`
`rhompson
`Chief Beverly Cook
`Chief MichaelConners
`Sub-Chief Chelyl Jacobs
`Sub-Chief Shelley Jacobs
`Sub-Chief Agnes Jacobs
`
`Kent6nha/Oct ober 12, 2017
`
`Hon. Charles Grassley
`Chairman
`Senate Judiciary Committee
`Washington, D.C.20510
`
`Hon. Dianne Feinstein
`Ranking Member
`Senate Judiciary Committee
`Washington, D.C.20510
`
`Tekwanonhwer6:tons/Greetings Chairman Grassley and Ranking Member Feinstein,
`
`On behalf of the Saint Regis Mohawk Tribe ("SRMT" or "the Tribe"), we are writing to clarify cerlain
`claims and misperceptions made in recent media coverage and in a September 27'h letter from Senator
`Maggie Hassan (D-NH), Senator Bob Casey (D-PA), Senator Sherrod Brown (D-OH), and Senator Richard
`Blumenthal (D-CT) requesting that the Senate Judiciary Committee investigate the Tribe's purchase of the
`Orange-Book patents for RESTASIS@ (Cyclosporine Ophthalmic Emulsion) from Allergan, Plc.
`
`Background on the Saint Regis Mohawk Tribe
`
`The Saint Regis Mohawk Tribe is a federally recognized tribal government located in our traditional
`Territory of Akwesasne, an economically depressed region ofNorthern New York State. The Tribe consists
`of over 15,600 enrolled tribal members, with approximately 8,000 tribal members living on the Territory.
`As one of the primary employers in the region, we take pride in our commitment to promoting and
`strengthening our region's economy. The Tribe and its tribally owned enterprises-Akwesasne Mohawk
`Casino Resort, Mohawk Networks, and Akwesasne TV-provide much-needed employment opportunities
`for more than 1,600 residents of Northern New York and devotes more than $52 million in salaries annually.
`Additionally, SRMT provides a number of essential services to tribal members and our neighbors, inclLrding
`public safety, economic development, and broadband, Despite our efforts, critical budget shortfalls remain.
`
`To ensure the strength and vigor of our regional economy and to protect against persistent threats to our
`tribal general fund and federal funding, we have been forced to diversiff our investment strategies. For
`example, in recent years, our gaming revenue has leveled off. This coupled with inflation, rising costs of
`living and healthcare, additional pressure of persistent budget cuts, sequestration, elimination of federal
`programs, increased competition, the Tribe's inability to tax, and limited economic development
`opportunities due to our rural location, have further strained our extremely limited budget. While we do the
`best we can to augment shortfalls in federal funding for the health, public safety, housing, environment,
`and educational services, we consistently run into roadblocks when attempting to access capital that is
`essential to promoting the health and wellbeing of our members, employees, and neighboring non-Native
`communities. This transaction with Allergan is thus, specifically intended to supplement our current
`funding in order to more adequately exercise and fulfill our essential governmental obligations to our
`members.
`
`Holnlng Sulld I Bensr Tomurrou*
`lakhiisnaw{:se' $6nha Aioianot6nhaks ns [ni 0hrhon'ns
`
`4u State ltotrte j7
`Akw*;a.*rn, N<xv York tj055
`wwl.sunt -rt * t, t7r.w
`Phorre: 5r8-j5fi-::7r
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`In addition to financial barriers, our surrounding environment has been polluted in a way that is causing the
`Tribe's healthcare costs to sky rocket. For the past sixty years, our Territory has been polluted by hazardous
`polychlorinated biphenyls ("PCBs"), polycyclic aromatic hydrocarbons, aluminum, fluoride, cyanide, and
`other volatile organic compounds ("VOCs") from (i) the General Motors (Central Foundry Division)
`Superfund Site, (ii) the Alcoa West - Grasse River Superfund Site, and (iii) Alcoa East (formerly owned
`by the Reynolds Metals Company) - all of which are located directly upstream and upwind from where our
`community draws its drinking water and permanently resides. While the industries and associated jobs
`causing the pollution have come and gone, the pollutants remain and continue to contaminate our water,
`land, and air. This greatly compromises the health of our tribal members at devastatingly disproportionate
`rates.
`
`Despite years of SRMT engagement with the EPA, New York, and Congress, mitigation plans that have
`been put into place are drastically underfunded and insufficient. New research also demonstrates that the
`EPA's mitigation methods are further exposing our community to additional pollutants. The lack of
`adequate federal funding to completely rnitigate these Superfund Sites is polluting our entire Territory with
`hazardous PCBs and other VOCs, creating a cycle of pollutant-based health issues, and negatively
`impacting the traditional practices that are essential to the preservation of our culture,
`
`Preserved as a part of the 1796 Treaty with the Seven Nations of Canada to use the river "unhindered", otr
`Tribe once lived a traditional subsistence lifestyle, relying on many of the natural resources and wildlife
`along the St. Lawrence and Grasse Rivers. However, 60 years of toxic pollution have forced us to turn away
`from our subsistent lifestyles. In the 1990s, the New York State Department of Health issued a health
`advisory warning residents not to consume any fish from the Grasse River. Unfortunately, this advisory
`warning came decades after our tribal members had been exposed to these contaminants. This has plagued
`our community with a disproportionately high prevalence of diabetes, thyroid disorders, asthma, arlhritis,
`autoimmune disease, heart disease and cancers. Newly conducted research also suggests that PCBs may be
`transferred through breast milk and inhibit the ability of our young women to conceive. Thus, even if our
`children no longer consume wildlife from the St. Lawrence and Grasse Rivers, they consume the milk from
`their mother who has been exposed to decades of contaminants, passing on a toxic legacy to the next
`generation of tribal members.
`
`The fact that we are being attacked for diversifying our economy and obtaining a revenue source that could
`remedy the current environmental disaster that is polluting our community and endangering our well-being,
`while also offsetting healthcare costs is, at best, another sad example of colonial paternalism. For many of
`our tribal members, the backlash directed at the Tribe - and not other sovereigns involved in the very same
`business - cannot be reconciled with the government's repeated statements of support for tribal sovereignty
`and the advancement of true Indian self-determination.
`
`The Tribe is parlicularly frustrated because we have been working with Congress, EPA, arrd various
`Administrations for decades to address the government's failure to warn us of the pollution and to protect
`us from being poisoned. We will no longer sit back and wait for the government to figure this out nor
`will we excuse the government's inability to provide an important remedy that protects our health
`and well-being. Our tribal members need adequate healthcare services and we will do everything we can
`to provide them with those essential services.
`
`On top of this, as members of Congress criticize the Tribe for our actions, each of the individual states own
`hundreds, if not thousands, of patents. And to be clear, 20-25 percent of these patents were developed by
`private parties and subsequently transferred to state entities - the exact fact pattern here. The hypocrisy on
`top of the government's failure to uphold the federal trust responsibility, pass meaningful legislation,
`maintain important programs, and pay for environmental damages is leaving the Tribe in a perpetual
`standing of uncertainty regarding our ability to provide desperately needed services for our rnembers. True
`fulfillment of the federal trust responsibility to tribal governments should not force Indian Country
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`to bear the consequences of partisan disagreements about how to control drug prices and deliver
`affordable healthcare.
`
`Recommendations as the Committee Moves Forward
`
`As you move forward in your review of our ownership of this patent and the Inter Partes Review ("lPR")
`proceedings conducted by the Patent Trial and Appeal Board ("PTAB"), we ask that you keep the following
`considerations in mind:
`l.
`
`Maintain Parity for Tribal Governments with States and Public Universities.
`
`Tribal governments, like the SRMT, possess the same sovereign authority exercised by state governments
`and public universities to partner with companies to bring products to the market, while retaining title of
`intellectual property developed. As you begin your review of the transaction, we encourage you to look at
`the practices of your own states and the positive impacts of state and public university ownership of Orange
`Book-listed patents are having on your constituents.
`
`According to the U.S, Patent and Trademark Office ("USPTO"), in 2012, every state had at least one
`university, foundation, or other institution that owned a patent. In fact, ror-rghly 4,797 Orange Book-listed
`patents, were acquired by states and their public universities. This is roughly a 1.5 percent increase from
`1985, more than25 years ago, when U.S, colleges and Universities owned less than one percent of all
`patents. Despite this increase in patent ownership, state and public university patent acquisitions have not
`been questioned as to whether their sovereign immunity is at fault for rising drug prices and the declining
`U.S. patent system.
`
`According to USPTO, in2012 the four states represented by the Senators who objected to the deal owned
`over 7.000 patents combined. In Senator Hassan's state, Dartmouth College and the University of New
`Hampshire owned a total of 257 patents. with 27 acquired in 2012.
`
`In Senator Casey's state, the University of Pennsylvania, University of Pittsburgh, Penn State Research
`Foundation, Camegie Mellon University, Thomas Jefferson University, Ternple University, Drexel
`University, Lehigh University, Duquesne University, Philadelphia Healtlr and EdLrcation Corp.,
`Pennsylvania Research Corp., Penn State University, Drexel University College of Medicine, Alleglreny
`University of the Health Sciences, University of Scranton, Villanova University, Bryn Mawr College,
`University of the Sciences in Philadelphia, Drexel Institute of Technology, Philadelphia College of
`Osteopathic Medicine, Philadelphia College of Textiles and Science, Philadelphia University, University
`of Pittsburg Medical Center, Widener College, Franklin and Marshall College, Lehigh University and
`Northeast Benjamin Franklin, Technology Center of PA, Lock Haven University of Pennsylvania,
`Philadelphia College of Pharmacy and Science, St. Francis University, Slippery Rock University,
`University of the Arts, and Widener University owned a total of 3686 patents with 251 acquired in 2012.
`
`In Senator Brown's state, Ohio State University, Case Western Reserve University, University of Akron,
`University of Cincinnati, Ohio State University Research Foundation, University of Dayton, University of
`Toledo, Kent State University, Ohio University, Wright State University, Cleveland State University, the
`Medical College of Ohio, Bowling Green State University, Miami University, Northeastern Ohio
`Universities College of Medicine, Ohio University Edison Animal Biotechnology Institute, Ohio
`Agricultural Research and Development Center, Ohio Northern University, and Antioch College owned a
`total of 2267 patenls " w ith | 49 acquir ed in 20 12.
`
`In Senator Blumenthal's state, Yale University, the University of Connecticut, University Patents Inc.,
`University of Connecticut Health Center, University of Hartford, Fairfield University, University of
`Connecticut Research and Development Corp., University of Connecticut - Center for Science and
`
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`Technology Cnmmercialization, Connecticut College, and owned a total of 1066 patents. with 51 acquired
`in2012.
`
`Your own states, Iowa and California, have also been long-tirne Orange-book patent owners. ln lowa, the
`University of lowa, Iowa State University, Iowa State University Research Foundation lnc., University of
`Iowa Research Foundation, the University of Iowa Foundation, and Kirkwood Community College owned
`atotal of 1"515 patents. ryith 46 acquired in 2012'
`
`In California, UC Berkley, Stanford University, Stanford University Medical Center, California Institute of
`Technology, University of Southern California, Scripps Research Institute, Scripps Clinic and Research
`Foundation, Loma Linda University Medical Center, University of California Office of Technology
`Transfer, Alfred E. Mann Institute for Biomedical Engineering at the University of South California, Loma
`Linda University, San Diego State University, Research and Education Institute - UCLA Medical Center,
`Los Angeles Biomedical Research Institute at Harbor UCLA Medical Center, California Institute Research
`Foundaiion, California Polytechnic State University Foundation, California Polytechnic State University
`Corporation, Keck Graduate Institute, Cal State Fresno Foundation, Research arid Education Institute Inc.,
`AmLassador College, Cal State Fullerton Foundation, Harvey Mudd College, San Diego State University
`Research Foundation, San Jose State University Foundation, San Jose State University Foundation,
`University of the Pacific, Western University of Health Sciences, California State University, Humboldt
`State University Foundation, Loma Linda University Adventist Health Sciences Center, The University
`Foundation - California State University, USC Stevens Center for Innovation, Art Center College of
`Design, California Institute of Technology - Jet Propulsion Lab, Chapman College, Charles R' Drew
`University of Medicine and Science, Jesuit Community at Loyola University, Pepperdine University, San
`Diego State College Foundation, and USCA{orris Comprehensive Cancer Center.
`
`For more information on other states' rates of Orange Book-listed patents, please the attached documents
`(U.S. Patent and Trademark Office Data concerning U.S. Colleges and Universities Utility Paten Grants
`dalendar Years 1969-2012, our analysis of this data by state, and a list of companies who have transferred
`their patents to state universities in the same manner the Tribe has done).
`2.
`
`Protect a Revenue Stream that Directly Benefits Tribal Citizens and Augments Lack of
`Adequate Federal Funding and Limited Economic Development Opportunities
`
`The Tribe's partnership with Allergan opens a new revenue stream that will help offset budget shortfalls
`-healthcare,
`eldercare, education and language preservation services due to inadequate annual
`for housing,
`funding levels, sequestration, the inability to tax, and limited economic development opportunities due to
`its rural location. The Tribe will receive $13.75 million upon execution ofthe agreement and will be eligible
`to receive $15 million in annual royalties. The Tribe will use this revenue to address the following shortfalls:
`
`Housing; The Tribe faces a critical housing shortage, As its population expands, its territory has not.
`Despite nearly 40 years of litigation with respect to returning Mohawk tribal lands, some local communities
`still have not agreed to the settlement forcing the Tribe to purchase additional lands from willing sellers at
`a great cost. Additionally, the Tribe's housing program lost a quarter of a million dollars this year forcing
`a ieduction in the workforce by three employees and several key staff transitioned to part-time to maintain
`operations. Working under these constraints makes it difficult to provide much needed housing for our
`members.
`Heslthcare and Environment; The SRMT community is plagued with chronic illness and has
`disproportionately high rates ofdiabetes and cancer as a result ofthe environmental pollutants from three
`superfund sites located upstream and upwind from the territory. ln 2016, SRMT's total healthcare budget
`wis $ 1 8.2 million. Despite receiving health dollars from federal appropriations, and $ 1 million in Medicaid,
`the Tribe had to heavily subsidize the remaining budget shortfall with its already limited resources,
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`Sequestration and elimination of certain EPA programs have also hindered the Tribes' ability to mitigate
`the impacts of these environmental health hazards, fully remediate the Superfund sites, and adequately
`monitor air quality, which further adds costs to the already insufficient healthcare budget.
`
`Eldercare: Like the sunounding non-lndian communities, as the Akwesasne community ages, the need for
`greater eldercare continues to strain the Tribe's budget. A recent referendum highlighted the community's
`concern about the need of the Tribal Government to provide more resources and assistance to elders living
`on fixed incomes.
`Language Preservation: Like many indigenous languages, the Mohawk language is endangered and faces
`the risk ofextinction unless the Tribe continues to subsidize and support strong language programs, such
`as the full language immersion Akwesasne Freedom School and other intensive programs necessary to
`preserve and pass down the Mohawk language.
`3.
`
`Understand the Role the Tribe is Playing
`
`A major concern raised is that the Tribe is merely a shell cornpany, This could not be further from the truth.
`The Tribe has created an Office of Technology Research and Patents that will be an active
`participant in any proceedings to protect tribal ownership of all its intellectual property. As a sovereign
`government, the Tribe has a duty to its citizens to protect its investments and cannot responsibly rely on its
`partners to enforce its sovereign rights.
`
`Finally, in its role as a government, the Tribe has been seeking opportunities that allow it to gain more
`knowledge on business models and the regulatory framework that protects intellectual properfy -
`specifically keeping in mind how the Tribe can use this framework to protect its own traditional ecological
`knowledge and other innovations.
`
`4.
`
`It is Not in the Best Interest of its Tribal Members to Delay Access to Generic Drugs or to
`Raise Drug Prices
`
`Some commentators fear the patent agreement between Allergan and the Tribe will delay access to generic
`drugs for the American public, insulate pharmaceutical patents from review, and take advantage of
`consumers. These concerns reflect a misunderstanding ofthe federal statutes that govern tribal sovereignty
`and market entry ofgeneric drugs.
`
`It is the Tribe's job, as a sovereign government, to provide healthcare services to its community members
`and it is acutely aware of the cost of pharmaceutical drugs and the financial challenges faced by so many
`families. Currently, 10 percent of the Tribe's overall healthcare budget is dedicated to pharmacy costs. To
`suggest the Tribe would engage in price-gouging or hinder access to medicine is a complete opposition of
`the core values ofthe Tribe and its own financial interest. Furthennore, generic drugs have already saturated
`the market. Ln2016, nearly 90 percent of prescription drugs dispersed were generic drugs. In addition, new
`research is finding that the cost of generic drugs is rising, not due to state or public university involvement
`in the sector, but due to below cost pharmacy reimbursements, low maximum allowable cost prices,
`difficulty sourcing alternative medications to fit patients' budgets, medication non-adherence costs, and
`inaccurate price forecasts.
`
`5.
`
`Like Public Universities Who Own Patents, Tribal Governments Will Not Cause a Rush of
`Companies Moving their Patents to Tribes Nor will it Result in Patents Evading Review
`
`The accusation that deals between private pharmaceutical companies and tribal governments will cause a
`rush of companies moving their patents to tribal governments to evade pharmaceutical patents review is
`factually incorrect. First and foremost, in2012 states and public universities owned atotal of 75,353 patents
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`with 4,797 acquired that year. During this same year, roughly 70 percent of prescription drugs were generic
`drugs. Today, that percentage is even higher.
`
`Recognize the Current System is Not Working
`
`Secondly, ownership of Orange Book-listed patents by sovereign entities will not affect the ability of
`generic drug companies to mount a full and fair patent challenge in federal court. Through 1984 Hatch
`Waxman Act ("HWA") litigation, generic companies can bring their affirntative defenses and
`counterclaims that arise from the underlying dispute, unaffected by sovereign immunity. lt is incorrect to
`say that a sovereign patent owner could use its patents to sue for infringement, but then use its immunity to
`block counter-arguments that these patents are invalid.
`6.
`Additional accusations contend that the purpose of the IPR proceedings is to ensure generic drug
`companies have efficient access to patent review proceedings, to increase access to important medicines,
`and to keep drug prices low. In reality, IPR proceedings were established in the U.S. Patent and Trademark
`Office in2012 in response to concerns from the high-technology sector. IPR proceedings were intended to
`be a cheaper and quicker alternative to federal court litigation over frivolous patent claims. Today, roughly
`80 percent of patents are reviewed through IPR proceedings. While it has proven efficient for tech patents,
`it has become controversial for pharrnaceutical patents, which were never discussed when the IPR system
`was created.
`
`For Orange Book-listed patent owners, IPR proceedings allow repetitive attacks on patents, lack finality
`and due process, and use legal standards that are systematically unfavorable to patentees. IPR is often used
`together with district court litigation for multi-pronged attacks on the same patents in different forums. For
`patent challengers IPR can be an effective form of answer-shopping. For patentees, they are a form of
`double jeopardy.
`
`For decades prior to the Leahy-Smith America Invents Act ("AIA"), HWA ensured that all duly issued
`U.S, patents protected by the presumption of validity, a clear and convincing evidence standard and the
`right to a trial before a jury overseen by an Article III judge on the issue of validity. As a result of the IPR
`abuses, where a federal district court typically invalidates about 28 percent ofpatents, IPRs have invalidated
`76 percent. Because there is rro limit on the number of IPRs that can be filed against a patent, challengers
`can keep filing IPRs until they win, Since passage of the AIA, the U.S. has fallen from lst to 10th in the
`ranking of the strength of its intellectual property system.
`
`Finally, the Supreme Court is set to review the constitutionality of the America Invents Act (AIA) in Oil
`States Energt Services, LLC v. Greene's Energt Group, LLC,includingthe constitutionality of the IPR
`proceedings. Thus at the very least, consideration of important questions surrounding the Hatch Waxman
`Act, the America Invents Act and the intersection of sovereign immunity should benefit from the Supreme
`Court's guidance on this issue.
`
`We thank you for your leadership on this matter and appreciate your consideration of our request. We hope
`that we can continue working, as governmental partners, to seek important opporlunities that allow us to
`provide our constituents, with the resources and services they need.
`
`Sk6n:nen I In peace,
`
`THE SAINT REGIS MOHAWK TRIBAL COUNCIL
`
`Thompsan
`Tribal Glrief
`
`I
`
`,j
`,t,,r',', i,tt1_I
`; Be$erly'Coak
`Tribal Chief
`
`6
`
`Hich*et Conlrers
`Tribatr Chief
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`ALL U.S UNIVERSITIES - U S. Unilcsi!.Utrlitt' Pabn6. CY 1969 - 2012. By Orgaiational Nme md issue-da@
`
`Home > PTMT Listing of Vicwahle Reports > tlniversity Report Table of Contents > tiniversitv Listing > This Page
`
`U.S. PATENT AND TRADEMARK OFFICE
`Patent Technology Monitoring Team (PTMT)
`
`U.S. COLLEGES AND UNIVERSITIES.
`UTILITY PATENT GRANTS,
`CALENDAR YEARS 19 69 -2012
`
`- lhis reporl was ctealed with suPport from the National Science Foundation -
`
`BREAKOUT BY TINTVERSITY ASSIGNEE -
`PATENTS DISTRIBUTED BY CALENDAR YEAR OF GRANT
`
`NUMBER OF UTILITY PATENTS ASSIGNED ANNUALLY
`TO U.S. COLLEGES AND UNTVERSITIES
`
`Renk Ordercd Listing ofAssignec N.mcs Rcceiving I or More Utility Patenb During th€ Period
`
`- Exphn{tion ofDrte -
`
`This Trblc Providd . D.tril Br€akout with Separatc Counts
`for Each Idcntified Assigne Namc Associated with:
`
`ALL U.S. UNT!'ERSITIES
`( coilnr ol palenl grdls, 6 distribrted b! calenda yeur of gnnt )
`( pdtent ownarship is delemined by fhefircl-@ed NsiSnee listed on a pakil )
`
`Amml patenl countsfor the universi4'.
`Counts of grarxed patents oe distributed by the yeu of patent granl.
`be associated with a
`names
`
`UNIVERSITY OF
`CALIFORNIA, THE REGENTS
`OF
`
`CA
`
`831
`
`79
`
`t12
`
`154
`
`203
`
`255
`
`264
`
`386
`
`434
`
`432
`
`401
`
`430
`
`388
`
`410
`
`J)J
`
`237
`
`251
`
`349
`
`323
`
`357
`
`7488
`
`99
`
`104
`
`138
`
`142
`
`t13
`
`125
`
`135
`
`127
`
`132
`
`136
`
`139
`
`l4l
`
`134
`
`134
`
`174
`
`160
`
`216
`
`40t7
`
`MASSACHUSETTS INSTITUTE
`OF TECHNOLOGY
`
`STANFORD TINIVERSITY
`
`MA
`
`CA
`
`1210
`
`125
`
`472
`
`42
`
`32
`
`lt2
`
`50
`
`29
`
`ll9
`
`55
`
`102
`
`64
`
`40
`
`79
`
`93
`
`62
`
`54
`
`37
`
`83
`
`103
`
`84
`
`102
`
`85
`
`75
`
`90
`
`98
`
`85
`
`120
`
`ll0
`
`155
`
`153
`
`182
`
`2403
`
`99
`
`103
`
`124
`
`I l0
`
`139
`
`135
`
`101
`
`115
`
`116
`
`96
`
`93
`
`134
`
`lll
`
`136
`
`2365
`
`CALIFORNIA INSTITLTE OF
`TECHNOLOGY
`
`I.JNIVERSITY OF TEXAS
`
`CA
`
`TX
`
`WI
`
`446
`
`308
`
`381
`
`86
`
`73
`
`39
`
`46
`
`97
`
`48
`
`24
`
`87
`
`64
`
`89
`
`44
`
`8l
`
`62
`
`96
`
`83
`
`9l
`
`86
`
`89
`
`64
`
`89
`
`72
`
`9t
`
`80
`
`94
`
`84
`
`99
`
`64
`
`89
`
`77
`
`t07
`
`l0l
`
`90
`
`9l
`
`79
`
`90
`
`98
`
`122
`
`t25
`
`l4l
`
`2321
`
`ll5
`
`r36
`
`144
`
`155
`
`2133
`
`WISCONSINALUMNI
`RESEARCH FOUNDATION
`
`JOHNS HOPKINS
`UMVERSITY
`
`CORNELL RESEARCH
`
`Mt)
`
`NY
`
`53
`
`239
`
`20
`
`33
`
`23
`
`i6
`
`27
`
`79
`
`97
`
`72
`
`80
`
`282
`
`4l
`
`35
`
`39
`
`36
`
`52
`
`50
`
`64
`
`64
`
`49
`
`6r
`
`8r
`
`35
`
`70
`
`94
`
`71
`
`91
`
`62
`
`66
`
`56
`
`7l
`
`70
`
`79
`
`I 556
`
`59
`
`40
`
`41
`
`61
`
`54
`
`50
`
`52
`
`74
`
`51
`
`33
`
`1323
`
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`
`ALL 2109
`MYLAN PHARMACEUTICALS V. ALLEGAN
`IPR2016-01127, -01128, -01129, -01130, -01131 & -01132
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`ALL U S TNIVERSITIES
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`FOLTNDATION INC,
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`https:/ sv.usp6.gov^veb/ofnces/aclido/@rplhlTunr! /org-gr/all-uni\-ag.hmu0/5,201?
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`I l:20:23 ANI I
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`ALL 2109
`MYLAN PHARMACEUTICALS V. ALLEGAN
`IPR2016-01127, -01128, -01129, -01130, -01131 & -01132
`
`
`
`ALL U.S UNIVERSITIES - U S. Univc6in Uiliq Pden6. CY 1969 - 2012. By Orgeiational Nmc hd Issuc-dat
`PENN STATE RESEARCH
`FOUNDATION. INC.
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`CARNEGIE-MELLON
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`UNIVERSITY OF NEBRASKA,
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`UNIVERSITY OF ARKANSAS
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`VANDERBILT TJNIVERSITY
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`BOSTON UNIVERSITY
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`UNIVERSITY OF
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