`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`HYPERION THERAPEUTICS, INC.,
`
`Plaintiff,
`
`v.
`
`PAR PHARMACEUTICAL, INC.,
`
`Defendant.
`
`)
`)
`)
`) C.A. No. 2:14-cv-00384-JRG-RSP
`)
`)
`)
`)
`)
`)
`
`PAR PHARMACEUTICAL, INC.’S INITIAL INVALIDITY
`CONTENTIONS AND NON-INFRINGEMENT CONTENTIONS FOR
`U.S. PATENT NOS. 8,404,215 AND 8,642,012
`
`Pursuant to Local Patent Rules 3-3, 3-4, and 3-8 of the Local Rules for the United States
`
`Eastern District of Texas, defendant Par Pharmaceutical, Inc. (“Par”) serves its Initial Invalidity
`
`Contentions and accompanying document production to plaintiff Hyperion Therapeutics, Inc.
`
`(“Hyperion”) for U.S. Patent Nos. 8,404,215 (“the ’215 patent”) and 8,642,012 (“the ’012
`
`patent”) (collectively the “patents-in-suit”).
`
`These contentions are based upon information obtained by Par as of the date of this
`
`document, and Par’s discovery and investigation in connection with this action continues. Par
`
`reserves the right to supplement or amend these contentions based on information learned
`
`through discovery, any claim construction entered by the Court, plaintiffs’ response to Par’s
`
`contentions, and expert discovery. Par incorporates by reference each of the invalidity
`
`contentions articulated in its Detailed Statement of the Factual and Legal Basis for Par
`
`Horizon Exhibit 2043
`Par v. Horizon
`IPR2017-01767
`
`Page 1 of 2
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on November 13, 2014, true and correct copies of the foregoing
`
`document were caused to be served by electronic mail on at the following counsel of record:
`
`Melissa R. Smith
`State Bar No. 24001351
`melissa@gillamsmithlaw.com
`Gillam & Smith, LLP
`303 S. Washington Ave.
`Marshall, Texas 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`
`George F. Pappas (pro hac vice)
`gpappas@cov.com
`Christopher N. Sipes (pro hac vice)
`csipes@cov.com
`Matthew Kudzin (pro hac vice)
`mkudzin@cov.com
`COVINGTON & BURLING LLP
`1201 Pennsylvania Avenue, N.W.
`Washington, D.C. 20004
`Tel: (202) 662-6000
`
` /s/ Harold Storey
`Harold Storey
`Harolds@seedip.com
`
`Page 2 of 2
`
`
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