`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - - - - - - - -x
`KVK TECH, INC.,
`
`::
`
`Case
`Petitioner, :IPR2018-00290
`:
`:Patent No.
`:8,846,100
`
`- v -
`
`SHIRE PLC,
`
`Patent Owner. :
`- - - - - - - - - - - - - - - - - -x
`:
`KVK TECH, INC.,
`:Case
`Petitioner, :IPR2018-00293
`:
`:Patent No.
`:9,173,857
`:
`:
`Patent Owner. :
`- - - - - - - - - - - - - - - - - -x
`January 17, 2019
`9:48 a.m.
`875 Third Avenue
`New York, New York
`DEPOSITION UPON ORAL EXAMINATION OF
`JAMES E. POLLI, Ph.D., held at the
`above-mentioned time and place, before Randi
`Friedman, a Registered Professional Reporter,
`within and for the State of New York.
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`KVK-TECH EXHIBIT 1046
`
`::
`
`- v -
`
`SHIRE PLC,
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`Page 2
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` J. Polli, Ph.D.
`APPEARANCES:
` LUCAS & MERCANTI, LLP
` Attorneys for Petitioner
`
` 30 Broad Street
` New York, New York 10004
` BY: STEVEN ROTH, ESQ.
` DAVID J. GALLUZZO, ESQ.
`
` TROUTMAN SANDERS LLP
` Attorneys for Patent Owner
` 875 Third Avenue
` New York, New York 10022
`
` BY: JOSEPH R. ROBINSON, ESQ.
` TANYA LEAVY
` * * *
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` J. Polli, Ph.D.
` * * *
` JAMES E. POLLI, Ph.D., the witness
` herein, after first having been duly sworn,
` was examined and testified as follows:
` * * *
` EXAMINATION
`BY MR. ROTH:
` Q Hello, Dr. Polli.
` A Yes, good morning.
` Q I'm Steven Roth, good morning, from
`Lucas & Mercanti, and we represent KVK Tech, Inc.
` Can you please state your full name
`and address?
` A My name is James Edward Polli. My
`address is 12115 Frederick Road, Ellicott City,
`Maryland, E-L-L-I-C-O-T-T City, Maryland, 21042.
` Q You are testifying as an expert for
`the patent owner in connection with two inter
`partes reviews on U.S. Patent Nos. 8,846,100 and
`9,173,857; is that right?
` A Yes, I recognize the last three
`numbers of those two patents, that's right.
` Q And we'll refer to them from here on
`as the '100 patent and the '857 patent; is that
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` J. Polli, Ph.D.
`okay?
` A Yes.
` Q You also submitted a declaration in
`both inter partes reviews which I'll abbreviate,
`IPRs; is that right?
` A That's correct.
` Q And they are substantially identical?
` A I'd say that's fair, yes.
` Q Do you know what ADHD is?
` A Yeah, I think I do.
` Q What is it?
` A Normally I hear it referred to as
`ADHD, but just sitting here now, attention
`deficit hyper-something disorder. I forget what
`the H may exactly stand for.
` Q I'm not 100 percent sure myself.
`Hopefully we'll see a document later that will
`inform us.
` Are you an expert in ADHD?
` A No, I'm not an expert in ADHD.
` Q Have you published in the area?
` A I don't believe so.
` Q Do you know --
` A I'm not sure.
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` J. Polli, Ph.D.
` Q Okay. Do you know what Adderall is?
` A Yes, I do.
` Q It delivers an immediate release of
`amphetamine?
` A Yeah, Adderall is a tradename for a
`product that contains, I think, mixed
`amphetamines I think is -- maybe a little
`slightly more correct. But an amphetamine, so to
`speak.
` Q And it delivers it as an immediate
`release?
` A Yeah, I recall Adderall is an
`immediate release product. That's my
`recollection, yes.
` Q And it's effective for the treatment
`of ADHD?
` A I think so. I mean, if you're asking
`me about the indication in Adderall's prescribing
`information, sitting here, I think so. Maybe I
`just haven't reviewed that particular recently,
`but I would think so, yes.
` Q It provides up to about six hours of
`efficacy for the treatment of ADHD; is that
`right?
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` J. Polli, Ph.D.
` A I mean, do you happen to have the
`package insert for Adderall?
` Q Actually, I don't.
` A Okay. I'd like to answer the
`question. The thing that's going through my mind
`is I think the duration of treatment might be a
`function of dosing. I wasn't sure in your
`question if you had a particular dosing regiment
`in mind.
` Q I don't.
` Do you know what Adderall XR is?
` A Yes, I do.
` Q And are you aware that it consists of
`two bead types containing amphetamine; an
`immediate release bead type and a delayed release
`bead type; is that right?
` A Yes, I'm aware of that.
` Q And it's also effective in treating
`ADHD; is that right?
` A Yes, I do know that it is indicated to
`treat ADHD.
` Q And are you aware that it provides up
`to about 12 hours of efficacy for the treatment
`of ADHD?
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` J. Polli, Ph.D.
` A That's what I recall, yes. I think
`sometimes there's some ranges, but 12 is a number
`that I do remember sitting here now.
` Q Mydayis, are you familiar with
`Mydayis?
` A I think only through these
`proceedings.
` Q Okay. And Mydayis has three bead
`types containing amphetamine, an immediate
`release, a delayed release and a second delayed
`release, with an overcoating of a sustained
`release material; is that right?
` A I'm less familiar, but I do understand
`that from these proceedings, I suppose.
` Q And in your declaration, you've
`referred to the third bead type as a sustained
`release bead type; is that right?
` A Yeah, I'm thinking about the -- for
`example, the '100 patent, I do refer to that as a
`sustained release bead, that's right.
` Q That third bead in Mydayis, the
`so-called sustained release bead, that releases
`amphetamine slower and further along in the
`gastrointestinal tract than the other two beads;
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` J. Polli, Ph.D.
`is that your understanding?
` A You're asking me about Mydayis?
` Q That's correct.
` A I don't remember reviewing the package
`insert for Mydayis; certainly not recently. I'm
`just -- I'm just not sure how Mydayis is
`described.
` Q Okay. So let's look at your
`declaration and look at how you described it --
` A Okay.
` Q -- since I don't have the package
`insert. So this has been previously marked as
`Shire Exhibit 2060.
` That is your declaration?
` A That's right.
` Q And you've signed it on Page 106?
` A That's right.
` MR. ROBINSON: You want to give
` him a copy of the errata sheet as well? Or
` we can make copies if you want.
` MR. ROTH: Okay.
` MR. ROBINSON: Also, this is one
` of two declarations; correct?
` MR. ROTH: That's right.
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` J. Polli, Ph.D.
` MR. ROBINSON: I just want to make
` it clear.
`BY MR. ROTH:
` Q This is the declaration in the 290
`case. And here is the errata sheet that
`Mr. Robinson handed me this morning and it's
`marked Exhibit 2060.
` A Thank you.
` MR. ROBINSON: Do you want a copy
` of that for yourself?
` MR. ROTH: I think I have one. I
` think you gave us two.
` MR. ROBINSON: One for each case.
` MR. ROTH: I see. No, I don't.
` MR. ROBINSON: I think the
` paragraph numbers are the same.
` MR. ROTH: The declarations are
` the same, so --
`BY MR. ROTH:
` Q So turn to Page 97 --
` A Okay.
` Q -- and look at Paragraph 204.
` A All righty.
` Q In the middle of that paragraph, do
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` J. Polli, Ph.D.
`you see a sentence beginning with the word
`"However" on the left?
` A Yes, I do.
` Q Go to the next sentence. It states,
`"The SR beads are releasing later and further
`along the GI tract than the IR and DPR beads"; do
`you see that?
` A Yes, I do.
` Q The SR bead is the sustained release
`bead?
` A That's right.
` MR. ROBINSON: Objection,
` foundation.
`BY MR. ROTH:
` Q The GI tract is gastrointestinal
`tract?
` A That's right.
` Q And the IR and DPR beads are the
`immediate release and delayed release beads; is
`that right?
` A That's right.
` Q DPR means delayed pulse release?
` A That's right.
` Q Okay. And then go down to the next
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` J. Polli, Ph.D.
`paragraph. The third line a little bit to the
`right beginning with the word "So." It says, "So
`an SR bead releasing slowly and much later in the
`GI tract would not necessarily release
`amphetamine to the same extent as the other
`beads"; do you see that?
` A Yes, I do.
` Q Are these statements correct?
` MR. ROBINSON: You're allowed to
` read as much as the declaration as you wish.
` THE WITNESS: Yeah, so in this
` section -- so the section on Page 97, I'm
` addressing Dr. Jusko's report. That's was
` what was on my mind, talking about Claims 5
` through 12.
` And -- so the first sentence in
` the first two paragraphs that you point me
` to say to Dr. Jusko, "Opine that AUC would
` not change if the total dose remains the
` same, no matter how it is distributed among
` the beads." And then I was trying to
` address my understanding of his report. So
` I was being somewhat favorable in some of
` these statements.
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` J. Polli, Ph.D.
` So the question that you asked me
` about, the SR beads are releasing later and
` further along the GI tract than the IR beads
` or DPR beads, this is in the framework of
` what I understand Dr. Jusko was saying.
` I think as far as the accuracy of
` that statement, I would say just taking one
` step back, I mean, this is my own report,
` and I stand by that sentence, but it's in
` the context of addressing Jusko.
` I would say one element that's --
` where there's some uncertainty about that
` statement -- my statement there, is that the
` SR bead is designed to release -- I'm
` sorry -- release later and further along the
` GI tract. Now whether that really happens;
` for example, it may not release at all. I
` think I made reference to that at other
` points in my report. But again, so in that
` way, it may not be exactly correct, but in
` this paragraph, again, I'm trying to address
` Dr. Jusko's point of view, which is -- which
` I do understand that he says, well, it would
` release later. And I have commented before
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` J. Polli, Ph.D.
` that I don't believe that's the case.
` And the major point I'm trying to
` make here is that on the very next sentence,
` the more of the dose that is in the SR bead,
` the less likely that it will be full release
` and full absorption of the entire three-bead
` combination. So in this entire paragraph,
` this section, I'm really trying to address
` what Dr. Jusko was saying. That was -- so
` you drew my attention I think to that one
` sentence.
` If I remember your question, you
` also drew my attention to another sentence
` or another phrase. Can you just repeat what
` the second phrase was? Maybe I lost my
` place. I think it was in Paragraph 205.
`BY MR. ROTH:
` Q It says, "So an SR bead releasing
`slowly and much later in the GI tract would not
`necessarily release amphetamine to the same
`extent as the other beads."
` A Yeah. So, again, I'm kind of taking a
`favorable view of Dr. Jusko's baseline
`understanding that even though these SR beads
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` J. Polli, Ph.D.
`have not been evaluated previously, that if they
`were -- if they were to, in fact, release slowly
`and much later in the GI tract, a person of
`ordinary skill would certainly recognize that
`just because something does release slower and
`later in the GI tract compared to other types of
`beads, that doesn't necessarily mean they would
`be absorbed to the same extent. And it's
`certainly well recognized -- a person of ordinary
`skill would recognize that, you know, the GI
`tract has a limit. There's temporal limits of a
`lot of SR designs fail because they run out of
`time. The colon is not designed to be an
`absorptive organ of materials in general. So
`that's what I was trying to get at there. I
`don't know of any limitation -- I don't know of
`any errors, if that was the question.
` Q Going back to my question, because you
`supplied a lot of information there; I'm not sure
`I followed it all. In your first statement you
`said the SR beads are releasing later and further
`along the GI tract than the IR and DPR beads.
` Are you standing by that statement?
`Is that statement still true?
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` J. Polli, Ph.D.
` A I mean, again, in the context of
`addressing Dr. Jusko's point of view, this is --
`so this is something that I read that I saw in
`his arguments, that the SR beads are releasing
`later and further along in the GI tract. Maybe
`he didn't use exactly those words, but I
`certainly see that he said that.
` But my main point is that, okay, even
`given that --
` Q I'm not asking your main point.
`You've done that already. I'm asking
`specifically about that sentence.
` MR. ROBINSON: Objection. Asked
` and answered twice.
`BY MR. ROTH:
` Q Do you have -- sitting here today, are
`you -- do you, yourself, have any opinion as to
`whether the SR beads are expected to release
`later and slower and further along in the GI
`tract than the IR and DPR beads?
` MR. ROBINSON: Objection; asked
` and answered, and foundation.
` THE WITNESS: You said expected to
` release later? Later than the other types
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` J. Polli, Ph.D.
` of beads?
`BY MR. ROTH:
` Q Yes.
` A Any of the DPR beads? I'm just trying
`to understand the comparison of the SR beads
`versus DPR beads.
` Q In the context that you used those
`words here, do you have an expectation that the
`SR beads are expected to release later in the
`GI -- later, further down the GI tract and slower
`than the IR and DPR beads?
` MR. ROBINSON: Objection; asked
` and answered, and foundation.
` THE WITNESS: The thing that's
` going through my mind is for -- relative to
` the IR bead, I would say, yes, I think they
` were designed to be certainly slower.
` The thing that's less uncertain in
` my mind about being able to answer your
` question is, I'm just not sure what SR bead
` you're referring to, because there's several
` formulation factors in SR beads. And then
` compare that to which DPR beads there's
` various formulation factors for DPR beads.
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` J. Polli, Ph.D.
`BY MR. ROTH:
` Q I'm only referring to what you said
`here. Whatever you were referring to here,
`that's how I want you to answer my question.
` MR. ROBINSON: Objection; asked
` and answered, and foundation.
`BY MR. ROTH:
` Q When you made this statement, do you
`agree that there's an -- do you have an
`expectation that the SR beads are releasing
`later, slower and further along the GI tract than
`the IR and DPR beads?
` MR. ROBINSON: Objection; asked
` and answered.
` THE WITNESS: I certainly -- in
` addressing Dr. Jusko's opinion, I think,
` yes, Dr. Jusko had that expectation that, in
` general, no matter how the SR beads were
` fabricated, that they would be releasing
` later and further along the GI tract than
` any DR bead.
`BY MR. ROTH:
` Q I'm not asking about Dr. Jusko's
`opinion. I'm asking about your opinion. You
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` J. Polli, Ph.D.
`didn't say in this statement this is Dr. Jusko's
`opinion. The statement is self-contained. It
`says, "The SR beads are releasing later and
`further along the GI tract than the IR and DPR
`beads."
` MR. ROBINSON: Objection; asked
` and answered, first of all. Secondly,
` mischaracterization of the testimony. The
` statement is not self-contained. The
` statement is part of an entire declaration
` in an entire paragraph.
`BY MR. ROTH:
` Q Is it your opinion, Dr. Polli, is it
`your opinion that the SR bead is expected to
`release later, slower and further along the GI
`tract than the IR and DPR beads?
` MR. ROBINSON: Objection; asked
` and answered. Becoming argumentative,
` repetitive. It's time to move on.
` THE WITNESS: I mean, I think it's
` possible that it could be, but I'm just --
` in your question, I'm not quite sure what --
` I think it's possible to have an SR bead
` that is designed to be slower than a DPR
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` J. Polli, Ph.D.
` bead, but not necessarily all. That's the
` uncertainty in my mind. I'm kind of
` wondering which formulations you're thinking
` about in asking the question. That's all.
`BY MR. ROTH:
` Q Do you have any understanding of what
`the SR bead is in the '100 patent?
` A Yes, yes, yes, I do.
` Q It's an amphetamine pellet coated with
`enteric coating and further Surelease.
` MR. ROBINSON: Objection,
` mischaracterizes the reference.
` THE WITNESS: I think that's an
` example, yes. I understand that.
`BY MR. ROTH:
` Q And do you have an understanding of
`what the DPR bead is in the '100 patent?
` A Yes, I do.
` Q Again, that's an amphetamine bead
`coated with a eudragit coating?
` MR. ROBINSON: Objection.
` Mischaracterizes the reference.
` THE WITNESS: I recall some
` examples like that; that's right.
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` J. Polli, Ph.D.
`BY MR. ROTH:
` Q And do you have an understanding of
`what an immediate release bead is in the '100
`patent?
` A Yes, I do.
` Q That's a bead that's designed to
`release very quickly; right?
` MR. ROBINSON: Objection.
` Mischaracterizes the reference.
` THE WITNESS: I think that's
` correct, yes.
`BY MR. ROTH:
` Q So given those definitions of those
`three beads, given your statement in your report
`that we've been discussing, do you have an
`expectation that the SR bead would be expected to
`release later, slower and further down the GI
`tract than the IR and DPR beads?
` A I mean, you know, I am thinking about
`the '100 patent, and the SR bead did have that
`intent to allow for treatment of ADHD for later
`day to prolong the duration of therapy via the SR
`bead. So in that regard, I would say, yes, I
`think there's some SR beads that had that intent.
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` J. Polli, Ph.D.
` MR. ROTH: I want to mark an
` exhibit. Mark it as Exhibit 100. Polli
` Exhibit 100.
` (Exhibit Polli 100 was marked.)
`BY MR. ROTH:
` Q This is a July 21st, 2006 Clinical
`Pharmacology/Biopharmaceutics Report, and it is
`the clinical pharmacology pharmaceutics review
`from the FDA website on FDA's review on the new
`drug application for Mydayis, which at the time
`was referred to as SPD465.
` Are you aware that Mydayis was earlier
`referred to as SPD465, Dr. Polli?
` A Not particularly, no.
` Q Okay. So I'd like you to assume for
`purposes of my question that Mydayis -- the
`earlier name for Mydayis was SPD465.
` A Okay.
` Q And you can assume that for the rest
`of the day.
` A Okay.
` Q Can you take a look at the Page 1
`right on the first page, second paragraph?
` A I'm sorry. What was that; second
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` J. Polli, Ph.D.
`paragraph?
` Q Right. "The rationale"; do you see
`it?
` A Yes.
` Q Can you read it out loud?
` A Sure. "The rationale for the
`development of SPD465 long-acting Adderall XR is
`to enable primary adult and adolescent ADHD
`patients to benefit from ADHD symptom control
`throughout the entire day, and to extend those
`benefits into the early evening hours following a
`single morning dose."
` Q Assuming that was the rationale for
`developing Mydayis, do you think it was
`reasonable for the inventors to add the SR bead
`to the IR and DPR beads to extend control of
`ADHD?
` MR. ROBINSON: Objection,
` foundation. And assumes the inventors had
` this information.
` THE WITNESS: I'm sorry. What was
` the question again?
` MR. ROTH: Can you read it back?
` (Whereupon the reporter read back
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` J. Polli, Ph.D.
` the requested portion of the record.)
` MR. ROBINSON: Objection,
` foundation.
` THE WITNESS: What do you mean by
` "reasonable"?
`BY MR. ROTH:
` Q Did it make sense? Did it have a
`scientific underpinning?
` A I cite some citations in my report
`about the recognition that some patients would
`benefit by longer duration of therapy, but it was
`also recognized that Adderall had tolerance, and
`that sustained release, which often involves
`flatter profiles, is -- had not previously worked
`and would not be expected to work for ADHD with
`treatment with amphetamine.
` Another issue is that, you know,
`trying to get drug absorbed from the colon
`through sustained release, that's beyond even
`this Adderall XR was associated with challenges
`that were known to a person of ordinary skill, in
`terms of the need for the drug to dissolve in a
`colonic environment, and then be absorbed from a
`colonic environment.
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` J. Polli, Ph.D.
` Q Was there any scientific basis at all
`for the inventors to add the sustained release
`bead to the IR and DPR beads so as to extend
`control of ADHD?
` MR. ROBINSON: Objection,
` foundation.
`BY MR. ROTH:
` Q Or was it just a shot in the dark that
`made no sense?
` MR. ROBINSON: Objection.
` Artificially restricts.
` THE WITNESS: You're talking about
` what was going on -- you're asking me what
` was going on in the minds of the inventors?
`BY MR. ROTH:
` Q No, no. I'm not asking you to read
`their minds. I'm asking you whether it made
`sense objectively to you, for the inventors to
`have added the SR bead to the IR and DPR beads
`with the expectation that it may extend control
`of ADHD?
` MR. ROBINSON: Objection,
` foundation.
` THE WITNESS: I don't think I -- I
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` J. Polli, Ph.D.
` mean, I -- I don't think a person of
` ordinary skill would think there would be an
` expectation of success of adding an SR bead
` to essentially replace -- I'm reading this
` paragraph that you drew my attention to in
` this, Clinical Pharmacology/Biopharmaceutics
` Review, to replace an immediate release dose
` of Adderall as given eight hours after the
` original -- after Adderall XR was given.
`BY MR. ROTH:
` Q That's not my question. I'm not
`talking about eight hours of anything, so let me
`restate my question.
` Was it reasonable for the inventors to
`add the SR bead to the two beads that were in
`Adderall XL, the IR and the DPR beads, to extend
`treatment of ADHD?
` MR. ROBINSON: Objection; asked
` and answered. Foundation.
` THE WITNESS: For what particular
` purpose? To extend ADHD treatment?
`BY MR. ROTH:
` Q Is there any scientific basis that
`doing that would extend ADHD treatment?
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` J. Polli, Ph.D.
` MR. ROBINSON: Objection; asked
` and answered.
`BY MR. ROTH:
` Q I gather you have a bases to think
`that -- why it might not work. You went through
`that.
` But I'm asking you, is there any basis
`to think that it might work, to add the SR bead
`to the IR and DPR beads to extend treatment of
`ADHD?
` MR. ROBINSON: Objection; asked
` and answered several times. He already told
` you he had no basis.
` MR. ROTH: Please don't coach the
` witness, Mr. Robinson.
` MR. ROBINSON: I'm not. You're
` asking him the same question repeatedly.
` You're badgering.
` THE WITNESS: So just for
` clarification, when you mean extend ADHD
` treatment, compared to, say, something like
` Adderall?
`BY MR. ROTH:
` Q Adderall XR, because Adderall XR has
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` J. Polli, Ph.D.
`the IR and the DPR beads. We went through that
`upfront. So let me clarify my question again.
`Thank you for that.
` Did it make any sense, any rational
`basis to add the SR bead to the IR and DPR beads
`in Adderall XL to extend treatment of ADHD beyond
`Adderall XR?
` MR. ROBINSON: Objection; asked
` and answered.
` THE WITNESS: Although there was
` clearly challenges that in my opinion would
` not provide a reasonable expectation of
` success, one could look at it and say, well,
` if we add -- if we somehow are able to get
` drug absorbed much later, I suppose it would
` go along that hope of being able to address
` that problem. I don't think a person of
` ordinary skill would think that it would be
` reasonable. I'm trying to answer your
` question, was there any remote chance.
` That's how I interpreted your question.
`BY MR. ROTH:
` Q That's not my question.
` Was there a rational basis? Did it
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` J. Polli, Ph.D.
`make any sense? Was there a scientific basis?
` MR. ROBINSON: Objection; asked
` and answered.
` THE WITNESS: So excluding other
` type of basis that would cause one to have
` doubts about its success?
`BY MR. ROTH:
` Q Correct. We're going to discuss those
`doubts, guaranteed.
` A Okay.
` Q I'm only asking you if there was any
`scientific basis for doing it, for adding the
`sustained release bead to the IR and DPR beads to
`extend evidence.
` MR. ROBINSON: Objection; asked
` and answered several times.
` THE WITNESS: I mean, yeah, yeah,
` so if -- I mean excluding --
`BY MR. ROTH:
` Q Excluding the doubts.
` A Even though there's reasons I think a
`person of ordinary skill would not think it would
`work, I think there's at least a line of thinking
`that it's -- that there could be a way of getting
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` J. Polli, Ph.D.
`drug absorbed later.
` Q Where is the -- and that could extend
`treatment of ADHD?
` A You mean if it worked?
` Q Yes.
` A Yeah, if one knew it worked, then I
`think it would work.
` Q Well if one -- is there a rational
`basis to think that it would extend delayed
`delivery, lower in the GI tract, and is there a
`rational basis to think that that might work to
`treat ADHD?
` MR. ROBINSON: Objection; asked
` and answered.
`BY MR. ROTH:
` Q Again, putting aside the doubts that
`you referred to.
` A When you mean "might," that means any
`remote chance.
` Q No. That means -- was -- I'm asking
`you, is there a scientific basis to think that it
`might work?
` MR. ROBINSON: Objection; asked
` and answered.
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` J. Polli, Ph.D.
` THE WITNESS: I think I addressed
` that. I think if one looks at what was
` known, they would say there wasn't a
` reasonable expectation of success. But I
` understand your question is excluding all
` the negatives. I mean, it is true, even
` though there's several negatives, that if
` you are somehow able to get more drug
` absorbed later, it could address that goal
` of extending the duration of therapy
` relative to Adderall XR.
`BY MR. ROTH:
` Q Where in the body is the SR bead
`released?
` MR. ROBINSON: Objection,
` foundation.
` THE WITNESS: Is there a
` particular SR bead that you're thinking
` about?
`BY MR. ROTH:
` Q The SR bead in Mydayis.
` A I recall there is -- you know what?
`I'm thinking about Adderall XR. I don't know
`that I've seen -- sitting here now, I don't
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