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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`DR. REDDY’S LABORATORIES S.A. AND
`DR. REDDY’S LABORATORIES, INC.
`Petitioners
`
`v.
`
`INDIVIOR UK LIMITED.
`Patent Owner
`
`
`
`U.S. PATENT NO. 9,687,454
`
`TITLE: SUBLINGUAL AND BUCCAL FILM COMPOSITIONS
`
`Case No. IPR2019-00329
`
`
`
`Petitioners’ Objections to Patent Owner’s Evidence Submitted with Patent
`Owner’s Response to Petition for Inter Partes Review
`
`
`ACTIVE/100961691.1
`
`
`
`
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`Pursuant to 37 C.F.R. § 42.64(b)(1) and the Federal Rules of Evidence
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`(“FRE”), Petitioners Dr. Reddy’s Laboratories S.A. and Dr. Reddy’s Laboratories,
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`Inc. (collectively, “Petitioners”) submit the following objections to evidence served
`
`with Patent Owner’s Response to the Petition for Inter Partes Review of U.S.
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`Patent No. 9,687,454.
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`Ex. 2006—Petitioners object to Exhibit 2006 under FRE 401, FRE 402, and
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`37 CFR § 42.61, as the Exhibit does not have any tendency to make a
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`consequential fact in this action more or less probable than it would be without the
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`evidence. Petitioners further object to this Exhibit under FRE 403 because any
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`probative value is substantially outweighed by the risk of unfair prejudice,
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`confusing the issues, wasting time, or needlessly presenting cumulative evidence.
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`Ex. 2007—Petitioners object to Exhibit 2007 under FRE 401, FRE 402, and
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`37 CFR § 42.61, as the Exhibit does not have any tendency to make a
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`consequential fact in this action more or less probable than it would be without the
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`evidence. Petitioners further object to this Exhibit under FRE 403 because any
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`probative value is substantially outweighed by the risk of unfair prejudice,
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`confusing the issues, wasting time, or needlessly presenting cumulative evidence.
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`Ex. 2008—Petitioners object to Exhibit 2008 under FRE 702. Opinions
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`expressed in Ex. 2008 are not reliably based on scientific, technical, or other
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`specialized knowledge, sufficient facts or data, reliable principles and methods, or
`
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`ACTIVE/100961691.1
`
`
`1
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`
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`the reliable application of principles and methods. This exhibit also includes
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`statements that are not relevant to the issues in this case and therefore have little
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`probative value, which is substantially outweighed by dangers such as confusing
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`the issues and wasting time, under FRE 402 and FRE 403. Argument and analysis
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`in this exhibit are improperly incorporated by reference into the Patent Owner
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`Response (Paper 33) in contravention of 37 C.F.R. §§ 43.6(a)(3) and 42.24(b)(2).
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`Ex. 2009—Petitioners object to Exhibit 2009 under FRE 802. Petitioners
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`also object to Exhibit 2009 under FRE 1001-1003. This Exhibit also includes
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`statements that are not relevant to the issues in this case and therefore have little
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`probative value, which is substantially outweighed by dangers such as confusing
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`the issues and wasting time, under FRE 402 and FRE 403. Petitioners maintain
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`their objections as stated by counsel on the record during the deposition.
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`
`Dated: September 24, 2019
`
`
`
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`ACTIVE/100961691.1
`
`
`
`
`By: /s/ Ira J. Levy
`Ira J. Levy
`Registration No. 35,587
`Goodwin Procter LLP
`The New York Times
`Building
`620 Eighth Avenue
`New York, NY 10018
`T: 212-459-7456
`F: 646-558-4143
`ILevy@goodwinlaw.com
`
`Robert Frederickson III (admitted pro hac
`vice)
`Goodwin Procter LLP
`2
`
`
`
`100 Northern Ave.
`Boston, MA 02210
`T: 617-570-1947
`F: 617-321-4773
`
`Counsel for Petitioners
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`ACTIVE/100961691.1
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`3
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`
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(a), the undersigned certifies
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`
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`that on September 24, 2019, a copy of the foregoing Petitioners’ Objections to
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`Patent Owner’s Evidence Submitted with Patent Owner’s Response to
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`Petition for Inter Partes Review was served by email on the lead and back-up
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`counsel for Patent Owners at:
`
`dgarr@cov.com
`pchen@cov.com
`IndiviorSBX@cov.com
`
`
`
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`Date: September 24, 2019
`
`
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`
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`By: /s/ Ira J. Levy
`Registration No. 35,587
`Goodwin Procter LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018
`T: 212-459-7456
`F: 646-558-4143
`ILevy@goodwinlaw.com
`
`
`ACTIVE/100961691.1
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`
`
`
`
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