UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`WOCKHARDT BIO AG, CASE IPR2016-01582
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` PATENT 8,822,438
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` PETITIONER,
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`vs.
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`JANSSEN ONCOLOGY, INC.,
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` PATENT OWNER.
`
`___________________________
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`MYLAN PHARMACEUTICALS INC.,
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` PETITIONERS, CASE IPR2016-01332
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` PATENT 8,822,438 B2
`
`vs.
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`JANSSEN ONCOLOGY, INC.,
`
` PATENT OWNER
`
`____________________________
`
`
`
`
`
` FRIDAY, APRIL 28, 2017
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` - - -
`
` VIDEOTAPED DEPOSITION of IAN McKEAGUE, Ph.D.,
`
`taken at the offices of Perkins Coie, 700 13th Street
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`NW, Suite 600, Washington, D.C., beginning at
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`9:02 a.m., before Nancy J. Martin, a Registered Merit
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`Reporter, Notary in and for the District of Columbia.
`
`VERITEXT NATIONAL COURT REPORTING COMPANY
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`JANSSEN EXHIBIT 2186
`Mylan v. Janssen IPR2016-01332
`
`

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` EXHIBITS PREVIOUSLY MARKED
`NUMBER Description Page
`Exhibit Selective Inhibition of CYP17 with 123
`2015 Abiraterone Acetate is Highly Active
` in the Treatment of
` Castration-Resistant Prostate
` Cancer, 9 pages
`Exhibit Phase II Study of Abiraterone 124
`2017 Acetate in Chemotherapy-Naive
` Metastatic Castration-Resistant
` Prostate Cancer Displaying Bone
` Flare Discordant with Serologic
` Response, 9 pages
`
`Exhibit Declaration of Matthew B. Rettig, 92
`2038 M.D.,in Support of Janssen Oncology,
` Inc.'s, Patent Owner Response,
` 108 pages
`
`A P P E A R A N C E S :
`
` PERKINS COIE
` BY: ROBERT D. SWANSON, ESQ.
` MARIA STUBBINGS, ATTORNEY AT LAW
` 700 13th Street NW
` Suite 600
` Washington, D.C. 20005
` (202) 654-1729
` rswanson@perkinscoie.com
` Representing Mylan
`
` SIDLEY AUSTIN LLP
` BY: TODD L. KRAUSE, ESQ.
` 787 Seventh Street
` New York, New York 10019
` (212) 839-5696
` tkrause@sidley.com
` Representing Janssen Oncology Inc.
`
` WINSTON & STRAWN
` BY: SHARON LIN, ATTORNEY AT LAW
` 1700 K Street NW
` Washington, D.C. 20006
` (202) 282-5756
` slin@winston.com
` Representing Actavis Laboratories FL,
` Inc., Amneal Pharmaceuticals LLD, Amneal
` Pharmaceuticals of New York, LLC,
` Dr. Reddy's Laboratories, Inc.,
` Dr. Reddy's Laboratories, Ltd.,
` Sun Pharmaceuticals Industries, Ltd.,
` Sun Pharmaceuticals Industries, Inc.,
` Teva Pharmaceuticals USA, Inc.,
` West-Ward Pharmaceutical Corp.,
` and Hikma Pharmaceuticals, LLC.
`
`ALSO PRESENT:
` MICHAEL GAY, LEGAL VIDEOGRAPHER
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`VERITEXT NATIONAL COURT REPORTING COMPANY
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` PAGE
`TESTIMONY OF IAN McKEAGUE, PH.D.
`BY MR. KRAUSE 6
`BY MR. SWANSON 162
`BY MR. KRAUSE 171
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` E X H I B I T S
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`NUMBER DESCRIPTION PAGE
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`Exhibit Reply Declaration of Ian McKeague, 162
`1146 Ph.D., in Support of Petition for
` Inter Partes Review of U.S. Patent
` No. 8,822,438, 55 pages
`Exhibit Journal of Clinical Oncology, March 140
`2016 20, 2010, 8 pages
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`Exhibit The (mis)use of Overlap of 54
`2183 Confidence Intervals to Assess
` Effect Modification, 2 pages
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`Exhibit A Brief Note on Overlapping 54
`2184 Confidence Intervals, 1 page
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` EXHIBITS PREVIOUSLY MARKED
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`NUMBER Description Page
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`Exhibit Reply Declaration of Ian McKeague, 7
`1091 Ph.D., in Support of Petition for
` Inter Partes Review of U.S. Patent
` No. 8, 822,438, 55 pages
`Exhibit Significant and Sustained Antitumor 105
`1096 Activity in Post-Docetaxel,
` Castration-Resistant Prostate Cancer
` with the CYP17 Inhibitor Abiraterone
` Acetate, 7 pages
`Exhibit Reply Declaration of Ian McKeague, 7
`1106 Ph.D., 55 pages
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` WASHINGTON, D.C., FRIDAY, APRIL 28, 2017; 9:02 A.M.
` - - -
` THE VIDEOGRAPHER: We are on the record.
`The time now is 9:02 a.m. This marks the beginning of
`Disk No. 1 for the videotaped deposition testimony of
`Ian McKeague in the matter of Mylan Pharmaceuticals,
`Inc. et al. v. Janssen Oncology, Inc. This case is
`pending in the United States Patent and Trademark
`Office, Case No. IPR:2016-01332. Today's date is
`April 28, 2017. This deposition is being conducted at
`700 13th Street, Northwest, Washington, D.C.
` Will all attorneys present, please identify
`themselves and who they represent.
` MR. KRAUSE: This is Todd Krause of Sidley
`Austin, and I represent Janssen Oncology, Inc. And
`I'll just note for the record that this deposition, as
`well as being held in the Mylan action today, is also
`being held with respect to the Wockhardt action, which
`is Wockhardt Bio AGV, Janssen Oncology, Inc. Case
`IPR No. 2016-01582.
` MR. SWANSON: Robert Swanson for Perkins Coie
`on behalf of Mylan.
` MS. STUBBINGS: Maria Stubbings also from
`Perkins Coie on behalf of Mylan.
` MS. LIN: Sharon Lin from Winston & Strawn on
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`behalf of Actavis, Ameal, DRL, Sun, Teva, and
`Westward.
` THE VIDEOGRAPHER: My name is Michael Gay.
`I'm with Galkow Technologies. Our court reporter
`today is Nancy Martin with Veritext and will now swear
`in our witness.
`
` IAN RAY MCKEAGUE, PH.D.,
` having been first duly sworn/affirmed,
` was examined and testified as follows:
`
` THE VIDEOGRAPHER: You may proceed.
`
` EXAMINATION
`BY MR. KRAUSE:
` Q. Good morning, Dr. McKeague. Can you please
`state your name and home address for the record.
` A. Ian Ray McKeague. My home address is
`455 Central Park West, Apartment 8-D, New York,
`New York, 10025.
` Q. There are a few points that I'd like to
`review before we get started.
` If I ask a question and it's not clear or you
`don't hear me, please ask me. Please let me know so I
`can ask the question again. If you answer, I'll
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` A. I have those.
` Q. And Mylan Exhibit 1091 was submitted in IPR
`No. 2016-01332; is that correct?
` A. That's correct.
` Q. And Wockhardt Exhibit 1106 was submitted in
`IPR No. 2016-01582. Is that also correct?
` A. That's correct.
` Q. Do you recognize this document -- these --
` A. Yes.
` Q. -- documents?
` A. Yes.
` Q. And what are they?
` A. These are my reply declarations in each of
`these cases.
` Q. And is that your signature on the last page
`of both declarations?
` A. Very last page. Do you mean right before my
`CV?
` Q. Yes.
` A. That's correct, yes.
` Q. Okay. And that's true with respect to the
`declaration?
` A. And -- yes. Yes.
` Q. Do the declarations accurately reflect the
`opinions that you've reached in the Mylan and
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`understand you heard and -- understood and heard my
`question. Is that fair?
` A. Yes.
` Q. And we have a court reporter taking down your
`answers to my questions. So please try to give verbal
`answers to my questions. Is that also understood?
` A. Yes.
` Q. We'll try to take breaks about every hour or
`so, but please let me know if you need a break. I'll
`finish whatever question I'm on, and we'll take a
`break. Okay?
` A. Okay.
` Q. Is there any reason you cannot give complete
`and accurate testimony here today?
` A. No.
` (Previously marked Exhibit 1091 was handed
` to the witness.)
` MR. KRAUSE: I've handed you two documents.
`One is marked Mylan Exhibit 1091, and the other is
`marked Wockhardt Exhibit 1106 respectively.
` (Previously marked Exhibit 1106 was handed
` to the witness.)
` THE WITNESS: Yes.
`BY MR. KRAUSE:
` Q. Do you have those?
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`Wockhardt cases?
` A. They do.
` Q. And are there any errors in the declarations
`that you're aware of?
` A. No, not that I'm aware of. There may be some
`minor verbal issues but no errors.
` Q. Is it fair to say that the declarations are
`substantively identical but for the definitions of a
`person of ordinary skill in the art that you provided
`in each case?
` A. Could you restate that question.
` Q. Sure.
` Is it fair to say that the declarations are
`substantively identical but for the definitions of a
`person of ordinary skill in the art that you've
`provided in each case?
` A. That's correct.
` Q. But your opinions are the same in the Mylan
`and Wockhardt matters regardless of any differences
`that may exist in the definitions of a person of
`ordinary skill in the art in those two cases; is that
`correct?
` A. That's correct.
` Q. So for purposes of today's deposition, we'll
`treat Mylan's and Wockhardt's person of ordinary skill
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`3 (Pages 6 to 9)
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`in the art as the same. Is that all right with you?
` MR. SWANSON: Object to form.
` You can answer.
` THE WITNESS: Yeah. Well, that's fine.
`That's fine with me.
`BY MR. KRAUSE:
` Q. And when I refer to "a person of ordinary
`skill in the art," or a POSA, P-O-S-A, I'm referring
`to a person within the definitions that you've
`provided in both your Mylan and Wockhardt
`declarations. Is that understood?
` A. That's understood.
` Q. Moreover, when we talk about that person's
`knowledge, it's referring to that person's knowledge
`as of August 2006. Is that also understood?
` A. Can we refer to the definitions?
` Q. Certainly. Feel free to look at whatever
`you'd like to look at.
` A. So here we're talking about the Mylan one.
`So this is -- as you see, the is the definition of
`person of ordinary art in the skill is offered by
`Dr. Garnick.
` Q. Yes. Yes.
` A. That's the source. You asked me about the
`source.
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` Q. So when we're talking --
` A. So -- so this refers to -- as I understand
`the definition as of the priority date, I expect.
` Q. Right. So when I refer to a person of
`ordinary skill's knowledge, I'm talking about that
`person's knowledge as of August 2006. Do you
`understand that?
` A. Okay.
` Q. Okay. Your declarations in the Mylan and
`Wockhardt IPRs refer to many of the same documents; is
`that correct?
` A. Yes.
` Q. But some of the documents bear different
`Exhibit numbers in the two cases; is that correct?
` A. Should we compare the --
` Q. Feel free to, sure.
` A. So the documents consulted in the last
`pages --
` Q. Yes, Doctor.
` A. -- and you want to know whether the Exhibit
`numbers are different? Indeed, they are.
` Q. Right. My question was for some exhibits the
`Exhibit numbers differ, but they're the same document;
`is that correct?
` A. Yes, I believe so. I believe that's the same
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` Q. No. I'm sorry. Maybe I didn't ask my
`question very well.
` I just wanted to make clear what date we're
`talking about with respect to the person of ordinary
`skill's knowledge.
` A. When Dr. Garnick gave that definition?
` Q. No. The date as of which one refers to prior
`art, information that was known to a person of skill
`in the area.
` A. When one does? You mean in terms of a legal
`question?
` Q. The -- in this case there are certain dates
`that are relevant.
` A. Right.
` Q. We're talking about the person of ordinary
`skill in the art.
` A. Yes.
` Q. We've talked about that.
` A. You mean the priority date?
` Q. Yes, Doctor.
` A. The 2006 priority date.
` Q. Yes.
` A. That's what you mean?
` Q. Yes.
` A. Yes.
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`set of documents in each one. Yeah. As you say, even
`though the Exhibit numbers are slightly different.
` Q. Yes.
` Okay. By agreement of the parties during
`today's deposition, I'll be using the declaration and
`exhibits from the Mylan IPR in an effort to reduce
`confusion. Is that all right?
` A. Yes. That's a good idea.
` Q. Okay. So, for example, when I refer to a
`paragraph number, I'm referring to the paragraph
`number in your Mylan declaration.
` A. Yes.
` Q. Now, Doctor, your understanding of prostate
`cancer and its treatment comes entirely from the
`references that are cited in your declarations; is
`that correct?
` MR. SWANSON: Object to form.
` THE WITNESS: I knew about prostate cancer
`long before my work on this case. No, it's not true
`to say my knowledge comes entirely from that.
`BY MR. KRAUSE:
` Q. Okay. So what other knowledge did you have
`with respect to prostate cancer before you started
`working on this case?
` A. Well, I mean I've had PSA tests myself. Of
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`course, I'm an informed reader of the literature. I
`think it's a vague question. But -- yeah.
` Q. Okay. Well, if you could turn to Page 9 of
`your Mylan declaration.
` A. Uh-huh.
` Q. In Footnote 2 you state, "My understanding of
`prostate cancer and its treatment comes from the
`references cited herein."
` A. Yes.
` Q. What area --
` A. What are you talking about? Which paragraph?
` Q. Footnote No. 2 on Page 9.
` A. Uh-huh. Uh-huh.
` Q. Do you see?
` A. Uh-huh.
` Q. It's the second sentence in Footnote No. 2.
` A. Yes. Uh-huh. What about it?
` Q. So what are you referring to there?
` A. So it's good to have some background, and
`citations are common and useful to a reader of this
`document.
` Q. So but for the references that you cited in
`your declaration --
` A. Uh-huh.
` Q. -- what is your understanding of the state of
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`2006?
` MR. SWANSON: Object to form. Calls for a
`legal conclusion.
` THE WITNESS: Yes. I'm not going to answer
`that because I don't have an understanding of the
`field as an expert in that field. I have an
`understanding as a layman essentially.
`BY MR. KRAUSE:
` Q. And what is your understanding as a layman?
` MR. SWANSON: Object to form. Vague.
` THE WITNESS: That's a very broad and vague
`question, and I don't think it's proper for me to
`speculate on the state of the art in a field in which
`I'm not an expert.
` MR. KRAUSE: Okay. Counsel, during the
`depositions of Dr. Bantle on Monday, a number of
`inappropriate objections were made. It seems like,
`despite my admonition during that deposition, you're
`continuing to make inappropriate objections. I refer
`you to the guidelines, particularly in the right
`column of the federal register that I've just handed
`you.
` MR. SWANSON: What in particular do you find
`objectionable?
` MR. KRAUSE: You made an objection, vague.
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`the art with respect to the treatment of metastatic
`castration-resistant prostate cancer as of August
`2006?
` MR. SWANSON: Object to form.
` THE WITNESS: I think that's well outside
`my -- my expertise is not as an expert in prostate
`cancer if that's what you're asking.
`BY MR. KRAUSE:
` Q. So would it be fair to say that your
`knowledge, with respect to the treatment of metastatic
`castration-resistant prostate cancer as of August
`2006, comes from the documents cited in your
`declaration?
` MR. SWANSON: Object to form.
` THE WITNESS: I have a broad understanding of
`what prostate cancer involves and the treatment of
`prostate cancer, but I don't consider myself an
`expert, no, in prostate cancer. My role in this is to
`analyze the nature of Dr. Rettig's declaration in this
`case, a reply to Dr. Rettig, not concerning --
`concerning biostatistical issues.
`BY MR. KRAUSE:
` Q. So what is your understanding of the state of
`the art with respect to the treatment of metastatic
`castration-resistant prostate cancer as of August
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`It states in the guidelines, "Examples of objections
`that would not be proper are, among others, objection,
`vague."
` MR. SWANSON: Okay. So as long as I don't
`make an objection, vague, I'm allowed to make other
`objections in addition to just saying the word "form"
`if there are objections based on your understanding?
` MR. KRAUSE: Counsel, you can read the
`guidelines if you're not familiar with them. I will
`raise issues as they come up.
` MR. SWANSON: I'm familiar with the
`guidelines, and if you have an objection to the way
`I'm objecting, I would appreciate it if you let me
`know.
` MR. KRAUSE: I just stated you made
`objection, vague, and clearly, that's outside the
`scope that's appropriate.
` MR. SWANSON: Okay. We'll move on.
`BY MR. KRAUSE:
` Q. So in this Footnote 2 you refer to
`Example 1092 as a reference that informed your
`knowledge with respect to treatment of prostate cancer
`and prostate cancer; is that correct?
` A. Yes.
` Q. Is that the primary reference that you relied
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`5 (Pages 14 to 17)
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`

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`on in bringing your understanding?
` A. As I just said, I have a broad general
`layman's knowledge of prostate cancer.
` Q. And the sources of that knowledge are, I
`believe you referred to your own treatment or --
` A. I had an elevated -- maybe I shouldn't talk
`about my own personal health.
` Q. I'm not asking about your personal health.
`I'm asking about your scope.
` A. It sounds as though you want to know where my
`knowledge comes from, and over a lifetime, that's a
`rather difficult question to answer, isn't it? So...
` Q. Have you had any formal training with respect
`to prostate cancer?
` A. No. I'm not a medical doctor. I am a
`biostatistician. But, of course, in biostatistics we
`deal with medical data from all over the medical
`field, not exclusively, of course, in any one field.
`So I'm broadly familiar with data and studies across
`the medical fields.
` Q. And you're not a-urologist, oncologist, or
`endocrinologist?
` A. I am none of those things. I'm a
`biostatistician.
` Q. And you have no specialized training in
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`implications as to whether Dr. Rettig did establish
`unexpected results.
` Q. But the foundation of your opinions is from a
`statistical perspective rather than a clinical
`perspective; is that correct?
` MR. SWANSON: Object to form.
` THE WITNESS: The -- I'm using my knowledge
`as a biostatistician to assess, to analyze
`Dr. Rettig's opinions.
`BY MR. KRAUSE:
` Q. And can you describe that for me?
` MR. SWANSON: Object to form.
` THE WITNESS: Describe in my declaration?
`BY MR. KRAUSE:
` Q. Well, I'm trying to get an understanding.
`I've asked a couple times whether the opinions that
`you're providing in the declaration are being provided
`from a statistical perspective, and I think you've
`parsed a couple times that you're talking about it
`with respect to your knowledge as a biostatistician.
` I'm just trying to understand is there
`something in addition to the --
` A. Well --
` Q. Excuse me.
` -- the application of statistical principles
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`Page 21
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`Page 19
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`urology, oncology, endocrinology, biochemistry, or
`pharmaceutical sciences; is that correct?
` A. No, I have not had formal training in any of
`those fields.
` Q. So as you said, it's fair to say that your
`area of expertise is statistics; is that correct?
` A. Biostatistics.
` Q. Biostatistics.
` A. And mathematics.
` Q. And your declarations provide opinions
`regarding unexpected results from a statistical
`perspective. Is that fair to say?
` A. Could you rephrase that.
` Q. Sure. Your declarations provide opinions
`regarding unexpected results from a statistical
`perspective. Is that fair to say?
` MR. SWANSON: Object to form.
` THE WITNESS: I understand that my
`declaration is -- involves an analysis of whether
`Dr. Rettig has established -- has reached the level of
`proof of having unexpected results.
`BY MR. KRAUSE:
` Q. And the analysis that you performed is purely
`a statistical analysis; is that correct?
` A. I am -- well, I think the conclusions have
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`that you're bringing to bear in the opinions you're
`providing in your declaration.
` A. Well, I do --
` MR. SWANSON: Object to form.
` Please give me a moment to object.
` THE WITNESS: I do rely on the opinion
`that -- in other words, the legal construction here
`relative to unexpected results. I understand that
`that is highly relevant from a legal point of view.
`So I am, of course, predicating my analysis on an
`understanding that Dr. Rettig is trying to prove
`unexpected results, and I understand that has an
`implication to the patent.
` So to say my report -- my deposition --
`sorry, my report -- what do you call it, the
`declaration has no implications towards unexpected
`results, and this is solely based on biostatistical
`analysis is not correct. There is the extra, the
`implication that -- indeed, that my conclusions refer
`to Dr. Rettig's claim of unexpected results.
` MR. KRAUSE: Let me try to ask the question
`differently.
` Q. Are your opinions informed by your view of
`what would be expected or unexpected in the fields of
`urology, oncology, or endocrinology as of August 2006?
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`6 (Pages 18 to 21)
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`

`

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` MR. SWANSON: Object to form.
`Mischaracterizes.
` THE WITNESS: Could you rephrase that
`question. You just asked a question.
`BY MR. KRAUSE:
` Q. Would you like to read it back, or is there
`something you don't understand?
` A. No, I didn't understand the question.
` Q. What don't you understand about it?
` A. Well, could you read -- well, first of all,
`if you could read it back, and then I can tell you.
` MR. KRAUSE: Sure.
` Can you read the question back, please.
` (Record read.)
` MR. SWANSON: Same objections.
` THE WITNESS: That sounds like a very vague
`question to me, and I can't get my head around it, I'm
`afraid. For one thing, as I said, I'm not an expert
`in the fields that you named there. So, of course,
`I'm relying on -- what I was asked to do was to assess
`unexpected results. And I know what Dr. Rettig is
`claiming. So Dr. Rettig is obviously an expert in
`those fields you just mentioned.
` I am analyzing his conclusions is what I'm
`doing.
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`ordinary skill in the art would believe about, for
`example, the efficacy of prednisone for the treatment
`of metastatic castration-resistant prostate cancer?
` MR. SWANSON: Object to form.
` THE WITNESS: I don't believe my definition
`includes any particular statement unless you point
`that out. And it would be pure speculation on my
`part.
`BY MR. KRAUSE:
` Q. So you don't know. Is that fair to say?
` A. Well, what I know is --
` MR. SWANSON: Object to form.
` THE WITNESS: I understand that there is a --
`the definition of a person of ordinary skill in the
`art. And I understand that definition.
`BY MR. KRAUSE:
` Q. Okay. Is it fair to say that you do not fall
`within the definition of a person of ordinary skill in
`the art as provided by Mylan or Wockhardt?
` A. Well, I am not a medical doctor, and that --
`so you can -- you can find various exceptions to my
`record as a biostatistician, in this definition
`patently, but I'm not a person of ordinary skill in
`the art of -- okay. Do you want me to read it to you?
` Q. No. I'm not asking you to read it to me.
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`Page 25
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`BY MR. KRAUSE:
` Q. And the analysis that you're performing is a
`statistical analysis. Is that fair to say?
` MR. SWANSON: Object to form.
`Mischaracterizes.
` THE WITNESS: Yes. I think it's broader than
`that as I think it has implications -- as I say, it
`has broader implications. It has legal implications
`as to Dr. Rettig's claim of unexpected results, and I
`understand that has implications in the patent.
`BY MR. KRAUSE:
` Q. So do you know what a person of ordinary
`skill in the art would have expected with respect to
`the use of prednisone, for example, in the treatment
`of metastatic castration-resistant prostate cancer?
` MR. SWANSON: Object to form.
` THE WITNESS: Do you mean -- the definition
`of a person of ordinary skill in the art is in my
`deposition -- in my declaration.
`BY MR. KRAUSE:
` Q. I understand that.
` A. Yes.
` Q. I wasn't asking for the definition of a
`person of ordinary skill in the art.
` My question was do you know what a person of
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` A. It says --
` Q. Doctor, I'm just asking if you fall within
`the scope of the definition --
` A. A person --
` Q. Excuse me. Let me finish my question. If
`you fall within the scope of the definition of a
`person of ordinary skill in the art as defined by
`Mylan or Wockhardt?
` A. Let's check. So "A person of ordinary skill
`in the art at the time of the filing of this patent is
`someone who is a physician specializing in urology" --
`that's not me -- "endocrinology or oncology" -- not
`me -- "or holds a Ph.D. in pharmacology, biochemistry
`or a related discipline." My Ph.D. is in
`biostatistics, none of those related disciplines.
` "A related discipline may include, for
`example, pharmaceutical" science -- "sciences." So
`biostatistics is not in the pharmaceutical sciences.
`Do you want me to go on? There is additional
`experience required, so on. So I do not fall into
`that definition.
` Q. Okay. And is the same true with respect to
`the Wockhardt definition?
` A. Yes, I believe that's essentially the same.
` Q. Is it fair to say that your declarations do
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`7 (Pages 22 to 25)
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`

`

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`not provide opinions based on the expectations of
`those in the field from the perspective of one with
`training or experience in the fields of urology,
`oncology, endocrinology, biochemistry, or
`pharmaceutical sciences?
` MR. SWANSON: Object to form.
` THE WITNESS: I think you're asking me to say
`what my declaration says? Is that what you're asking
`me?
` MR. KRAUSE: No, Doctor. I think my question
`is a little simpler than that.
` Can you read it back, please.
` (Record read.)
` MR. SWANSON: Same objections.
` THE WITNESS: So I think you're asking
`whether my opinion has relevance to Dr. Rettig's claim
`of whether these results are unexpected. I believe
`that's what you're asking.
` MR. KRAUSE: N