`Filed On Behalf Of:
`West-Ward Pharmaceuticals International Limited
`
` Paper No. 73
`
`By:
`Marta E. Delsignore
`MDelsignore@goodwinlaw.com
`(212) 813-8800
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________
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`WEST-WARD PHARMACEUTICALS INTERNATIONAL LIMITED
`
`Petitioner,
`
`v.
`
`NOVARTIS AG
`
`Patent Owner
`
`Case IPR2017-015921
`
`
`
`Patent No. 8,410,131 B2
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVES
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`
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`1 IPR2018-00507 has been joined to this proceeding and the proceeding has
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`been terminated as to Petitioner Breckenridge Pharmaceutical Inc.
`
`
`
`IPR2017-01592
`Petitioner’s Objections to Demonstratives
`
`
`Petitioner objects to the following demonstratives served by Patent Owner:
`
`1. Slide 19: This slide contains new evidence because the quote from Ex. 2112
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`was not relied on in Patent’s Owner’s Response or Observations.
`
`2. Slides 27, 32, and 38: These slides mischaracterize and take out of context
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`the testimony quoted from Ex. 2093 (which comes from a different proceeding).
`
`The title of Slide 32 also presents new argument that was not included in Patent
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`Owner’s Response.
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`3. Slides 39, 56, 69, and 71: These slides mischaracterize and take out of
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`context the testimony quoted from Ex. 2094 (which comes from a different
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`proceeding). Slide 71 also contains new evidence because the quote from Ex. 2092
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`was not relied on in Patent Owner’s Response.
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`4. Slides 81 and 95: These slides mischaracterize and take out of context the
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`deposition testimony cited from Ex. 2027.
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`5. Slides 99 and 100: These slides contain new evidence because they display
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`a chart from Ex. 2092 that was not relied on in Patent Owner’s Response or
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`Observations.
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`
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`
`
`1
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`
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`Respectfully submitted,
`
`/ Marta E. Delsignore /
`Marta E. Delsignore (Reg. No. 32,689)
`Keith A. Zullow (Reg. No. 37,975)
`Michael Cottler (pro hac vice)
`GOODWIN PROCTER LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018-1405
`Tel: 212-813-8822
`Fax: 646-558-4226
`
`Counsel for Petitioner West-Ward
`Pharmaceuticals International Limited
`
`IPR2017-01592
`Petitioner’s Objections to Demonstratives
`
`
`Dated: September 14, 2018
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`2
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 14th day of September,
`
`2018, a true and correct copy of the foregoing PETITIONER’S OBJECTIONS
`
`TO PATENT OWNER’S DEMONSTRATIVES was served by electronic mail
`
`on Patent Owner’s lead and backup counsel at the following email address:
`
`Nicholas N. Kallas
`Laura K. Fishwick
`Fitzpatrick, Cella, Harper & Scinto
`nkallas@fchs.com
`lfishwick@fchs.com
`ZortressAfinitorIPR@fchs.com
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`Dated: September 14, 2018
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`/ Marta E. Delsignore /
`Marta E. Delsignore
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`
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