`____________
`
`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 CHRISTOPHER J. CITRO IN SUPPORT OF
`PETITIONER’S MOTION FOR THE PRO HAC VICE ADMISSION
`
`
`
`PFIZER EX. 1192
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Christopher J. Citro in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Christopher J. Citro
`
`I, Christopher J. Citro, do hereby declare:
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`1.
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`I am an Associate at the law firm Kirkland & Ellis LLP (“Kirkland”).
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`Lead counsel in the inter partes review proceeding is Amanda Hollis, a Partner at
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`Kirkland, who is registered to practice before the PTO and holds Registration No.
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`55,629. Backup counsel are: (1) Stefan Miller, a Partner at Kirkland, who is
`
`registered to practice before the PTO and holds Registration No. 57,623; and (2)
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`Karen Younkins, an Associate at Kirkland, who is registered to practice before the
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`PTO and holds Registration No. 67,554. With respect to the proceeding, I will work
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`closely with Ms. Hollis, Mr. Miller, and Ms. Younkins.
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`2.
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`I hold a Bachelor of Science degree in Chemistry and a Bachelor of
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`Arts degree in Political Science from American University and a Juris Doctor degree
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`from George Washington University Law School.
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`3.
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`I have approximately one year of experience as a litigation attorney
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`specializing in patent litigation and representing clients in patent litigation matters
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`in various United States District Courts. My experience includes several matters in
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`the life sciences and pharmaceuticals arts. I have particular experience relevant to
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`the technological and legal matters at issue in this proceeding, including matters
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`concerning monoclonal antibody therapies and methods of preparing antibodies,
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`including representing Pfizer, Inc. (“Petitioner”) in a number of related matters. I
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`am, therefore, an experienced patent litigation attorney with particular expertise that
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`2
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`PFIZER EX. 1192
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Christopher J. Citro in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Christopher J. Citro
`
`is pertinent to the proceeding. Petitioner desires, and has a need to be represented
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`in certain aspects of this proceeding by an experienced patent litigation attorney who
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`has particular expertise that is relevant to the issues involved.
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`4.
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`I am very familiar with U.S. Patent No. 6,407,213, as well as the legal
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`subject matter, technical subject matter, and prior art discussed in the Request for
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`Inter Partes Review. I have personally reviewed the patent at issue, as well as the
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`prosecution history, submissions filed in this proceeding, and accompanying
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`declarations and exhibits. I have been and continue to be actively involved with
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`strategic, factual, and technical aspects of this matter.
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`5.
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`I am a member in good standing of the Bars of the State of New York
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`and the District of Columbia.
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`6.
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`I have never been suspended or disbarred from practice before any court
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`or administrative body.
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`7.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
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`8.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`9.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`
`
`3
`
`PFIZER EX. 1192
`Pfizer v. Genentech
`IPR2017-01488
`
`
`
`Declaration of Christopher J. Citro in Support of
`Petitioner’s Motion for the Pro Hac Vice Admission of Christopher J. Citro
`
`
`10.
`
`I agree to be subject to the United States Patent and Trademark Office
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`Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et. seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11.
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`I have been admitted pro hac vice as counsel in the following
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`proceedings before the United States Patent and Trademark Office:
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`• IPR2017-00804 and IPR2017-00805 as counsel for Hospira, Inc.
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`concerning dosages for treatment with anti-ErbB2 antibodies.
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`• IPR2017-00737 as counsel for Hospira, Inc. concerning treatment
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`with anti-ErbB2 antibodies.
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`12.
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`I declare that all statements made herein of my own knowledge are true
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`and that all statements made on information and belief are believed to be true, and
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`further that these statements were made with the knowledge that willful, false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Date: November 2, 2017
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`Respectfully submitted,
`
`By: /s/Christopher J. Citro
`Christopher J. Citro
`Kirkland & Ellis LLP
`601 Lexington Avenue
`New York, NY 10022
`Telephone: (212) 909-3141
`Facsimile: (212) 446-4900
`christopher.citro@kirkland.com
`
`4
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`PFIZER EX. 1192
`Pfizer v. Genentech
`IPR2017-01488
`
`