`
`From:
`Sent:
`To:
`
`Cc:
`
`Subject:
`
`Kennedy, Michael <MKennedy@cov.com>
`Tuesday, March 21, 2017 6:18 PM
`Cobb, Jeremy; Olinger, Jonathan; Holloway, Clay; Stockwell, Mitch; Brouillette, Amanda;
`MJOFFRE@skgf.com; JCROZENDAAL@skgf.com; CVIRA@skgf.com; Delzicol-Cov
`Moore, Susie; andrea@wsfirm.com; claire@wsfirm.com; wh@wsfirm.com; George
`Pappas; Elikan, Jeffrey
`RE: Warner Chilcott, et al v Teva Pharmaceuticals USA, Inc. and Mylan Pharmaceuticals
`Inc., et al
`
`All: In view of today’s meet-and-confer, and Qualicaps’ designation of Nigel Watson to cover some topics previously
`assigned to Tanjoh-san, the below now represents the topics for which Qualicaps is designating Tanjoh-san subject to
`our objections. I have indicated changes from Jeremy’s 3/17 email with strikethrough and underline. I believe the edits
`below to topics 3, 4, and 6, and addition of 9 to the list, should address Mylan’s concerns from this morning’s call.
`
`
`• Mylan and Teva Topic 1: Tanjoh-san will provide testimony regarding the conception,
`research, development, design, manufacture, reduction to practice, and diligence
`between conception and reduction to practice of the inventions claimed by the ’180
`patent
`• Mylan and Teva Topic 2: Tanjoh-san will provide testimony regarding publications
`related to the ’180 patent.
`• Mylan and Teva Topic 3: Tanjoh-san will provide testimony regarding facts concerning
`the work on hard capsule products manufactured by Qualicaps, including but not limited
`to those that embody the invention claimed by the ’180 patent.
`• Mylan and Teva Topic 4: Tanjoh-san will provide testimony regarding the first offer for
`sale, public use, and first sale of any hard capsule products manufactured by Qualicaps
`that embody the invention claimed by the ’180 patent.
`• Mylan and Teva Topic 5: Tanjoh-san will provide testimony regarding facts concerning
`the identification of any hard capsule products manufactured by Qualicaps that
`incorporates, practices, or embodies that embody the invention claimed by the ’180
`patent.
`• Mylan and Teva Topic 6: Tanjoh-san will provide testimony regarding facts concerning
`the development of hard capsule products manufactured by Qualicaps, including failed
`attempts, that led to the are an embodiment of the ’180 patent.
`• Mylan and Teva Topic 7: Tanjoh-san will provide testimony regarding the design,
`development, first sale, and/or first offer for sale of hard capsule products
`manufactured by Qualicaps that embodies the invention claimed by the ’180 patent.
`• Mylan and Teva Topic 8: Tanjoh-san will provide testimony regarding any non-privileged
`information that is responsive to this topic.
`• Mylan and Teva Topic 9: Tanjoh-san will provide testimony regarding any non-privileged
`information that is responsive to this topic.
`• Mylan and Teva Topic 12: Tanjoh-san will provide testimony regarding facts concerning
`any assignment, license, or transfer of rights in the ’180 patent to Warner Chilcott
`Company, LLC.
`
`1
`
`Petitioner Mylan Pharmaceuticals Inc. - Exhibit 1025 - Page 1
`
`
`
`• Mylan and Teva Topic 15: Tanjoh-san will provide testimony regarding the benefits or
`advantages of hard capsule products manufactured by Qualicaps that embody the
`invention claimed by the ’180 patent.
`• Mylan and Teva Topic 16: Tanjoh-san will provide testimony regarding the facts
`concerning this topic subject to the objections and to the extent that it does not involve
`expert testimony or a legal conclusion
`• Mylan and Teva Topic 17: Tanjoh-san will provide testimony regarding the facts
`concerning this topic subject to the objections and to the extent that it does not involve
`expert testimony or a legal conclusion
`• Mylan and Teva Topic 18: Tanjoh-san will provide testimony regarding the people at
`Qualicaps involved in the development, manufacture, sales, and licensing of any hard
`capsule products manufactured by Qualicaps that embodies the invention claimed by
`the ’180 patent. [Qualicaps will designate Mr. Watson for the portion of Topic 18
`dealing with sales and licensing].
`• Mylan and Teva Topic 21: Tanjoh-san will provide testimony regarding facts concerning
`any assignment, license, or transfer of rights in the ’180 patent to Warner Chilcott
`Company, LLC.
`• Mylan and Teva Topic 22: Tanjoh-san will provide testimony regarding this topic subject
`to our objections.
`• Mylan Topic 24 and Teva Topic 26: Tanjoh-san will provide testimony regarding this
`topic subject to our objections. [Clarification - Tanjoh-san will cover this topic as it
`relates to the topics for which he is designated, and Mr. Watson will cover this topic as it
`relates to his topics].
`• Mylan Topic 25 and Teva Topic 27: Tanjoh-san will provide testimony regarding this
`topic subject to our objections.
`• Mylan Topic 26 and Topic 28: Tanjoh-san will provide testimony regarding this topic
`subject to our objections. [Clarification - Tanjoh-san will cover this topic as it relates to
`the topics for which he is designated, and Mr. Watson will cover this topic as it relates to
`his topics].
`
`
`From: Cobb, Jeremy
`Sent: Monday, March 20, 2017 5:56 PM
`To: Olinger, Jonathan; Holloway, Clay; Stockwell, Mitch; Brouillette, Amanda; MJOFFRE@skgf.com;
`JCROZENDAAL@skgf.com; CVIRA@skgf.com; Delzicol-Cov
`Cc: Moore, Susie; andrea@wsfirm.com; claire@wsfirm.com; wh@wsfirm.com; Pappas, George; Elikan, Jeffrey;
`Kennedy, Michael
`Subject: RE: Warner Chilcott, et al v Teva Pharmaceuticals USA, Inc. and Mylan Pharmaceuticals Inc., et al
`
`Jonathan,
`
`We will be available at noon EST tomorrow. Please use the following dial-in: 1-866-798-7071 Conference Code
`13504396.
`
`Best,
`Jeremy
`
`Jeremy Cobb
`
`Covington & Burling LLP
`One CityCenter, 850 Tenth Street, NW
`
`2
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`
`
`Petitioner Mylan Pharmaceuticals Inc. - Exhibit 1025 - Page 2
`
`