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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`WATSON LABORATORIES, INC.,
`Petitioner,
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`v.
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`UNITED THERAPEUTICS CORP.
`Patent Owner.
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`Case No. IPR2017-01621
`Patent No. 9,358,240
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`Case No: PR2017-01622
`Patent No. 9,339,507
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`DECLARATION OF KURT A. MATHAS IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313-1450
`Submitted Electronically via the Patent Review Processing System
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`WATSON LABORATORIES, INC. , IPR2017-01622, Ex. 1167, p. 1 of 4
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`Pursuant to 37 C.F.R. § 1.68, I, Kurt A. Mathas, attest to the following:
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`1. I am a member in good standing of the Illinois Bar, as well as the bars
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`of the following Federal and State Courts:
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`a. United States Court of Appeals for the Federal Circuit;
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`b. United States Court of Appeals for the Seventh Circuit;
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`c. United States Court for the Northern District of Illinois;
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`d. United States Court for the Eastern District of Texas;
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`e. United States Court for the District of Colorado; and
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`f. United States District Court for the Western District of Michigan.
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`2. I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`3. I have never had an application for admission to practice before any
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`court or administrative body denied.
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`4. I have never had sanctions or contempt citations imposed by any court
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`or administrative body imposed against me.
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`5. 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.
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`6. I will be subject to the USPTO Code of Professional Responsibility set
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`forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`WATSON LABORATORIES, INC. , IPR2017-01622, Ex. 1167, p. 2 of 4
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`7. I am concurrently seeking pro hac vice admission in IPR2017-01621
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`related to U.S. Patent No. 9,358,240 and IPR2017-01622 related to U.S. Patent No.
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`9,339,507. I have not previously applied for pro hac vice admission before the Board
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`in any other matters.
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`8. I am an experienced litigation attorney and have been involved in
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`numerous patent infringement cases in federal courts across the country. I have 12
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`years of litigation experience. I have experience in all aspects of patent infringement
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`matters including up to and including jury trials and bench trials. I have argued in
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`multiple patent cases in federal courts. I serve as trial counsel for Watson
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`Laboratories, Inc. (the petitioner in this proceeding) concerning the patent
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`challenged by the Petition, among others, in district court litigation pending in the
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`District of New Jersey and captioned United Therapeutics Corp. v. Watson
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`Laboratories, Inc., Civil Action No. 3:15-cv-05723-PGS-LHG (D.N.J.). As a result
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`of my involvement as trial counsel for Petitioner in the co-pending district court
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`litigation over the involved patent, I have obtained substantial familiarity with the
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`involved patent, the prior art, and the various issues raised in this proceeding. I have
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`appeared for numerous proceedings before the district court and I have reviewed the
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`Petition, and the cited materials, and am familiar with the subject matter involved in
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`this proceeding. Specifically, I am the outside counsel primarily responsible for the
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`day-to-day management of the district court litigation and have been involved in
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`WATSON LABORATORIES, INC. , IPR2017-01622, Ex. 1167, p. 3 of 4
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`analysis of the prior art and developing and litigating invalidity defenses for the
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`involved patents in the district court action.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Date: January 25, 2018
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` Kurt A. Mathas
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`WATSON LABORATORIES, INC. , IPR2017-01622, Ex. 1167, p. 4 of 4
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