`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney
`Ridgway Brady
`
`Date: April 27, 2018
`Case: Pfizer, Inc. -v- Genentech, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
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`WORLDWIDE COURT REPORTING | INTERPRETATION | TRIAL SERVICES
`
`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 1
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`

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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
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`1 (1 to 4)
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` A P P E A R A N C E S
`ON BEHALF OF PETITIONER PFIZER, INC.:
` BENJAMIN LASKY, ESQUIRE
` SHARICK NAQI, ESQUIRE
` KIRKLAND & ELLIS, LLP
` 601 Lexington Avenue
` New York, New York 10022
` (212) 446-6415
`ON BEHALF OF PETITIONER CELLTRION:
` LINNEA P. CIPRIANO, ESQUIRE
` (Via videoconference)
` GOODWIN PROCTER LLP
` 620 Eighth Avenue
` New York, New York 10019
` (212) 813-8800
`ON BEHALF OF PATENT OWNER GENENTECH, INC.:
` ANDREW J. DANFORD, ESQUIRE
` NORA Q.E. PASSAMANECK, ESQUIRE
` WILMER CUTLER PICKERING HALE AND DORR, LLP
` 60 State Street
` Boston, Massachusetts 02109
` (617) 526-6022
`ALSO PRESENT:
` Joseph A. Mourgos, Videographer
` Traci Ropp, Genentech
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` -----------------------------------
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` -----------------------------------
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` PFIZER, INC. and SAMSUNG BIOEPIS CO., LTD.,
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` Petitioner,
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` v.
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` GENENTECH, INC.,
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` Patent Owner.
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`1 2 3 4 5 6 7 8 9 1
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` Case Nos. IPR2017-01488, IPR2017-01489
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` CELLTRION, INC.,
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` Petitioner,
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` v.
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` GENENTECH, INC.,
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` Patent Owner.
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` -----------------------------------
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` Case Nos. IPR2017-01373, IPR2017-01374
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`
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` ** CONFIDENTIAL - UNDER PROTECTIVE ORDER **
`
`VIDEOTAPED DEPOSITION OF JOHN BARNEY RIDGWAY BRADY
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` San Francisco, California
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` Friday, April 27, 2018
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` 5:00 p.m.
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` I N D E X
` WITNESS PAGE
` JOHN BARNEY RIDGWAY BRADY
` Examination by Mr. Lasky 6
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` I N D E X O F E X H I B I T S
` EXHIBITS DESCRIPTION PAGE
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` PREVIOUSLY MARKED EXHIBITS
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` EXHIBIT DESCRIPTION PAGE
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`Exhibit 2005 Copy of laboratory notebook 14
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` number 10840
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`Exhibit 2006 Copy of laboratory notebook 14
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` number 11162
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`Exhibit 2018 Declaration of John Ridgway Brady 6
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` in Case IPR2017-01488
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`Exhibit 2018 Declaration of John Ridgway Brady 6
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` in Case IPR2017-01489
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`Exhibit 2020 Article "Humanization of an 11
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` anti-pl85HER2 antibody for human
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` cancer therapy"
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`PLANET DEPOS
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`Job No.: 186256
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`Pages: 1 - 35
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`Reported By: Charlotte Lacey, RPR, CSR No. 14224
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` VIDEOTAPED DEPOSITION OF JOHN BARNEY RIDGWAY BRADY,
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`held at the offices of DURIE TANGRI, 217 Leidesdorff
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`Street, San Francisco, California
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` Pursuant to notice, before Charlotte Lacey,
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 2
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`

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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
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` A I see that they are declarations. I don't
`know what the difference between the two of them are.
` Q Okay. Well, that was going to be my next
`question.
` A Okay.
` Q How many declarations have you prepared for
`proceedings regarding the '213 patent?
` And when I say different declarations I'm
`not -- I'm not referring to, kind of, differences in the
`proceeding number. I'm talking about difference in
`substance.
` A One.
` Q Okay.
` And so to the extent that declarations were
`submitted from you in multiple proceedings involving
`Pfizer and Celltrion, they would be copies of the same
`declaration?
` A They -- they should be.
` Q Okay.
` And the declarations that -- sorry. Strike
`that.
` The declaration that you prepared is intended
`to describe your role in the project of humanizing 4D5
`antibody that was initiated by Dr. Leonard Presta and
`Dr. Paul Carter; is that right?
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` P R O C E E D I N G S
` THE VIDEOGRAPHER: Here begins video number 1
`in the videotaped deposition of John R. Brady in the
`matter of Pfizer Incorporated, et al., versus Genentech
`Incorporated, IPR numbers 2017-01488 and 01489 and
`Celltrion versus Genentech -- I got that -- yeah -- IPR
`numbers 2017-01373 and 01374 in the United States Patent
`and Trademark Office before the Patent Trial and Appeal
`Board.
` Today's date is April 27th, 2018. The time on
`the video monitor is 5:01 p.m. The videographer today
`is Joseph Mourgos representing Planet Depos. This video
`deposition is taking place at 217 Leidesdorff Street,
`San Francisco, California.
` Would counsel please voice identify yourselves
`and state whom you represent.
` MR. LASKY: My name is Ben Lasky. I'm from
`Kirkland & Ellis representing Pfizer in this proceeding.
`With me today is my colleague, also from Kirkland &
`Ellis, Sharick Naqi.
` MR. DANFORD: Andrew Danford of WilmerHale.
`I'm representing Genentech and the witness, and I'm
`joined today by Nora Passamaneck of WilmerHale and Traci
`Ropp of Genentech.
` THE VIDEOGRAPHER: And on the telephone, we
`6
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` A That's correct.
` Q Now, did you review your declaration again in
`preparation for this deposition?
` A Yeah.
` Q Was there anything in there that you saw was
`incorrect?
` A No.
` Q Is there anything in there that you saw that
`you would change if you could write it again today?
` A No.
` Q Now, the first -- well, strike that.
` In paragraphs 13 through 24 of your
`declaration --
` A Uh-huh.
` Q -- you have a section titled, "My work on
`humanized 4D5 antibodies."
` Do you see that?
` A Right. Right.
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`have:
` MS. CIPRIANO: Linnea Cipriano, Goodwin
`Procter, representing Celltrion.
` THE VIDEOGRAPHER: Thank you. The court
`reporter is Charlotte Lacey representing Planet Depos.
` Would the reporter please administer the oath.
` JOHN BARNEY RIDGWAY BRADY,
`the witness herein, having been first duly sworn, was
`examined and testified as follows:
` EXAMINATION
`BY MR. LASKY:
` Q Good afternoon, Mr. Brady.
` A Good afternoon.
` Q Could you please state your full name for the
`record.
` A John Barney Ridgway Brady.
` Q And what is your current title at Genentech?
` A Senior scientific researcher.
` Q And in 1990, what was your title at Genentech?
` A It may have been senior research associate.
` Q I'm going to hand you two documents. The
`first document has been marked as Exhibit 2018 in
`IPR2017-01488, and the other one has been marked as
`Exhibit 2018 in IPR2017-01489.
` Have you seen these documents before?
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 3
`
`

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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`9
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`3 (9 to 12)
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` Q Let's see. In paragraph 5 of your
`declaration, you refer to a research paper,
`"Humanization of the anti-p185 antibody for human cancer
`therapy," published in the Proceedings of the National
`Academy of Sciences --
` A Uh-huh.
` Q -- in May 1992.
` Do you see that?
` A Yes.
` Q I've handed you a copy of what is marked as
`Genentech Exhibit 2020. It's -- is this a copy of the
`paper that's referred to in paragraph 5 of your
`declaration?
` A Yes.
` Q And you are listed as a coauthor.
` A Right.
` Q Is that right?
` A Right.
` Q What was your contribution to this paper?
` A Expression and purification of the -- some of
`the variants.
` Q So did you contribute to writing any of the
`paper?
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` A No. No. They may have asked me. I don't
`remember the details. They may have asked me for a
`brief summary of a protocol for purification, but I
`don't really, actually remember whether I -- whether
`they did or not. But that would have been the extent of
`it.
` Q Okay.
` And so in terms of expression and
`purification, that's again, referring to your having
`expressed and purified protein from the vectors that
`Dr. Carter had gave you; is that right?
` A Correct.
` Q Now, you state in paragraph 6 that, "The
`purpose of this work was to develop a humanized 4D5
`antibody for use as a human therapeutic to treat cancers
`overexpressing p185HER2."
` Do you see that?
` A Uh-huh, yeah.
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 4
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`

`

`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`13
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`4 (13 to 16)
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` Can you confirm that?
` A Okay.
` Q And then --
` A Okay. Got it. Yes.
` Q And then Exhibit 2006 is 11162.
` A Good. Okay.
` Q Do you want to just check the number --
` A Yeah.
` Q -- the second one?
` A Yeah. So I like them in sequential order.
`There we go. I got it.
` Q Okay.
` A Yeah. That looks good.
` Q Okay.
` And so these two notebooks detail the
`experiments you performed as part of the 4D5
`humanization project?
` A Yes.
` Q Are there any other notebooks that you have
`containing that any experiments relating to that
`project?
` A No.
` MR. DANFORD: Objection to form.
` Q Do you still have these notebooks in your
`possession at Genentech?
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` Q Now, you indicate that your work -- and this
`is in paragraphs 8 through 12 of your declaration. You
`
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`indicate that your work on the humanized 4D5 antibodies
`was documented in laboratory notebooks you maintained.
` Do you see that?
` A Yes.
` Q And then you refer to two notebooks,
`notebook 10840 and notebook 11162.
` Do you see that?
` A Yes. Okay.
` Q Handing you copies of --
` A Okay.
` Q -- two documents.
` A Sure.
` Q One is marked as Exhibit 2005 in IPR 1488, and
`it is a copy of notebook 10840. And the other is
`Genentech Exhibit 2006 in IPR2017-01488, and it is
`notebook number 11162.
` A Okay. So -- so this 11162 is number 5 or 6?
` Q Okay. As -- as indicated in your
`declaration --
` A Okay.
` Q -- you can check it --
` A Okay.
` Q -- Exhibit 2005 --
` A Okay.
` Q -- is 10840.
`
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` A Yes.
` Q Okay.
` And so at some point, someone came and copied
`them for purposes of this proceeding; is that right?
` MR. DANFORD: Objection to form.
` A They were scanned a long time ago.
` Q When you say, "scanned a long time ago," when
`was that?
` A I -- it's -- it's been many years.
` Q Okay.
`0
` A I don't know exactly when, but...
`11
` Q Do you know if they were copied again recently
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`for these proceedings?
`13
` A I don't -- no. I don't know.
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` Q Is that possible --
`15
` A But it may be the case that they were scanned
`16
`March 1991, but I -- I can't be certain of that.
`17
` Oh, there's a date here. '91. 12/23/1991,
`18
`they were scanned.
`19
` Q Okay.
`20
` But do you know that the version that was
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`produced here in these proceedings is the version that
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`was scanned in 1991 or a copy of the -- hard copy
`23
`version that you have in your --
`24
` A They should be one and the same. I have not
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 5
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`

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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`17
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`altered my notebooks since they were scanned.
` Q And I understand that. I'm just --
` A Yeah. Yeah. Yeah. Okay.
` Q I'm trying to understand the process by which
`we received them --
` A Okay.
` Q And how they got from your possession into our
`possession.
` A Okay.
` Q Whether they were copied again recently.
` Is that possible?
` A I would not know.
` Q Okay.
` MR. DANFORD: Since these are exhibits now,
`I'm going to designate the transcript as confidential
`under the protective order.
` Q Now, have you seen microfilm notebooks?
` MR. DANFORD: Objection to form.
` A I -- I'm not sure. I don't think so. Have I
`seen microfilm? I've seen microfilm in the library,
`like, ages ago maybe but...
` Q And do these copies that you have before you
`Exhibits 2005, 2006, look to you like they were
`microfilmed? Or would you not know?
` A I wouldn't know. This is just photocopy, as
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`in there at the moment?
` A I don't know. 25 or so, maybe 30.
` Q Okay.
` Now, in paragraph 11, you go through the
`procedures that you are expected to follow as a
`Genentech researcher, right?
` A Yes.
` Q And one of the things you were expected to do
`is to record experiments in realtime, providing the date
`of the experiment at the top left-hand corner, followed
`by a brief description of the protocol and results,
`right?
` A Yeah.
` Q And do you understand why you were expected to
`do that at the time?
` A Yes.
` Q And why is that?
` A Legal reasons. They, you know, made it clear
`to us that this was a legal document and that we were --
`do our best to keep it current and record the date while
`we were doing the experiments.
` Q Okay. And then the next sentence of
`paragraph 11 states, "After an experiment was completed,
`I further dated and signed the page in the lower
`right-hand corner and obtained the signature of a
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`far as I can tell. It does say microfilmed here, so --
`in '91. So...
` Q Right. But that stamp there is also on the
`hard-copy version that you have in your office, right?
` A Yes. Yes.
`
`
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`witness."
` Do you see that?
` A Yes.
` Q Why did you obtain the signature of a witness?
` A I guess so that somebody could corroborate it.
`Legal wanted that to happen, and so we -- we did our
`best to get that done at some point. But it was
`something that was not done immediately or on a daily
`basis.
` Q Okay.
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` Q And it wasn't necessarily done by someone who
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` Q Now, other than when they were microfilmed,
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` MR. DANFORD: Objection to form.
`were these notebooks ever out of your possession?
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` A No. It was always done by someone who was in
` A I don't think so. No. I have had them in my
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`office the whole time.
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`on occasion, describe my work and so they were familiar.
` Q Okay.
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` Q It's not someone who had independent knowledge
` Where are they in your office?
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` A They are in a cabinet above my desk, which --
`that you performed the experiment that you stated on the
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`which I have other, you know, it's under lock and key,
`date that you have on the experiment, right?
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`and I have all my notebooks in there from the past.
` MR. DANFORD: Objection to form.
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` A Yeah, I don't -- you know, I mean, they were
` Q Okay.
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`done with -- they were -- they were witnessed by my
` How many are -- how many notebooks do you have
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`21
`coworkers who were in the same lab. They didn't know
`exactly what I was doing every day 'cause we were all
`doing our own thing to some degree, but they were
`familiar.
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 8
`
`

`

`8 (29 to 32)
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`31
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`29
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` MR. LASKY: Okay. I have nothing further.
`24
`Thank you very much.
`25
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 9
`
`

`

`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`33
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` THE WITNESS: Oh, great. Thank you. Okay.
` MR. DANFORD: I have nothing.
` MR. LASKY: We're done.
` THE VIDEOGRAPHER: Okay. This marks the end
`of disc number 1 and today's testimony of John R. Brady.
`We are off the record at 5:57 p.m.
` (The deposition concluded at 5:57 p.m.)
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`9 (33 to 36)
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`35
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` IN WITNESS WHEREOF, I have hereunto set my
`hand this 2nd day of May, 2018.
`
`
` __________________________________
` Charlotte Lacey, RPR, CSR #14224
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`34
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` CERTIFICATE OF SHORTHAND REPORTER
` I, Charlotte Lacey, Certified Reporter within
`and for the State of California do hereby certify:
` That JOHN BARNEY RIDGWAY BRADY, the witness
`whose deposition is hereinbefore set forth, was duly
`sworn by me before the commencement of such deposition
`and that such deposition was taken before me and is a
`true record of the testimony given by such witness.
` I further certify that the adverse party,
`GENENTECH, INC., was represented by counsel at the
`deposition.
` I further certify that the deposition of JOHN
`BARNEY RIDGWAY BRADY occurred at the offices of DURIE
`TANGRI, 217 Leidesdorff Street, San Francisco,
`California, on Friday, April 27, 2018, commencing at
`5:00 p.m. to 5:57 p.m.
` I further certify that I am not related to any
`of the parties to this action by blood or marriage, that
`I am not employed by or an attorney to any of the
`parties to this action, and that I am in no way
`interested, financially or otherwise, in the outcome of
`this matter.
`
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`
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 10
`
`

`

`10
`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`13:9, 13:12,
`13:14, 13:16,
`13:21, 13:23,
`21:20, 23:15,
`23:19, 23:20,
`23:21, 23:22,
`24:2, 24:12,
`24:15, 24:21,
`24:22, 26:5,
`28:9, 28:17,
`30:5, 30:11,
`30:17, 31:12,
`31:17, 31:19,
`31:22, 32:21
`antigen
`32:18
`antiproliferation
`26:17
`any
`11:24, 15:19,
`15:20, 31:18,
`31:25, 32:1,
`32:2, 32:19,
`32:20, 34:17,
`34:19
`anything
`8:5, 8:8
`appeal
`1:3, 5:8
`applied
`28:18, 31:4
`april
`1:24, 5:10,
`34:15
`article
`4:21asked
`12:1, 12:2,
`29:25
`assay
`22:14, 25:25,
`26:3, 26:9,
`26:15, 26:16,
`26:18, 26:20,
`27:8, 27:15,
`28:1, 28:3,
`28:12, 28:18,
`29:17, 29:24,
`
`ago
`16:6, 16:7,
`17:21
`ahead
`23:11
`al
`5:4all
`18:23, 21:2,
`26:20, 30:17
`already
`9:3, 9:9
`also
`3:23, 5:19,
`9:25, 18:3,
`24:20
`altered
`17:1always
`20:17
`amino
`31:13
`amount
`27:17, 31:15
`analysis
`25:20, 31:25
`analyzed
`31:13
`andrew
`3:17, 5:21
`answer
`30:1, 30:2
`answered
`29:25
`anti-p
`11:5anti-plher2
`4:22antibodies
`8:16, 8:22,
`9:2, 9:8, 14:1,
`22:16, 22:19,
`31:9, 32:18
`antibody
`4:22, 7:24,
`9:8, 10:2, 10:8,
`11:5, 12:15,
`12:21, 13:7,
`
`30:5, 30:16,
`30:20, 30:24,
`32:12, 32:13
`assayed
`22:16, 22:17,
`22:18, 22:19
`assays
`22:14, 24:4,
`25:16, 26:3,
`26:15, 26:24,
`27:12, 27:25
`associate
`6:20assumption
`24:17
`attended
`20:18
`attorney
`34:19
`avenue
`3:6, 3:13
`aware
`10:23
`B
`back
`25:12, 32:9
`barney
`1:22, 2:5, 4:3,
`6:7, 6:16, 34:4,
`34:13
`basically
`10:11
`basis
`20:9because
`23:18
`been
`6:8, 6:20,
`6:22, 6:23, 9:9,
`12:5, 16:9,
`31:12
`before
`1:3, 2:12, 5:8,
`6:25, 9:7, 9:19,
`9:20, 17:22,
`34:6, 34:7
`beginning
`21:19
`
`A
`
`ability
`25:20
`about
`7:10, 9:16,
`10:1, 10:18,
`10:19, 18:13,
`31:6, 31:16,
`32:3above
`18:21
`academy
`11:7achieve
`13:7acid
`31:13
`action
`34:18, 34:20
`actual
`27:12
`actually
`12:4, 20:11
`added
`27:18
`adenocarcinoma
`25:22
`administer
`6:6adverse
`34:9affinity
`24:15, 24:18,
`32:14, 32:17,
`32:20, 32:22
`after
`19:23, 29:13
`afternoon
`6:12, 6:13
`again
`8:2, 8:9, 12:9,
`16:12, 17:10,
`29:23
`against
`13:23
`ages
`17:21
`
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`PFIZER and SAMSUNG v. GENENTECH
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`PFIZER EX. 1201, Page 11
`
`

`

`11
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`begins
`5:2behalf
`3:2, 3:9, 3:16
`being
`13:21, 24:25,
`27:18
`believe
`23:14
`ben
`5:17benjamin
`3:3best
`19:20, 20:7
`better
`13:22
`between
`7:2bind
`22:20, 31:10
`binding
`13:13, 22:18,
`24:7, 24:14,
`24:18, 26:24,
`27:14, 27:15,
`27:16, 28:12,
`28:15, 28:16,
`28:17, 29:17,
`29:24, 30:16,
`30:20, 30:23,
`32:14, 32:17,
`32:18, 32:20,
`32:22
`binds
`24:3, 30:17
`bioassay
`25:20, 26:16,
`27:9, 28:6,
`29:21
`bioassayed
`30:12
`bioepis
`1:5biological
`26:18
`blood
`34:18
`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`27:10
`cells
`26:4, 26:10,
`26:19, 27:18,
`31:4celltrion
`1:13, 3:9, 5:6,
`6:3, 7:16
`certain
`16:17, 28:2
`certainly
`28:4certificate
`34:1certified
`2:13, 34:2
`certify
`34:3, 34:9,
`34:12, 34:17
`chains
`9:5, 9:9
`change
`8:9changes
`10:19, 10:24
`characteristics
`13:6, 13:13,
`24:8charlotte
`2:3, 2:12, 6:5,
`34:2, 35:6
`check
`14:21, 15:7
`chimera
`23:2chimeric
`13:12, 23:14,
`23:18, 24:1,
`24:12, 24:18,
`24:21
`cipriano
`3:10, 6:2
`claims
`32:2clear
`19:18
`coat
`31:8
`
`board
`1:3, 5:9
`boston
`3:21both
`27:25
`brady
`1:22, 2:5, 4:3,
`4:17, 4:19, 5:3,
`6:7, 6:12, 6:16,
`32:12, 33:5,
`34:4, 34:13
`brief
`12:3, 19:11
`C
`cabinet
`18:21
`california
`1:23, 2:7,
`2:14, 5:14,
`34:3, 34:15
`came
`10:12, 16:3
`can
`10:18, 14:21,
`15:1, 18:1,
`25:7, 30:1,
`30:2, 31:16,
`32:4can't
`16:17
`cancer
`4:23, 11:5
`cancers
`12:15
`cannot
`28:2carter
`7:25, 9:3, 9:9,
`10:1, 12:11
`case
`1:11, 1:19,
`4:18, 4:20,
`16:16
`cause
`21:2cell
`25:21, 25:22,
`
`coauthor
`11:17
`colleague
`5:19collected
`22:15
`column
`27:22
`combinations
`10:14
`comes
`28:16
`commencement
`34:6commencing
`34:15
`compare
`31:12, 31:14
`compared
`23:2comparison
`23:20
`completed
`19:23
`concentration
`28:7, 28:9,
`28:17, 28:20,
`29:6, 29:13,
`29:20, 30:5,
`30:11, 30:22,
`31:17
`concluded
`33:7conclusion
`31:16
`conducted
`25:1, 25:16,
`28:1conducting
`9:23confidential
`1:21, 17:15
`confirm
`15:1constant
`23:3, 24:14,
`31:11
`containing
`9:4, 15:20
`
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 12
`
`

`

`D
`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`7:14, 7:20
`degree
`21:3depos
`5:12, 6:5
`deposition
`1:22, 2:5, 5:3,
`5:13, 8:3, 33:7,
`34:5, 34:6,
`34:7, 34:11,
`34:12
`derived
`30:23, 31:2
`describe
`7:23, 9:24,
`20:19, 21:19,
`25:16, 26:14,
`26:21, 26:24,
`27:9, 31:18,
`32:19
`described
`22:13, 32:14,
`32:23
`describing
`22:7description
`4:8, 4:12,
`19:11
`designate
`17:15
`designed
`9:9desk
`18:21
`detail
`15:15
`details
`10:4, 12:2
`detect
`31:11
`determine
`28:16, 30:5,
`30:16, 31:22,
`32:1determined
`25:20, 31:14
`develop
`12:14, 13:23
`
`cutler
`3:19
`daily
`20:8danford
`3:17, 5:21,
`8:24, 9:17,
`10:3, 10:9,
`15:23, 16:5,
`17:14, 17:18,
`20:16, 20:23,
`21:13, 24:16,
`24:24, 25:2,
`26:1, 28:14,
`29:18, 29:25,
`30:2, 30:18,
`32:5, 32:16,
`33:2data
`22:12, 22:13,
`22:15, 27:11
`date
`5:10, 16:18,
`18:7, 18:9,
`19:9, 19:20,
`20:22
`dated
`19:24
`dates
`18:8day
`21:2, 35:2
`december
`18:11
`declaration
`4:17, 4:19,
`7:17, 7:22, 8:2,
`8:13, 9:25,
`11:4, 11:15,
`13:25, 14:19,
`21:6, 21:18,
`26:14, 26:22,
`27:2, 27:9,
`27:12, 32:19
`declarations
`7:1, 7:6, 7:8,
`
`12
`
`did
`8:2, 8:22,
`10:4, 10:6,
`11:24, 12:5,
`13:15, 20:4,
`20:6, 25:25,
`26:2didn't
`21:1difference
`7:2, 7:10
`differences
`7:9different
`7:8, 10:13,
`23:1, 31:9,
`32:13, 32:18
`diluted
`29:4, 31:3
`dilution
`29:7, 29:14
`dilutions
`31:10, 31:15
`disc
`33:5dish
`26:4distinction
`30:7dna
`9:4document
`6:22, 19:19
`documented
`14:2documents
`6:21, 6:25,
`14:11
`does
`18:1, 31:7
`doing
`10:25, 13:8,
`19:21, 20:15,
`21:2, 21:3,
`21:11, 21:15
`domain
`31:8don't
`7:1, 12:1,
`
`contribute
`11:24
`contribution
`11:21
`control
`23:7, 24:4,
`25:21, 26:12,
`26:13, 27:22,
`28:20, 31:5
`copied
`16:3, 16:12,
`17:10
`copies
`7:16, 14:9,
`17:22
`copy
`4:13, 4:15,
`11:12, 11:13,
`14:14, 16:23
`corner
`19:10, 19:25
`correct
`8:1, 9:6, 9:14,
`11:2, 12:12,
`21:25, 22:25,
`24:23, 25:17,
`26:11, 26:17,
`26:22, 28:8,
`29:7, 29:15,
`30:14, 31:20
`corresponding
`28:19
`corroborate
`20:5could
`6:14, 8:9,
`20:5, 30:22
`counsel
`5:15, 34:10
`course
`13:18
`court
`6:4coworkers
`21:1csr
`2:3, 35:6
`current
`6:17, 19:20
`
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`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 13
`
`

`

`13
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`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`employed
`experiments
`34:19
`15:16, 15:20,
`end
`19:9, 19:21
`express
`26:6, 33:4
`ensued
`10:14, 21:19
`expressed
`25:11, 32:8
`equal
`12:10, 21:24
`expressing
`26:4esquire
`10:25, 21:11,
`22:16
`3:3, 3:4, 3:10,
`expression
`3:17, 3:18
`et
`11:22, 12:8,
`22:7extent
`5:4ever
`7:14, 10:23,
`18:16
`every
`12:5extracellular
`21:2evidence
`31:8
`F
`31:1, 31:2
`exactly
`fact
`16:11, 21:2
`26:20
`examination
`familiar
`4:4, 6:10
`20:19, 21:4
`examined
`far
`6:9exhibit
`13:21, 18:1
`february
`4:12, 4:13,
`18:14
`financially
`4:15, 4:17,
`4:19, 4:21,
`34:21
`6:22, 6:24,
`finished
`11:13, 14:13,
`13:2first
`14:15, 14:23,
`15:5, 18:10,
`6:8, 6:22,
`22:6, 32:15
`8:11, 8:19, 9:1,
`exhibits
`31:21
`4:8, 4:11,
`focus
`17:14, 17:23
`13:3, 27:2,
`expect
`27:4follow
`24:12
`expectation
`19:5, 21:15
`24:20
`followed
`expected
`19:10
`19:5, 19:8,
`follows
`19:14
`6:9form
`experiment
`19:10, 19:23,
`8:24, 9:17,
`20:21, 20:22,
`10:3, 10:9,
`21:19
`
`15:23, 16:5,
`17:18, 20:16,
`20:23, 21:13,
`24:16, 24:24,
`25:2, 26:1,
`28:14, 29:18,
`30:18, 32:16
`forth
`34:5four
`29:4framework
`10:7, 10:20
`francisco
`1:23, 2:7,
`5:14, 34:14
`friday
`1:24, 34:15
`from
`5:17, 5:19,
`7:15, 12:10,
`17:7, 18:7,
`18:23, 22:15,
`22:16, 24:4,
`25:11, 26:2,
`27:13, 27:25,
`28:16, 29:6,
`29:16, 30:23,
`32:8, 32:13,
`32:18
`full
`6:14, 24:2,
`24:19
`fully
`13:22, 24:19
`further
`19:24, 29:14,
`31:3, 32:24,
`34:9, 34:12,
`34:17
`G
`gave
`12:11
`genentech
`1:8, 1:16,
`3:16, 3:25, 5:4,
`5:6, 5:22, 5:24,
`
`12:4, 16:11,
`16:14, 17:19,
`18:17, 19:2,
`20:24, 26:23,
`30:3, 30:6,
`31:1, 31:18,
`32:3, 32:19
`done
`9:16, 20:7,
`20:8, 20:11,
`20:14, 20:17,
`20:25, 26:9,
`26:15, 30:16,
`31:22, 33:3
`dorr
`3:19dr
`7:24, 7:25,
`9:3, 9:9, 9:10,
`10:1, 12:11
`draw
`30:7, 31:16
`duly
`6:8, 34:5
`durie
`2:6, 34:13
`during
`9:25
`E
`each
`25:20, 29:13
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`27:25
`ecb
`22:20
`eighth
`3:13elisa
`22:18, 27:15,
`27:16, 28:16,
`29:16, 29:24,
`31:3, 31:6,
`32:12, 32:13
`elisas
`28:5ellis
`3:5, 5:18, 5:20
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`PFIZER and SAMSUNG v. GENENTECH
`IPR2017-01488
`PFIZER EX. 1201, Page 14
`
`

`

`6:17, 6:19,
`11:13, 14:15,
`15:25, 19:6,
`34:10
`general
`12:22
`germane
`30:25
`get
`20:7, 24:3,
`30:12, 30:22
`gist
`12:22
`given
`34:8gives
`24:5go
`15:11, 19:4,
`23:11, 25:7,
`32:4going
`6:21, 7:3,
`13:20, 17:15
`good
`6:12, 6:13,
`15:6, 15:13,
`23:20
`goodwin
`3:12, 6:2
`got
`5:6, 9:19,
`9:20, 15:4,
`15:11, 17:7,
`31:4, 31:5
`gotcha
`29:10
`great
`33:1growth
`26:7, 26:10,
`26:11, 27:10
`guess
`20:5, 30:3,
`30:6guide
`21:15
`H
`had
`9:9, 10:1,
`
`14
`
`CONFIDENTIAL - UNDER PROTECTIVE ORDER
`Transcript of John Barney Ridgway Brady
`Conducted on April 27, 2018
`heavy
`10:7, 12:11,
`13:10, 13:14,
`9:5, 9:8
`held
`18:17, 20:15,
`20:20, 26:3
`2:6her2
`hale
`3:19hand
`22:18, 22:20,
`24:3, 26:24,
`6:21, 35:2
`27:13, 27:16,
`handed
`28:16, 28:18,
`11:12
`31:8here
`handing
`14:9happen
`5:2, 10:18,
`16:18, 16:22,
`18:1, 27:11,
`20:6hard
`32:23
`hereby
`16:23, 27:14,
`34:3herein
`27:23
`hard-copy
`6:8hereinbefore
`18:4has
`34:5hereunto
`6:22, 6:23,
`23:19, 24:2,
`31:12
`35:1how
`have
`6:1, 6:20,
`7:6, 9:16,
`6:25, 7:6, 8:15,
`10:1, 10:4,
`12:1, 12:2,
`17:7, 18:25,
`12:5, 13:13,
`25:25, 30:16
`however
`15:19, 15:24,
`16:24, 16:25,
`10:12
`human
`17:17, 17:19,
`17:22, 18:4,
`4:22, 11:5,
`18:7, 18:17,
`12:15, 13:10,
`18:22, 18:23,
`13:16, 13:21,
`18:25, 20:22,
`13:22, 22:17,
`21:5, 24:7,
`23:3, 24:14,
`24:14, 24:18,
`25:21
`humanization
`27:21, 28:4,
`28:19, 29:6,
`4:21, 11:5,
`30:12, 31:17,
`15:17, 24:25
`humanize
`32:24, 33:2,
`35:1haven't
`9:2, 9:8
`humanized
`31:25
`8:16, 8:22,
`having
`9:4, 10:2,
`6:8, 12:9,
`12:14, 13:7,
`24:20, 30:15
`14:1, 21:20,
`heard
`23:21, 24:5,
`20:18
`
`32:1humanizing
`7:23, 10:7
`humans
`31:19, 31:23
`hybridoma
`24:19
`I
`i've
`11:12, 17:20
`identify
`5:15, 26:16
`idg
`22:17
`immediately
`20:8immune
`13:23
`immunogenicity
`24:21, 31