UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`PFIZER, INC.,
`Petitioner,
`
`v.
`
`GENENTECH, INC.,
`Patent Owner,
`____________
`
`Case IPR2017-01488
`Patent 6,407,213 B2
`____________
`
`DECLARATION OF SARAH K. TSOU IN SUPPORT OF
`PETITIONER’S MOTION FOR THE PRO HAC VICE ADMISSION
`
`
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`PFIZER, INC.,
`Petitioner,
`
`v.
`
`GENENTECH, INC.,
`Patent Owner,
`____________
`
`Case IPR2017-01488
`Patent 6,407,213 B2
`____________
`
`DECLARATION OF SARAH K. TSOU IN SUPPORT OF
`PETITIONER’S MOTION FOR THE PRO HAC VICE ADMISSION
`
`
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Sarah K. Tsou in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Sarah K. Tsou
`
`I, Sarah K. Tsou, do hereby declare:
`
`1.
`
`I am a Partner at the law firm of Kirkland & Ellis LLP (“Kirkland”).
`
`Lead counsel in the inter partes review proceeding is Amanda Hollis, a Partner at
`
`Kirkland, who is registered to practice before the USPTO and holds Registration No.
`
`55,629. Backup counsel are: (1) Stefan Miller, a Partner at Kirkland, who is
`
`registered to practice before the USPTO and holds Registration No. 57,623; and (2)
`
`Karen Younkins, an Associate at Kirkland, who is registered to practice before the
`
`USPTO and holds Registration No. 67,554. With respect to this proceeding, I will
`
`work closely with Ms. Hollis, Mr. Miller, and Ms. Younkins.
`
`2.
`
`I hold Bachelor of Arts degrees in Biology and Psychology from
`
`Washington University and a Doctor of Jurisprudence degree in Law from New
`
`York University School of Law.
`
`3.
`
`I have approximately ten years of experience as a litigation attorney
`
`specializing in patent litigation and representing clients in patent litigation matters
`
`in various United States District Courts. I also have experience working on inter
`
`partes review proceedings. My experience includes numerous matters in the life
`
`sciences and pharmaceuticals arts. I have particular experience relevant to the
`
`technological and legal matters at issue in this proceeding, including matters
`
`concerning pharmaceutical and biotechnology. I represent Pfizer, Inc. (“Petitioner”)
`
`in a number of related matters. I am, therefore, an experienced patent litigation
`
`1
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Sarah K. Tsou in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Sarah K. Tsou
`
`attorney with particular expertise that is pertinent to this proceeding. Petitioner
`
`desires, and has a need, to be represented in certain aspects of this proceeding by an
`
`experienced patent litigation attorney who has particular expertise that is relevant to
`
`the issues in this proceeding.
`
`4.
`
`I am very familiar with U.S. Patent No. 6,407,213, as well as the legal
`
`subject matter, technical subject matter, and prior art discussed in the Petition for
`
`Inter Partes Review of U.S. Patent No. 6,407,213, which forms the basis for this
`
`proceeding. I have personally reviewed the patent at issue, as well as the prosecution
`
`history, submissions filed in this proceeding, and accompanying declarations and
`
`exhibits. I have been and continue to be involved in the strategic, factual, and
`
`technical aspects of this matter.
`
`5.
`
`I am a member in good standing of the Bar of the State of New York
`
`and am admitted to practice before the United States District Court for the Southern
`
`District of New York.
`
`6.
`
`I have never been suspended or disbarred from practice before any court
`
`or administrative body.
`
`7.
`
`I have never had a court or administrative body deny my application for
`
`admission to practice.
`
`8.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`2
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Sarah K. Tsou in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Sarah K. Tsou
`
`9.
`
`I have read and will comply with the Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`10.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et. seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`11.
`
`I have been admitted pro hac vice as counsel in the following
`
`proceedings before the United States Patent and Trademark Office:
`
`• IPR2017-00804 and IPR2017-00805 as counsel for Hospira, Inc.
`
`concerning dosages for treatment with anti-ErbB2 antibodies.
`
`• IPR2017-00737 as counsel for Hospira, Inc. concerning treatment
`
`with anti-ErbB2 antibodies.
`
`12.
`
`I declare that all statements made herein of my own knowledge are true
`
`and that all statements made on information and belief are believed to be true, and
`
`further that these statements were made with the knowledge that willful, false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`3
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Sarah K. Tsou in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Sarah K. Tsou
`
`
`
`Date: November 2, 2017
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /Sarah K. Tsou/
`Sarah K. Tsou
`Kirkland & Ellis LLP
`601 Lexington Avenue
`New York, NY 10022
`Telephone: (212) 446-6435
`Facsimile: (212) 446-4900
`sarah.tsou@kirkland.com
`
`4
`
`PFIZER EX. 1189
`Pfizer v. Genentech
`IPR2017-01488
`
`
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