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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`WOCKHARDT BIO AG
`Petitioner
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`v.
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`JANSSEN ONCOLOGY, INC.
`Patent Owner
`
`_____________________
`
`Case IPR2016-01582
`U.S. Patent No. 8,822,438
`_____________________
`
`DECLARATION OF GOPAL VENKATESAN
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`WCK1081
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`Case IPR2016-01582
`U.S. Patent No. 8,822,438
`I, Gopal Venkatesan, do hereby declare as follows:
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`
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`1.
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`I am over the age of 18 and otherwise competent to make this
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`declaration. This declaration is based on my knowledge and belief as Vice
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`President – Business Development at Wockhardt Bio AG (“Wockhardt”).
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`2.
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`I would, and could, testify competently to what is contained in this
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`declaration if called upon to do so. I understand that this declaration is being
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`submitted in connection with the above captioned proceeding.
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`3. Wockhardt and Amerigen Pharmaceuticals Ltd. (“Amerigen”) are
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`entirely separate and unrelated corporations, with separate financial arrangements
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`and separate and non-overlapping corporate directorship.
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`4. Wockhardt has never entered into a contract with Amerigen and has
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`never had any financial dealings with Amerigen.
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`5.
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`The only relationship between Wockhardt and Amerigen that I am
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`aware of is as codefendants in a joint defense group with respect to underlying
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`district court litigation involving the same patent at issue in this proceeding. Based
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`on my position at Wockhardt, I would know of any other relationship between the
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`parties if one existed. But I do not.
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`6. Wockhardt has not coordinated or otherwise collaborated with
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`Amerigen with respect to the above captioned proceeding. I understand that both
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`1
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`WCK1081
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`Case IPR2016-01582
`U.S. Patent No. 8,822,438
`parties are proceeding independently and separately, both financially and in terms
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`of their ability to control what arguments and evidence are presented.
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`7.
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`Amerigen did not coordinate or share information with Wockhardt
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`regarding the separate petition filed in IPR2016-00286 by Amerigen.
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`8. Wockhardt did not coordinate or share information with Amerigen
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`regarding its filing of the petition associated with the above captioned proceeding.
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`9. Wockhardt made a deliberate decision not to be involved in any
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`petition filed by Amerigen, including not to seek joinder to Amerigen’s IPR.
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`10. Neither Wockhardt as an entity, nor any individual employed by
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`Wockhardt (including Dr. Vipin Dhanorkar), has any authority over Amerigen, or
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`the authority to settle any dispute on its behalf.
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`11. Amerigen has no authority over Wockhardt and cannot settle any
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`dispute on its behalf. Wockhardt and Amerigen are entirely independent.
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`2
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`WCK1081
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`Case IPR2016-01582
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`U.S. Patent No. 8,822,438
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`12.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true, and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under § 100 1 of title 18 of the United States Code.
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`Dated: Dec 12,2016
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`"} '§f’5=“L""=5‘“‘
`
`Gopalakrishnan Venkatesan
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`Parsippany, NJ
`
`WCK1081
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`WCK1081
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