`Patent Owner’s Observations on Cross-Examination
`
`Adam R. Brausa (Reg. No. 60,287)
`Daralyn J. Durie (Pro Hac Vice)
`DURIE TANGRI LLP
`217 Leidesdorff Street
`San Francisco, CA 94111
`
`
`
`
`Filed on behalf of Patent Owner Genentech, Inc. by:
`
`David L. Cavanaugh (Reg. No. 36,476)
`Lauren V. Blakely (Reg. No. 70,247)
`Robert J. Gunther, Jr. (Pro Hac Vice)
`Lisa J. Pirozzolo (Pro Hac Vice)
`Kevin S. Prussia (Pro Hac Vice)
`Andrew J. Danford (Pro Hac Vice)
`WILMER CUTLER PICKERING
` HALE & DORR LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`CELLTRION, INC.,
`Petitioner,
`
`v.
`
`GENENTECH, INC.,
`Patent Owner.
`
`Case IPR2017-01374
`U.S. Patent 6,407,213
`
`PATENT OWNER’S MOTION FOR OBSERVATIONS ON CROSS-
`EXAMINATION OF LUTZ RIECHMANN, PH.D.
`
`
`
`
`
`
`
`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`Pursuant to the Joint Notice of Stipulation to Revise Schedule (Paper 56),
`
`Patent Owner Genentech, Inc. (“Patent Owner”) submits the following
`
`observations on cross-examination of Lutz Riechmann, Ph.D. with respect to his
`
`testimony in support of Petitioner’s reply (Paper 52). The complete transcript of
`
`this cross-examination is submitted herewith as Exhibit 2064.
`
`1.
`
`In Exhibit 2064 at 30:9-18 and 31:19-32:7, Dr. Riechmann admitted
`
`that, when applying Queen 1989 (Ex. 1034) or Queen 1990 (Ex. 1050), it is
`
`possible to identify a combination of substitutions that does not fall into the ’213
`
`patent claims. This testimony is relevant to Petitioners’ argument that a person of
`
`ordinary skill following the teachings of the asserted references would arrive at a
`
`humanized antibody with substitutions that are recited in the claims of the ’213
`
`patent with a reasonable expectation of success. (Paper 52, Petitioner Reply at 7-
`
`11, 13-14; Paper 2, Petition at 6-8, 17-20, 24-60; Ex. 1143, Riechmann Reply
`
`Decl. ¶¶6, 12; Ex. 1003, Riechmann Decl. ¶¶27-36, 114-126, 161-337.)
`
`2.
`
`In Exhibit 2064 at 29:11-30:8 and 32:12-22, Dr. Riechmann admitted
`
`that none of the 15 substitutions disclosed in the anti-Tac antibody in Queen 1989
`
`(Ex. 1034) are recited in the ’213 patent claims and that Queen 1990 (Ex. 1050)
`
`and Queen 1989 (Ex. 1034) contain the same experimental example. This
`
`testimony is generally relevant to Petitioners’ argument that a person of ordinary
`
`skill following the teachings of the asserted references would arrive at a humanized
`
`1
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`antibody with substitutions that are recited in the claims of the ’213 patent with a
`
`reasonable expectation of success and/or that the prior art teaches humanized
`
`antibodies with the recited substitutions that bind antigen. (Paper 52, Petitioner
`
`Reply at 7-11, 13-14; Paper 2, Petition at 6-8, 17-20, 24-60; Ex. 1143, Riechmann
`
`Reply Decl. ¶¶6, 12; Ex. 1003, Riechmann Decl. ¶¶27-36, 114-126, 161-337.)
`
`3.
`
`In Exhibit 2064 at 38:3-10, Dr. Riechmann admitted that Chothia
`
`1985 (Ex. 1063) does not describe a humanized antibody sequence and that the
`
`discussion of 93H in Chothia 1985 is not referring to a substitution in any
`
`particular humanized antibody. This testimony is generally relevant to Petitioners’
`
`argument that a person of ordinary skill following the teachings of the asserted
`
`references would arrive at a humanized antibody with substitutions that are recited
`
`in the claims of the ’213 patent with a reasonable expectation of success and/or
`
`that the prior art teaches humanized antibodies with the recited substitutions that
`
`bind antigen. (Paper 52, Petitioner Reply at 7-14.) In particular, this testimony is
`
`relevant to Dr. Riechmann’s testimony in paragraph 25 of his Reply Declaration
`
`(Ex. 1143) in which he asserts that “The Prior Art Taught Substitutions at 71H,
`
`73H, 78H, and 93H,” “[t]o the extent that the patent identifies 71H, 73H, 78H, and
`
`93H as back mutations . . . the prior art identifies these residues at those positions,”
`
`and included Chothia 1985 (Ex. 1063) in a chart that “summarizes those
`
`substitutions” for residue 93H.
`
`2
`
`
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`
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`In Exhibit 2064 at 11:2-9, 38:14-39:11, 43:12-14 and 44:2-6, Dr.
`
`4.
`
`Riechmann testified that the chart in paragraph 25 of his Reply Declaration (Ex.
`
`1143) should list Chothia & Lesk (Ex. 1062) for residue 78H (not Chothia 1985
`
`(Ex. 1063)) and admitted that Chothia & Lesk does not discuss humanized
`
`antibodies or identify actual substitutions in any humanized antibody. This
`
`testimony is generally relevant to Petitioners’ argument that a person of ordinary
`
`skill following the teachings of the asserted references would arrive at a humanized
`
`antibody with substitutions that are recited in the claims of the ’213 patent with a
`
`reasonable expectation of success and/or that the prior art teaches humanized
`
`antibodies with the recited substitutions that bind antigen. (Paper 52, Petitioner
`
`Reply at 7-14.) In particular, this testimony is relevant to Dr. Riechmann’s
`
`testimony in paragraph 25 of his Reply Declaration (Ex. 1143) in which he asserts
`
`that “The Prior Art Taught Substitutions at 71H, 73H, 78H, and 93H,” “[t]o the
`
`extent that the patent identifies 71H, 73H, 78H, and 93H as back mutations . . . the
`
`prior art identifies these residues at those positions.”
`
`5.
`
`In Exhibit 2064 at 50:3-14, 50:20-51:11, 52:1-4, and 66:8-12, Dr.
`
`Riechmann admitted that the only humanized antibody in Kurrle (Ex. 1071) with a
`
`substitution at 71H and 73H is CIV-4 and that Kurrle does not have any binding
`
`data for CIV-4. This testimony is generally relevant to Petitioners’ argument that
`
`the “up to 3-fold more” binding affinity limitation of claim 65 would have been
`
`3
`
`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`obvious. (Paper 52, Petitioner Reply at 15.) In particular, this testimony is
`
`relevant to Dr. Riechmann’s testimony in paragraphs 21-22 of his Reply
`
`Declaration (Ex. 1143) in which he states that “a person of ordinary skill in the art
`
`would have a reasonable expectation that BMA-EUCIV4 would bind an antigen to
`
`some degree.”
`
`6.
`
`In Exhibit 2064 at 56:19-57:5, Dr. Riechmann admitted that the Table
`
`on page 879 of Chothia 1989 (Ex. 1049) does not describe a humanized antibody.
`
`This testimony is generally relevant to Petitioners’ argument that a person of
`
`ordinary skill following the teachings of the asserted references would arrive at a
`
`humanized antibody with substitutions that are recited in the claims of the ’213
`
`patent with a reasonable expectation of success and/or that the asserted references
`
`teach humanized antibodies with the recited substitutions that bind antigen. (Paper
`
`52, Petitioner Reply at 7-14.) In particular, this testimony is relevant to Dr.
`
`Riechmann’s testimony in paragraph 25 of his Reply Declaration (Ex. 1143) in
`
`which he asserts that “The Prior Art Taught Substitutions at 71H, 73H, 78H, and
`
`93H,” “[t]o the extent that the patent identifies 71H, 73H, 78H, and 93H as back
`
`mutations . . . the prior art identifies these residues at those positions,” and
`
`included Chothia 1989 (Ex. 1049) in a chart that “summarizes those substitutions”
`
`for residue 71H.
`
`7.
`
`In Exhibit 2064 at 61:4-62:5, Dr. Riechmann admitted that in Jones
`
`4
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`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`(Ex. 1033), which is cited by Tramontano (Ex. 1051), the residue at 71H in the
`
`mouse and human sequence is the same. This testimony is generally relevant to
`
`Petitioners’ argument that a person of ordinary skill following the teachings of the
`
`asserted references would arrive at a humanized antibody with substitutions that
`
`are recited in the claims of the ’213 patent with a reasonable expectation of success
`
`and/or that the asserted references teach humanized antibodies with the recited
`
`substitutions that bind antigen. (Paper 52, Petitioner Reply at 7-14.) In particular,
`
`this testimony is relevant to Dr. Riechmann’s testimony in paragraph 25 of his
`
`Reply Declaration (Ex. 1143) in which he asserts that “The Prior Art Taught
`
`Substitutions at 71H, 73H, 78H, and 93H,” “[t]o the extent that the patent identifies
`
`71H, 73H, 78H, and 93H as back mutations . . . the prior art identifies these
`
`residues at those positions,” and included Tramontano (Ex. 1051) in a chart that
`
`“summarizes those substitutions” for residue 71H.
`
`8.
`
`In Exhibit 2064 at 62:6-18, Dr. Riechmann admitted that in
`
`Verhoeyen (Ex. 1068), which is cited by Tramontano (Ex. 1051), there was a
`
`different residue at 71H in the mouse and human sequence and that Verhoeyen did
`
`not make a back mutation at residue at 71H in its humanized antibody. This
`
`testimony is generally relevant to Petitioners’ argument that a person of ordinary
`
`skill following the teachings of the asserted references would arrive at a humanized
`
`antibody with substitutions that are recited in the claims of the ’213 patent with a
`
`5
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`
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`reasonable expectation of success and/or that the asserted references teach
`
`humanized antibodies with the recited substitutions that bind antigen. (Paper 52,
`
`Petitioner Reply at 7-14.) In particular, this testimony is relevant to Dr.
`
`Riechmann’s testimony in paragraph 25 of his Reply Declaration (Ex. 1143) in
`
`which he asserts that “The Prior Art Taught Substitutions at 71H, 73H, 78H, and
`
`93H,” “[t]o the extent that the patent identifies 71H, 73H, 78H, and 93H as back
`
`mutations . . . the prior art identifies these residues at those positions,” and
`
`included Tramontano (Ex. 1051) in a chart that “summarizes those substitutions”
`
`for residue 71H.
`
`9.
`
`In Exhibit 2064 at 63:1-19, Dr. Riechmann admitted that in
`
`Riechmann 1988 (Ex. 1069), which is cited by Tramontano (Ex. 1051), there was a
`
`different residue at 71H in the rat and human sequence and that Riechmann 1988
`
`did not make a back mutation at residue at 71H in its humanized antibody. This
`
`testimony is generally relevant to Petitioners’ argument that a person of ordinary
`
`skill following the teachings of the asserted references would arrive at a humanized
`
`antibody with substitutions that are recited in the claims of the ’213 patent with a
`
`reasonable expectation of success and/or that the asserted references teach
`
`humanized antibodies with the recited substitutions that bind antigen. (Paper 52,
`
`Petitioner Reply at 7-14.) In particular, this testimony is relevant to Dr.
`
`Riechmann’s testimony in paragraph 25 of his Reply Declaration (Ex. 1143) in
`
`6
`
`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`which he asserts that “The Prior Art Taught Substitutions at 71H, 73H, 78H, and
`
`93H,” “[t]o the extent that the patent identifies 71H, 73H, 78H, and 93H as back
`
`mutations . . . the prior art identifies these residues at those positions,” and
`
`included Tramontano (Ex. 1051) in a chart that “summarizes those substitutions”
`
`for residue 71H.
`
`10.
`
`In Exhibit 2064 at 69:19-70:4, Dr. Riechmann admitted that, prior to
`
`the ’213 patent, there was no prior art fully humanized antibody where the binding
`
`affinity was greater for the humanized antibody as compared with the original
`
`mouse antibody. This testimony is generally relevant to Petitioners’ argument that
`
`the “up to 3-fold more” binding affinity limitation of claim 65 would have been
`
`obvious. (Paper 52, Petitioner Reply at 15.) In particular, this testimony is
`
`relevant to Dr. Riechmann’s testimony in paragraph 20 of his Reply Declaration
`
`(Ex. 1143) in which he states that “[a] person of ordinary skill in the art would
`
`have also expected that humanized antibodies that had back mutations in the
`
`framework region identified using the methods in the Queen references and
`
`elsewhere would be more likely to bind antigens with higher affinities . . .”
`
`11.
`
`In Exhibit 2064 at 81:20-84:12, Dr. Riechmann testified that he had
`
`analyzed the sequence of Herceptin and compared it against the claims but that he
`
`was not qualified to answer whether the sequence of Herceptin has everything that
`
`is required to satisfy the limitations of the claims of the ’213 patent. This
`
`7
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`
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`testimony is generally relevant to Petitioners’ argument that Genentech has not
`
`established that Herceptin is an embodiment of the claims. (Paper 52, Petitioner
`
`Reply at 18-21.) In particular, this testimony is relevant to Dr. Riechmann’s
`
`testimony in paragraph 34 of his Reply Declaration (Ex. 1143) in which he states
`
`that “Herceptin does not use a consensus sequence of ‘all human immunoglobulins
`
`of any particular subclass or subunit structure’ as required by the claims.”
`
`Respectfully submitted,
`
`/David L. Cavanaugh/
`David L. Cavanaugh
`Reg. No. 36,476
`
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`1875 PENNSYLVANIA AVENUE NW
`WASHINGTON, DC 20006
`TEL: 650-858-6000
`FAX: 650-858-6363
`EMAIL: david.cavanaugh@wilmerhale.com
`
`Date: June 25, 2018
`
`
`
`
`
`8
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`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`IPR2017-01374
`Patent Owner’s Exhibit List
`
`Exhibit Name
`
`Genentech, Inc. Laboratory Notebook No. 10098 (Leonard
`Presta)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Laboratory Notebook No. 10823 (Leonard
`Presta)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Laboratory Notebook No. 11268 (Paul Carter)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Laboratory Notebook No. 11643 (Paul Carter)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Laboratory Notebook No. 10840 (John Brady)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Laboratory Notebook No. 11162 (John Brady)
`PROTECTIVE ORDER MATERIAL
`Excerpts from Genentech, Inc. Laboratory Notebook No. 11008
`(Ann Rowland)
`PROTECTIVE ORDER MATERIAL
`Excerpts from Genentech, Inc. Laboratory Notebook No. 11297
`(Tim Hotaling)
`PROTECTIVE ORDER MATERIAL
`Excerpts from Genentech, Inc. Laboratory Notebook No. 11568
`(Monique Carver)
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Interoffice Memorandum from Paul Carter to
`Leonard Presta and Dennis Henner
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Interoffice Memorandum from Paul Carter to
`Leonard Presta
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Synthetic DNA Requests
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Synthetic DNA Requests
`PROTECTIVE ORDER MATERIAL
`
`Patent Owner’s
`Exhibit Number
`2001
`
`
`2002
`
`2003
`
`2004
`
`2005
`
`2006
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`2007
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`2008
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`2009
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`2010
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`2011
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`2012
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`2013
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s
`Exhibit Number
`2014
`
`
`2015
`
`2016
`
`2017
`
`2018
`
`2019
`2020
`
`2021
`
`2022
`
`2023
`
`2024
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`2025
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`2026
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`2027
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`Exhibit Name
`
`Genentech, Inc. Protein Engineering of 4D5 Status Report
`PROTECTIVE ORDER MATERIAL
`Genentech, Inc. Interoffice Memorandum re: RCC Minutes and
`Recommendations
`PROTECTIVE ORDER MATERIAL
`Declaration of Dr. Leonard G. Presta
`PROTECTIVE ORDER MATERIAL
`Declaration of Dr. Paul J. Carter
`PROTECTIVE ORDER MATERIAL
`Declaration of John Ridgway Brady
`PROTECTIVE ORDER MATERIAL
`Declaration of Irene Loeffler
`Paul Carter, et al., Humanization of the Anti-p185 Antibody for
`Human Cancer Therapy, 89 PROC. NATL. ACAD. SCI. 4285-
`4289 (1992)
`Leonard Presta, et al., Humanization of an Anti-Vascular
`Endothelial Growth Factor Monoclonal Antibody for the
`Therapy of Solid Tumors and Other Disorders, 57 CANCER
`RESEARCH 4593-4599 (1997)
`Marianne Brüggerman, et al., The Immunogenicity of Chimeric
`Antibodies, 170 J. EXP. MED. 2153-2157 (1989)
`Jatinderpal Kalsi, et al., Structure-function Analysis and the
`Molecular Origins of Anti-DNA Antibodies in Systemic Lupus
`Erythematosus, EXPERT REVIEWS IN MOLECULAR MEDICINE 1-
`28 (1999)
`Scott Gorman, et al., Reshaping a Therapeutic CD4 Antibody,
`88 PROC. NATL. ACAD. SCI. 4181-4185 (1991)
`John Isaacs, et al., Humanised Monoclonal Antibody Therapy
`for Rheumatoid Arthritis, 340 THE LANCET 748-752 (1992)
`Elvin Kabat, et al., Sequences of Proteins of Immunological
`Interest 1-23 (4th ed. 1987)
`Anna Tramontano, et al., Framework Residue 71 Is a Major
`Determinant of the Position and Conformation of the Second
`Hypervariable Region in the VH Domains of Immunoglobulins,
`215 J. MOL. BIOL. 175-182 (1990)
`
`
`
`
`
`
`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`Exhibit Name
`
`H.M. Shepard, et al., Herceptin, in THERAPEUTIC ANTIBODIES.
`HANDBOOK OF EXPERIMENTAL PHARMACOLOGY 183-219 (Y.
`Chernajovsky & A. Nissim, eds. 2008)
`Excerpt from Roche Finance Report 2016
`Modified Default Standing Protective Order and Patent
`Owner’s Certification of Agreement to Terms
`Modified Default Standing Protective Order – Redline
`Declaration of Robert J. Gunther, Jr. in support of Motion for
`Admission Pro Hac Vice
`Declaration of Daralyn J. Durie in support of Motion for
`Admission Pro Hac Vice
`Declaration of Lisa J. Pirozzolo in support of Motion for
`Admission Pro Hac Vice
`Declaration of Kevin S. Prussia in support of Motion for
`Admission Pro Hac Vice
`Declaration of Andrew J. Danford in support of Motion for
`Admission Pro Hac Vice
`File History for U.S. Patent Application No. 07/715,272
`Immunoglobulin Variants (filed June 14, 1991).
`Reserved
`Deposition Transcript of Lutz Riechmann, Celltrion, Inc. v.
`Genentech, Inc. (PTAB), Feb. 14, 2018
`Deposition Transcript of Robert Leonard, Celltrion, Inc. v.
`Genentech, Inc. (PTAB), Feb. 16, 2018
`Expert Declaration of Dr. Ian A. Wilson
`U.S. Patent No. 7,375,193
`U.S. Patent No. 7,560,111
`Leonard Presta, et al., Humanization of an Antibody Directed
`Against IgE, 151 J. IMMUNOLOGY 2623-2632 (1993)
`A. Bondi, van de Waals Volumes and Radii, 68 J. PHYSICAL
`CHEMISTRY 441-451 (1964)
`Reserved
`Reserved
`Reserved
`Reserved
`Reserved
`Reserved
`
`Patent Owner’s
`Exhibit Number
`2028
`
`
`2029
`2030
`
`2031
`2032
`
`2033
`
`2034
`
`2035
`
`2036
`
`2037
`
`2038
`2039
`
`2040
`
`2041
`2042
`2043
`2044
`
`2045
`
`2046
`2047
`2048
`2049
`2050
`2051
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`
`Patent Owner’s
`Exhibit Number
`2052
`
`2053
`
`
`2054
`
`2055
`
`2056
`2057
`2058
`2059
`
`2060
`
`2061
`
`2062
`
`2063
`
`2064
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`Exhibit Name
`
`Reserved
`Ole Brekke, et al., Therapeutic Antibodies for Human Diseases
`at the Dawn of the Twenty-First Century, 2 NATURE REVIEWS |
`DRUG DISCOVERY 52- 62 (2003)
`Thomas A. Waldmann, Monoclonal Antibodies in Diagnosis
`and Therapy, 252 SCIENCE 1657-1662 (1991)
`Greg Winter, et al., Antibody-Based Therapy: Humanized
`Antibodies, 14 TIPS 139-143 (1993)
`Reserved
`Reserved
`Reserved
`Gert Riethmüller, et al., Monoclonal Antibodies in the
`Detection and Therapy of Micrometastic Epthelial Cancers, 4
`CURRENT OP. IMMUNOLOGY 647-655 (1992)
`Gert Riethmüller, et al., Monoclonal Antibodies in Cancer
`Therapy, 5 CURRENT OP. IMMUNOLOGY 732-739 (1993)
`Mark D. Pegram, et al., Phase II Study of Receptor-Enhanced
`Chemosensitivity Using Recombinant Humanized Anti-
`pl85HER2/neu Monoclonal Antibody Plus Cisplatin in Patients
`with HER2/neu-Overexpressing Metastatic Breast Cancer
`Refractory to Chemotherapy Treatment, 16 J. CLINICAL
`ONCOLOGY 2659-2671 (1998)
`Redline of IPR2016-01694 Expert Declaration of Dr. Eduardo
`A. Padlan in Support of Petition for Inter Partes Review of
`Patent No. 6,407,213 and IPR2017-01373 Expert Declaration
`of Lutz Riechmann, Ph.D., in Support of Petition for Inter
`Partes Review of Patent No. 6,407,213
`Corrected Exhibit P of Expert Declaration of Lutz Riechmann,
`Ph.D., in Support of Petition for Inter Partes Review of Patent
`No. 6,407,213
`Deposition Transcript of Lutz Riechmann, Celltrion, Inc. v.
`Genentech, Inc. (PTAB), June 19, 2018
`
`
`
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`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`CERTIFICATE OF SERVICE
`I hereby certify that, on June 25, 2018, I caused a true and correct copy of
`the following materials:
`
`
`
` Patent Owner’s Observations on the Cross-Examination of Lutz
`Riechman, Ph.D.
` Patent Owner’s Updated Exhibit List
` Exhibit 2064
`
`
`to be served via electronic mail on the following attorneys of record:
`
`Cynthia Lambert Hardman
`GOODWIN PROCTER LLP
`chardman@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
`
`Robert V. Cerwinski
`GOODWIN PROCTER LLP
`rcerwinski@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
`
`Elizabeth Holland
`GOODWIN PROCTER LLP
`eholland@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
`
`Linnea P. Cipriano
`GOODWIN PROCTER LLP
`lcipriano@goodwinlaw.com
`620 Eighth Avenue, New York, NY 10018
`
`Sarah J. Fischer
`GOODWIN PROCTER LLP
`sfischer@goodwinlaw.com
`100 Northern Avenue, Boston, MA 02110
`
`
`
`
`
`
`
`
`IPR2017-01374
`Patent Owner’s Observations on Cross-Examination
`
`/Lauren V. Blakely/
`Lauren V. Blakely
`Reg. No. 70,247
`Wilmer Cutler Pickering Hale & Dorr LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`(650) 600-5039
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