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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE IPR 2015-01409
` Patent 5,886,035
`__________________________________
`MICRO LABS LIMITED and )
`MICRO LABS USA, INC., )
` Petitioners )
`vs. )
`SANTEN PHARMACEUTICAL CO., LTD. )
`and ASAHI GLASS CO., LTD., )
` Patent Owner )
`___________________________________
`
` Videotaped Deposition of Aron Rose
` Washington, D.C.
` February 14, 2018
` 9:07 a.m.
`
`Reported by: Bonnie L. Russo
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`212-279-9424
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`Veritext Legal Solutions
`www.veritext.com
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`212-490-3430
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`Santen/Asahi Glass Exhibit 2026
`Micro Labs v. Santen Pharm. and Asahi Glass
`IPR2017-01434
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE IPR 2015-01409
` Patent 5,886,035
`__________________________________
`MICRO LABS LIMITED and )
`MICRO LABS USA, INC., )
` Petitioners )
`vs. )
`SANTEN PHARMACEUTICAL CO., LTD. )
`and ASAHI GLASS CO., LTD., )
` Patent Owner )
`___________________________________
`
` Videotaped Deposition of Aron Rose
` Washington, D.C.
` February 14, 2018
` 9:07 a.m.
`
`Reported by: Bonnie L. Russo
`
`212-279-9424
`
`Veritext Legal Solutions
`www.veritext.com
`
`212-490-3430
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`Santen/Asahi Glass Exhibit 2026
`Micro Labs v. Santen Pharm. and Asahi Glass
`IPR2017-01434
`
`
`
`Deposition of Aron Rose held at:
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`Page 2
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` Pillsbury Winthrop Shaw Pittman, LLP
` 1200 17th Street, N.W.
` Washington, D.C.
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`Pursuant to Notice, when were present on behalf
`of the respective parties:
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`APPEARANCES:
`On behalf of the Petitioner:
` CEDRIC TAN, Esq.
` SOPHIE WEI, Ph.D., Esq.
` ALTON HARE, Esq.
` PILLSBURY WINTHROP SHAW PITTMAN, LLP
` 1200 17th Street, N.W.
` Washington, D.C. 20036
` 202-663-8000
` cedric.tan@pillsburylaw.com
` sophie.wei@pillsburylaw.com
` alton.hare@@pillsburylaw.com
`On behalf of the Patent Owner:
` ARLENE CHOW, Esq.
` ERNEST YAKOB, Ph.D., Esq.
` HOGAN LOVELLS US LLP
` 875 Third Avenue
` New York, New York 10022
` 212-918-3000
` arlene.chow@hoganlovells.com
` ernest.yakob@hoganlovells.com
`Also Present:
`Daniel Russo, Videographer
`Solomon Francis, Videographer
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` C O N T E N T S
`EXAMINATION OF ARON ROSE PAGE
`BY MR. YAKOB 7
`
` EXHIBITS
`
`Exhibit 2024 Article entitled 28
` "Pharmacological testing
` in the laser-induced
` monkey glaucoma model"
`
`PREVIOUSLY MARKED EXHIBITS:
`
`Exhibit 1003 European Patent Application
` 0 639 563 A2
`
`Exhibit 2017 European Patent Application
` 0 364 417
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`(Exhibits included with transcript.)
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` P R O C E E D I N G S
`
` THE VIDEOGRAPHER: Good morning.
` We are going on the record at 9:07
`a.m. on February 14, 2018. Please note that
`the microphones are sensitive and may pick up
`whispering, private conversations, and cellular
`interference. Please turn off all cell phones
`and place them away from the microphones as
`they can interfere with the deposition audio.
`Audio and video recording will take place
`unless all parties agree to go off the record.
` This is Media Unit 1 of the video
`recorded deposition of Dr. Aron Rose, taken by
`counsel for respondent in the matter of Micro
`Labs Limited and Micro Labs U.S.A. versus
`Santen Pharmaceutical Company, LTD, and Asahi
`Glass Company, LTD, filed in the United States
`Patent and Trademark Office before the Patent
`Trial and Appeal Board.
` This deposition is being held at
`Pillsbury Winthrop Shaw Pittman, LLP, located
`at 1200 17th Street, N.W., Washington, D.C.
` My name is Daniel Russo from the
`firm Veritext Legal Solutions. I am the
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`Page 6
`videographer. The court reporter is Bonnie
`Russo from the firm Veritext Legal Solutions.
` Counsel and all present in the room
`will now state their appearances and
`affiliations for the record, please.
` MR. YAKOB: Ernest Yakob of Hogan
`Lovells on behalf of the patent owners, Santen
`Pharmaceutical and Asahi Glass.
` MS. CHOW: Arlene Chow of Hogan
`Lovells on behalf of patent owner AGC and
`Santen.
` MR. TAN: Cedric Tan with the law
`firm of Pillsbury, here on behalf of the
`petitioners, Micro Labs Limited and Micro Labs
`U.S.A.
` MR. HARE: Alton Hare, also on
`behalf of Pillsbury Winthrop Shaw Pittman and
`also on behalf of petitioners.
` MS. WEI: Sophie Wei on behalf of
`Micro Labs.
` THE VIDEOGRAPHER: Will the court
`reporter, please, swear in the witness.
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` ARON ROSE,
`being first duly sworn, to tell the truth, the
` whole truth and nothing but the truth,
` testified as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNERS
` BY MR. YAKOB:
` Q. Good morning.
` A. Good morning.
` Q. Could you, please, state your name
`and address for the record.
` A. Dr. Aron Rose.
` Business address? Home address?
` Q. Home address is fine.
` A. 136 Riverview Avenue in Branford,
`Connecticut.
` Q. Dr. Rose, you understand you're
`under oath today?
` A. I do.
` Q. Okay. And do you have any medical
`conditions that would impair your ability to
`testify truthfully and accurately today?
` A. I do not.
` Q. Just so we're on the same page and
`so everything goes smoothly here today, do you
`understand that I'm going to be asking
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`Page 8
`questions and you'll wait for me to finish
`asking a question before you start your answer?
` A. I understand.
` Q. Okay. And so that the court
`reporter -- so that -- sorry.
` So that the stenographer can
`accurately capture the testimony, do you
`understand that you should verbalize your
`answers rather than nodding, for example, or
`saying uh-huh?
` A. Yes, I do.
` Q. Okay. With that, let's talk a
`little bit about your preparation for the
`deposition today. Okay?
` Did you meet with Counsel to prepare
`for your deposition today?
` A. Yes, I did.
` Q. Okay. When did you meet with them?
` A. In person.
` Q. Let's start with in person. When
`did you meet with Counsel in person to prepare
`for the deposition today?
` A. On Monday of this week.
` Q. How long did you meet with Counsel
`during -- on Monday?
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` A. Approximately eight hours.
` Q. Prior to the in-person meeting, did
`you meet with Counsel to -- other than in
`person to prepare for the deposition today?
` A. I had several phone conversations.
` Q. Okay. And when did those occur?
` A. As of the date of my engagement
`which was last spring.
` Q. Okay. Specifically to prepare for
`this deposition, did you have other meetings
`with Counsel?
` A. I did not.
` Q. Okay. Did you review any documents
`while preparing for this deposition with
`Counsel?
` A. I did.
` MR. TAN: And -- and I'm -- I'm
`going to make a note here. Be very careful
`with respect to disclosing specific information
`relating to your preparation for today's
`deposition because that is privileged, but you
`can answer certain questions "yes" or "no,"
`with that said.
` MR. YAKOB: Do you want me to re-ask
`the question?
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` MR. TAN: Sure.
` BY MR. YAKOB:
` Q. Did you review any documents during
`your preparation for the deposition today?
` A. Yes, I did.
` Q. Okay. Can you identify the
`documents that you reviewed?
` MR. TAN: I'm going to -- I'm going
`to object on the basis of privilege and
`instruct the witness not to answer that
`question.
` BY MR. YAKOB:
` Q. Okay. Are you declining to identify
`which documents you reviewed on instruction of
`Counsel?
` MR. TAN: I'm instructing you not to
`answer.
` THE WITNESS: The answer would be
`"yes."
` BY MR. YAKOB:
` Q. Did you communicate with anyone
`other than Counsel during your prep -- during
`your preparation for the deposition today?
` A. No, I did not.
` Q. And who was -- which counsel
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`Page 11
`specifically did you meet with during your
`preparation?
` A. I met with Cedric Tan. I met with
`Alton Hare. I met with the attorney, Sophie,
`whose name -- whose complete name I do not
`know. I met very briefly with an attorney
`whose first name is Keeto and his last name is
`unknown to me.
` Q. Did you meet yesterday, at all, with
`Dr. DeLong?
` A. I said "hello" to Dr. DeLong.
` Q. Other than -- other than saying
`"hello," you didn't discuss -- did you discuss
`the substance of his deposition?
` MR. TAN: Objection to form.
` THE WITNESS: No, I did not.
` BY MR. YAKOB:
` Q. Did -- did you, otherwise, learn of
`the substance, or did you -- sorry -- strike
`that.
` Did anyone discuss the substance of
`Dr. DeLong's deposition with you yesterday?
` MR. TAN: Objection to form. I'm
`going to object that you are delving into
`protected -- a protected area and you're asking
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`Page 12
`for information relating to the preparation of
`his deposition. I'm going to instruct the
`witness not to answer that question.
` MR. YAKOB: I guess just a "yes" or
`"no" as to whether a topic or documents were
`reviewed, not the substance of the
`communication. So I -- I just want to state
`for the record that I think the last two
`instructions have been improper.
` MR. TAN: That's fine. My objection
`stands.
` BY MR. YAKOB:
` Q. Just "yes" or "no," are you aware of
`the substance of questions and answers from Dr.
`DeLong's deposition?
` MR. TAN: Objection to form.
` THE WITNESS: My answer would be
`"no."
` BY MR. YAKOB:
` Q. Are you aware that the patent owners
`in this case -- sorry -- strike that.
` Are you aware that Dr. Robert
`Fechtner has submitted a declaration in this
`proceeding?
` A. Yes.
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` Q. Okay. Do you have any experience
`with Dr. Fechtner?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Okay. Have you -- have you heard
`of -- are you aware of Dr. Fechtner?
` MR. TAN: Objection to form.
` THE WITNESS: Yes.
` BY MR. YAKOB:
` Q. How are you aware of him?
` A. He has lectured at numerous
`conferences in which I have taken part or
`attended.
` Q. Is Dr. Fechtner respected in the
`glaucoma field?
` MR. TAN: Objection to form.
` THE WITNESS: Yes.
` BY MR. YAKOB:
` Q. Do you understand that you have been
`retained in this proceeding as an expert
`witness?
` A. Yes, I do.
` Q. Have you been retained as an expert
`in any other patent proceedings?
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` A. No, I have not.
` Q. Have you ever been retained as a
`technical consultant in any other patent
`proceedings?
` A. No, I have not.
` Q. So just for the sake of clarity, you
`have not ever been deposed before in a patent
`proceeding?
` MR. TAN: Objection to form.
` THE WITNESS: That is correct.
` BY MR. YAKOB:
` Q. And have you been deposed in any
`other proceedings, any other legal pro- --
`sorry.
` Have you ever been deposed in any
`other legal proceedings?
` A. Yes, I have.
` Q. Okay. Can you identify the subject
`-- how many times have you been -- sorry.
`Strike that.
` How many times have you been -- have
`you been deposed?
` A. As an expert?
` Q. Sorry.
` How many times have you ever been
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`deposed in a legal proceeding?
` MR. TAN: Objection to form.
` THE WITNESS: Four, I believe.
` BY MR. YAKOB:
` Q. What was the subject matter of the
`legal proceedings in which you have been
`deposed?
` A. Medical malpractice and personal
`injury.
` Q. Were you a named defendant in any of
`those proceedings?
` A. Only one.
` Q. When was the proceeding in which you
`were a named defendant?
` A. More than two decades ago.
` Q. Have you ever testified in front of
`a judge?
` A. Yes, I have.
` Q. How many times have you testified in
`front of a judge?
` A. Twice.
` Q. In the two times that you've
`testified before a judge, were both of those
`cases medical malpractice cases?
` A. Yes.
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` Q. Were either of the cases in which
`you testified in front of a judge a proceeding
`in which you were a named defendant?
` A. No.
` Q. In the four proceedings in which you
`have been deposed, did the cases involve
`treatment of glaucoma?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Have you ever -- have you ever --
`sorry. Strike that.
` Do you understand that Counsel
`that -- that has retained you in this
`proceeding is the Pillsbury law firm?
` A. I do.
` Q. Okay. And have you ever been
`retained previously, apart from this
`proceeding, by the Pillsbury law firm?
` A. I have not.
` Q. Have you -- strike that.
` Do you understand that the
`petitioner in this proceeding is Micro Labs?
` A. I do understand that.
` Q. Have you ever been retained, apart
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`Page 17
`from this proceeding, as an expert on behalf of
`Micro Labs?
` A. I have not.
` Q. Have you ever been retained as a
`consultant for Micro Labs?
` A. I have not.
` Q. Now, you submitted a declaration in
`this proceeding; is that correct?
` A. Yes.
` Q. You mentioned previously when you
`first had been retained, but I'm going to ask
`you to repeat it for the record.
` When were you retained in this
`proceeding?
` MR. TAN: Objection to form.
` THE WITNESS: The spring of last
`year.
` BY MR. YAKOB:
` Q. Do you recall what month you were
`retained in this proceeding?
` A. I believe it was May, but I can't
`say that with certainty.
` Q. Who approached you initially with
`respect to retaining you in this proceeding?
` MR. TAN: Objection to form.
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`Page 18
` THE WITNESS: Attorney Christopher
`May.
` BY MR. YAKOB:
` Q. Is Christopher May an attorney at
`the Pillsbury law firm?
` A. He was at the time.
` Q. Do you remember, approximately, when
`in May of 2017 you were retained in this
`proceeding?
` A. Not with assurance, but I believe it
`was toward the end of the month.
` Q. How -- how many hours did you spend
`preparing your declaration?
` MR. TAN: Objection to form.
` THE WITNESS: I don't recall.
` BY MR. YAKOB:
` Q. Was it more than ten hours?
` MR. TAN: Same objection.
` THE WITNESS: Probably.
` BY MR. YAKOB:
` Q. Did you spend more than 20 hours
`preparing your declaration?
` A. I can't say with assurance.
` Q. Is it fair to say that you spent
`between 10 and 20 hours --
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` MR. TAN: Objection to form.
` BY MR. YAKOB:
` Q. -- of preparing your declaration?
` A. That would be a guess on my part.
` Q. Who prepared the first draft of your
`declaration?
` MR. TAN: Objection to form. I'm
`going to object that you're delving into the
`areas that are protected and privileged. I'm
`going to instruct the witness not to answer
`with respect to the preparation of his
`declaration and how that came about.
` MR. YAKOB: I think who drafted his
`declaration is not privileged substance in any
`way.
` MR. TAN: I think you can -- you can
`ask the question with a "yes" or "no" question,
`but I'm not going to allow that question.
` BY MR. YAKOB:
` Q. Did you personally prepare the first
`draft of your declaration?
` MR. TAN: You may answer.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Did you -- sorry -- strike that.
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` Are you aware that Dr. DeLong
`submitted a declaration in this proceeding as
`well?
` A. Not specifically.
` Q. I'm going to ask this question
`anyway just to -- just to make sure.
` Did you review a declaration by Dr.
`DeLong in connection with this proceeding?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Sorry, just -- just to clarify, at
`any point in time, including in preparation for
`your deposition today, have you reviewed a
`declaration by Dr. DeLong submitted in this
`proceeding?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Let's talk about your educational
`background a little bit. Do you -- just to
`confirm, you don't have a Ph.D.; is that
`correct?
` A. That is correct.
` Q. Do you have a degree in medicinal or
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`organic chemistry?
` A. No.
` Q. Do you have experience formulating
`ophthalmic compositions for the treatment of
`glaucoma or ocular hypertension?
` A. No, I do not.
` Q. Do you have experience formulating
`any other ophthalmic formulations for the
`treatment of eye conditions?
` A. No, I do not.
` Q. Do you have experience developing
`prostaglandin analogs for IOP reduction?
` MR. TAN: Objection to form.
` THE WITNESS: No, I do not.
` BY MR. YAKOB:
` Q. Did you study prostaglandin analogs
`prior to December 26, 1996?
` A. Can you be more specific in your
`question?
` Q. Sure.
` In a basic research setting, have
`you studied prostaglandin analogs prior to
`December 26, 1996?
` MR. TAN: Objection to form.
` THE WITNESS: Sorry, but can you
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`clarify the use of the word "study"?
` BY MR. YAKOB:
` Q. Okay. Have you published any
`scientific papers based on work conducted prior
`to December 26, 1996, in relation to
`prostaglandin analogs?
` A. Yes, I did.
` Q. Okay. How many papers have you
`published based on work conducted prior to
`December 26, 1996, regarding prostaglandin
`analogs?
` A. I published one paper.
` Q. Was that paper published in
`approximately 1985?
` MR. TAN: Objection to form.
` THE WITNESS: To the best of my
`recollection.
` BY MR. YAKOB:
` Q. Do you recall the authors -- do you
`recall the -- sorry. Strike that.
` Do you recall the first author on
`that paper that was published in 1985?
` A. I believe his name was Ping-Yu Lee.
` Q. What was the subject matter of the
`paper that was published in 19- -- 1985
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`regarding prostaglandin analogs?
` A. Sorry. Could you repeat the
`question?
` Q. What was the subject matter of the
`paper that was published in 1985 regarding
`prostaglandin analogs?
` A. Pharmacologic testing in the
`cynomolgus monkey model.
` Q. Apart from the paper that was
`published in 1985 that you just testified
`about, did you publish any other papers prior
`to December 26, 1996, regarding work -- sorry.
`Strike that.
` Apart from the paper published in
`1985 that you just testified about, did you
`publish any other papers based on work
`regarding prostaglandin analogs that was done
`prior to December 26, 1996.
` MR. TAN: Objection to form.
` THE WITNESS: For clarification, are
`you asking whether I have any other
`publications involving any work with
`prostaglandins?
` BY MR. YAKOB:
` Q. Prior to -- well, let's start with
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`that. Prior to this -- you know, prior -- with
`respect to work conducted prior to December 26,
`1996, have you published any papers regarding
`prostaglandin analogs?
` MR. TAN: Objection to form.
` THE WITNESS: It would help me if I
`was able to see a copy of my CV.
` BY MR. YAKOB:
` Q. All right. So sitting here today,
`do you recall any papers that -- based on work
`prior to December 26, 1996, regarding
`prostaglandin analogs?
` A. The question in my mind has to do
`with the date.
` Q. Okay. What -- is there a specific
`paper that you're -- that you are thinking
`about with respect to -- sorry.
` What paper are you unsure of the
`date of in which you conduct -- in which you
`studied prostaglandin analogs?
` MR. TAN: Objection to form.
` THE WITNESS: The clarification I
`seek by examination of my CV are the title and
`date of publication.
` BY MR. YAKOB:
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` Q. Is that -- are you seeking
`clarification with respect to a particular
`publication?
` MR. TAN: Objection to form.
` THE WITNESS: Yes, I am.
` BY MR. YAKOB:
` Q. And what was the subject matter of
`that publication that you are seeking
`clarification on?
` MR. TAN: Objection to form. Asked
`and answered.
` THE WITNESS: Clinical research
`involving the use of prostaglandin drops in
`human subjects.
` BY MR. YAKOB:
` Q. Were the prostaglandin drops in that
`paper latanoprost?
` A. I would like to refer to a copy of
`my CV to answer that question with the
`accuracy --
` Q. Okay.
` A. -- it deserves.
` Q. Okay. Other than clinical research,
`other than papers relating to clinical
`research, are there any other papers relating
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`to work prior to December 26, 1996, on
`prostaglandin analogs?
` A. No, there are not.
` Q. Have you ever synthesized a
`prostaglandin analog?
` A. No, I have not.
` Q. Have you performed animal studies of
`IOP reduction with prostaglandin analogs?
` A. Yes, I have.
` Q. And you have published animal
`studies of IOP reduction with prostaglandin
`analogs?
` MR. TAN: Objection to form.
` THE WITNESS: Yes, I have.
` BY MR. YAKOB:
` Q. Other than the -- sorry -- strike
`that.
` Is -- is one of those papers on
`animal studies of IOP reduction of
`prostaglandin analogs the Lee 1985 paper
`that -- that you testified about?
` MR. TAN: Objection to form.
` THE WITNESS: Yes, it is.
` BY MR. YAKOB:
` Q. Are there any other published
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`papers -- sorry.
` Have you published any other papers
`other than the Lee 1985 paper regarding animal
`studies with IOP reduction with prostaglandin
`analogs?
` A. No, I have not.
` Q. Have you published any papers
`reporting on side effects in animal -- in
`animal studies of IOP reduction with
`prostaglandin analogs?
` A. No.
` Q. So, after 1985, have you studied
`animal models of IOP reduction with respect to
`prostaglandin analogs?
` MR. TAN: Objection to form.
` THE WITNESS: I would need to refer
`to my CV to find out the publication date and
`to refresh my memory as to when my animal
`studies were conducted.
` BY MR. YAKOB:
` Q. But other than that one paper by
`Lee, which I will show you in a minute, you did
`not publish any other papers on animal studies
`of IOP reduction with prostaglandin analogs,
`correct?
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` MR. TAN: Objection to form.
` THE WITNESS: That's correct.
` BY MR. YAKOB:
` Q. Okay. Have you consulted with
`pharmaceutical companies -- starting with the
`broad question.
` Have you ever consulted with
`pharmaceutical companies?
` A. Can you be more specific in your
`question?
` Q. Sure. Yeah.
` Have you consulted for
`pharmaceutical companies to select a lead
`prostaglandin analog compound?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB: As promised, I am
`going to mark as Exhibit 2024 a paper titled
`"Pharmacological Testing In The Laser-Induced
`Monkey Glaucoma Model" with the first author
`Ping-Yu Lee published in 1985.
` (Deposition Exhibit No. 2024 was
`marked for identification.)
` MR. TAN: What was the exhibit
`number?
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` MR. YAKOB: 2024.
` BY MR. YAKOB:
` Q. Dr. Rose, do you recognize Exhibit
`2024?
` A. Yes, I do.
` Q. And are you a coauthor of Exhibit
`2024?
` A. I am.
` Q. Is Exhibit 2024 the Lee 1985 paper
`that you testified about earlier in which you
`studied an animal model of IOP reduction
`within -- with respect to prostaglandin
`analogs?
` A. Yes.
` Q. Does Exhibit 2024 report on a
`laser-induced monkey glaucoma model?
` A. It does.
` Q. Were you in medical school when the
`studies of Exhibit 2024 were conducted?
` A. Yes.
` Q. And can you confirm that Exhibit
`2024 was published in 1985?
` A. Yes, I can confirm that.
` Q. What was your contribution to the
`studies of Exhibit 2024?
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` MR. TAN: Objection to form.
` THE WITNESS: I took part in the
`creation of the glaucoma model and the
`measurements of intraocular pressure.
` BY MR. YAKOB:
` Q. Did anyone else contribute to the
`creation of the glaucoma model?
` A. Yes.
` Q. Who else -- which of the other
`authors contributed to the creation of the
`glaucoma model?
` A. My answer would represent a best
`guess as 1985 as certainly many years ago.
` Q. Sorry.
` Are you thinking or can you answer
`as to who contributed to the creation of the
`glaucoma model?
` A. I'm happy to give you an answer, but
`it represents my best recollection.
` Q. To the best of your recollection,
`who -- which of the other named authors
`contributed to the creation of the glaucoma
`model?
` A. Julia Howard Williams and Marc J.
`Siegel.
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` Q. Marc Siegel -- sorry. Strike that.
` Was Marc Siegel a professor at the
`time?
` A. No.
` Q. What was his title as of 1985?
` A. I can't say with certainty.
` Q. Was he a lab -- was Marc Siegel a
`lab head?
` MR. TAN: Objection to form.
` THE WITNESS: No.
` BY MR. YAKOB:
` Q. Was there a lab or labs that were --
`sorry.
` In what lab were the studies
`reported in Exhibit 2024 conducted?
` MR. TAN: Objection to form.
` THE WITNESS: Are you asking me
`under whose name the lab was run.
` BY MR. YAKOB:
` Q. Yes.
` A. Dr. Steven M. Podos.
` Q. Okay. And Dr. Podos is the second
`named author on the paper, correct?
` A. That's correct.
` Q. Was Marc Siegel a member of the
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`Podos lab?
` A. I believe so.
` Q. Do you recall if he was a post-doc
`in Marc Siegel's lab -- sorry. Strike that.
` Do you recall if Marc Siegel was a
`post-doc in the Podos lab?
` A. I'm not able to answer that
`question.
` Q. Do you recall Marc Siegel's title at
`that time?
` A. He had a medical degree, but I am
`unaware of a specific title.
` Q. Okay. Julia Williams, did she have
`a medical degree?
` A. To the best of my recollection.
` Q. Was Julia Williams also a member of
`the Podos lab?
` A. Yes.
` Q. Were all of the authors, including
`yourself, members of the Podos lab?
` A. Yes.
` Q. When you testified that you were
`involved in the creation of the glaucoma model,
`what was your specific contribution to the
`creation of the glaucoma model?
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` MR. TAN: Objection to form.
` THE WITNESS: I would like to make a
`clarification to my previous answer.
` BY MR. YAKOB:
` Q. Sure.
` A. I helped induce glaucoma in the
`monkey subject, but was not a contributor to
`the concept of the mon- -- of the animal model.
` Q. Okay. Did you handle the monkeys
`that were studied in Lee 19 -- sorry. Strike
`that.
` Did you handle the monkeys that were
`studied in Exhibit 2024.
` A. Can you be more specific about the
`word "handle"?
` Q. Did you physically handle the
`monkeys at all in the studies reported in
`Exhibit 2024?
` MR. TAN: Objection to form.
` THE WITNESS: As rarely as possible.
` BY MR. YAKOB:
` Q. Who -- sorry.
` Did Dr. Podos supervise the studies
`that were reported in Exhibit 2024?
` A. Yes.
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` Q. Was there anyone else that
`supervised the studies reported in Exhibit
`2024?
` A. I'm not clear as to the use of the
`word "supervised."
` Q. Was there anyone else -- sorry.
`Strike that.
` Did Dr. Podos come up with the
`concept of the glaucoma mod
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