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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`KOIOS PHARMACEUTICALS LLC
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`Petitioner
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`v.
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`MEDAC GESELLSCHAFT FUER KLINISCHE SPEZIALPRÄPARATE MBH
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`Patent Owner
`____________
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`Patent No. 8,664,231
`Title: Concentrated Methotrexate Solutions
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`Declaration of Kayvan B. Noroozi
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`Koios Exhibit 1035
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`IPR2016-01370
`U.S. Patent No. 8,664,231
`I, Kayvan B. Noroozi, declare the following:
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`Noroozi Declaration
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`1.
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`Koios Pharmaceuticals LLC (“Koios”) is a generic
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`pharmaceutical company launched in 2015. Koios is a Delaware limited
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`liability company. It is neither a hedge fund, litigation finance fund, nor an
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`investment vehicle. Koios’s mission is to increase Americans’ access to
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`affordable pharmaceuticals by promoting generic competition. To that end,
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`Koios challenges pharmaceutical patents that claim public knowledge for
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`private profit.
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`2.
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`I am the sole member of Koios and its President and CEO. No
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`person other than myself, and no entity other than Koios, has authority to
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`direct or control any decisions or activities relating to Koios, this Petition, or
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`proceedings related to this Petition. All of the costs associated with the
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`Petition are expected to be borne by Koios. Although Koios has entered into
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`a partnership with a pharmaceutical company for the development and
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`commercialization of a generic equivalent to Rasuvo, this Petition was not
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`brought at the behest of any person or entity other than Koios, and is entirely
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`under Koios’s control. Moreover, Koios is not in privity with, and has no
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`relation to, either Frontier or Antares.
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`3.
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`I declare that all statements made herein of my knowledge are
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`true and that all statements made on information and belief are believed to
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`I P R 2 0 1 6 - 0 1 3 7 0
`U.S. Patent No. 8,664,231
`be true, and that these statements were made with knowledge that willful
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`N o r o o z i
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`D e c l a r a t i o n
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`false statements and the like are made punishable by fine or imprisonment,
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`or both, under Section 1001 of Title 18 of the United States Code.
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`Dated:
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`2