION OF SHANNON M. BLOODWORTH IN SUPPORT OF
`PETITIONER MYLAN PHARMACEUTICAL INC.’S MOTION FOR
`PRO HAC VICE ADMISSION OF SHANNON M. BLOODWORTH
`UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`1 Cases IPR2017-00576 and IPR2017-00594, IPR2017-00578 and IPR2017-00596,
`IPR2017-00579 and IPR2017-00598, IPR2017-00583 and IPR2017-00599,
`IPR2017-00585 and IPR2017-00600, and IPR2017-00586 and IPR2017-00601,
`have respectively been joined with the captioned proceedings. The word-for-word
`identical paper is filed in each proceeding identified in the caption pursuant to the
`Board’s Scheduling Order (Paper 10).
`
`MYLAN - EXHIBIT 1138
`Mylan Pharmaceuticals Inc. et al. v. Allergan, Inc.
`IPR2016-01127, -01128, -01129, -01130, -01131, -01132
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`MYLAN PHARMACEUTICALS INC., TEVA PHARMACEUTICALS USA,
`INC. and AKORN INC.,1
`Petitioners,
`
`v.
`
`ALLERGAN, INC.
`
`Patent Owner.
`
`
`Case IPR2016-01127 (8,685,930 B2)
`Case IPR2016-01128 (8,629,111 B2)
`Case IPR2016-01129 (8,642,556 B2)
`Case IPR2016-01130 (8,633,162 B2)
`Case IPR2016-01131 (8,648,048 B2)
`Case IPR2016-01132 (9,248,191 B2)
`
`
`DECLARATION OF SHANNON M. BLOODWORTH IN SUPPORT OF
`PETITIONER MYLAN PHARMACEUTICAL INC.’S MOTION FOR
`PRO HAC VICE ADMISSION OF SHANNON M. BLOODWORTH
`UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`1 Cases IPR2017-00576 and IPR2017-00594, IPR2017-00578 and IPR2017-00596,
`IPR2017-00579 and IPR2017-00598, IPR2017-00583 and IPR2017-00599,
`IPR2017-00585 and IPR2017-00600, and IPR2017-00586 and IPR2017-00601,
`have respectively been joined with the captioned proceedings. The word-for-word
`identical paper is filed in each proceeding identified in the caption pursuant to the
`Board’s Scheduling Order (Paper 10).
`
`MYLAN - EXHIBIT 1138
`Mylan Pharmaceuticals Inc. et al. v. Allergan, Inc.
`IPR2016-01127, -01128, -01129, -01130, -01131, -01132
`
`
`
`
`
`I, SHANNON M. BLOODWORTH, declare as follows:
`
`1.
`
`I am more than twenty-one years of age, competent to present this
`
`affidavit, and have personal knowledge of the facts set forth herein.
`
`2.
`
`This affidavit is given in support of Petitioner’s Mylan Pharmaceutical
`
`Inc.’s Motion for Pro Hac Vice Admission of Shannon M. Bloodworth under 37
`
`C.F.R. § 42.10(c).
`
`3.
`
`4.
`
`I am a partner in the patent litigation group at Perkins Coie LLP.
`
`I am a member in good standing of the Bar of the States of Maryland
`
`and Wisconsin, the Commonwealth of Virginia and the District of Columbia. I am
`
`also admitted to practice before the United States Courts of Appeals for the Fourth
`
`Circuit, D.C. Circuit, Federal Circuit and the United States Supreme Court. I am
`
`admitted to practice before the United States District Courts for D.C. and Maryland,
`
`and the Supreme Courts of Virginia and Wisconsin.
`
`5. My Bar membership numbers are VA 46671, DC 474925 and
`
`WI 1088470.
`
`6.
`
`I have been practicing law for almost 16 years, including litigating
`
`patent cases, specifically focused on pharmaceutical patent cases, for the last 15
`
`years.
`
`7. More generally, I have represented the Mylan and/or and its various
`
`related entities in litigating significant pharmaceutical patent cases, such as the
`
`1
`
`
`
`
`
`following cases:
`
`• Teva Pharmaceuticals USA Inc., et al. v. Mylan Pharmaceuticals Inc., et
`
`al., Civil Action No. 1:09-cv-08824-WHP (U.S. District Court for the
`
`Southern District of New York);
`
`• Teva Pharmaceuticals USA Inc., et al. v. Mylan Pharmaceuticals Inc., et
`
`al., No. 10-cv-7246 (KBF) (U.S. District Court for the Southern District
`
`of New York);
`
`• Teva Pharmaceutical USA Inc., et al. v. Mylan Pharmaceutical Inc., et
`
`al., Civil Action No. 1:14-cv-01278-GMS (U.S. District Court of District
`
`of Delaware);
`
`• Apotex, Inc. v. Daiichi Sankyo, Inc. et al., Civil Action No. 1:15-cv-03695
`
`(U.S. District Court for the Northern District of Illinois);
`
`• Janssen Biotech, Inc. et al. v. Mylan Pharmaceuticals Inc., et al., Civil
`
`Action No. 2:15-cv-05909-KM-JBC (U.S. District Court for the District
`
`of New Jersey);
`
`• Astrazeneca Pharmaceuticals LP v. Agila Specialties Inc.et al., Civil
`
`Action No. 1:15-cv-06039-RMB-KMW (U.S. District Court for the
`
`District of New Jersey);
`
`• Astrazeneca AB et al. v. Mylan Laboratories Ltd., Civil Action No. 3:12-
`
`cv-01378-MLC-TJB (U.S. District Court for the District of New Jersey);
`
`2
`
`
`
`
`
`• The Medicines Co. v. Mylan Inc., Civil Action No. 1:11-cv-01285 (U.S.
`
`District Court for the Northern District of Illinois);
`
`• Teva Neuroscience, Inc. et al. v. Mylan Inc. et al., Civil Action No. 2:10-
`
`cv-05078-CCC-JBC (U.S. District Court for the District of New Jersey);
`
`and
`
`• Novo Nordisk Inc. v. Mylan Pharmaceutical Inc., et al., Civil Action No.
`
`3:09-cv-02445-FLW-DEA (United States District Court for the District of
`
`New Jersey).
`
`8.
`
`I have never been disbarred, sanctioned or cited for contempt by any
`
`court or administrative body. I am not currently suspended in any bar or by any
`
`court or administrative body.2
`
`9.
`
`I have never had a court deny my application for admission to practice.
`
`10.
`
`I am familiar with the subject matter of this proceeding.
`
`11. Given my familiarity with the underlying facts and my litigation
`
`experience with the Federal Rules of Evidence, I have experience and expertise
`
`important to representing Mylan’s interests in this matter.
`
`2 In May 2004, during transition to a new law firm, my DC Bar dues were
`
`inadvertently not paid. As soon as I discover the non-payment, I immediately paid
`
`all outstanding dues and was reinstated. I have been a member in good standing
`
`ever since.
`
`3
`
`
`
`
`
`12.
`
`I have read and will comply with Office Patent Trial Practice guide
`
`and the Board’s Rules of Practice for Trials, as set forth in Part 42 of 37 C.F.R.
`
`13.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R.§§ 11.101 et seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`14.
`
`I have previously applied for admission pro hac vice before the United
`
`States Patent and Trademark Office in the following IPRs:
`
`a. IPR No. 2015-00643
`
`b. IPR No. 2015-00644
`
`c. IPR No. 2015-00830
`
`15.
`
`I hereby declare that all statements made herein of my own knowledge
`
`are true and that all statements made on information and belief are believed to be
`
`true; and further that these statements are made with the knowledge that willful
`
`false statements and the like are punishable by fine, imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`
`
`September 21, 2017
`
`
`
`
`
`
`
`
`
`/s/ Shannon M. Bloodworth
`Shannon M. Bloodworth
`
`4
`
`
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