`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`PROLLENIUM US INC.,
`Petitioner,
`
`v.
`
`ALLERGAN INDUSTRIE, SAS,
`Patent Owner.
`
`_________________
`
`IPR2019-01505 (Patent 8,450,475 B2)
`IPR2019-01506 (Patent 8,357,795 B2)
`IPR2019-01508 (Patent 9,238,013 B2)
`IPR2019-01509 (Patent 9,358,322 B2)
`IPR2019-01617 (Patent 8,822,676 B2)
`IPR2019-01632 (Patent 8,357,795 B2)
`IPR2020-00084 (Patent 9,089,519 B2)
`_________________
`
`PETITIONER’S NOTICE OF DEPOSITION OF DR. CORY J. BERKLAND1
`
`
`
`
`
`
`1 Authorization for the use of a joint caption page was received on April 27, 2020.
`Neither party opposes the use of a joint caption page. An identical paper has been
`filed in each case recited in the consolidated caption.
`
`
`
`
`
`IPR2019-01505, IPR2019-01506, IPR2019-01508, IPR2019-01509,
`IPR2019-01617, IPR2019-01632, IPR2020-00084
`
`
`Notice of Deposition
`
`Pursuant to 37 C.F.R. § 42.53, Petitioner, by and through its attorneys, will
`
`conduct a deposition of Dr. Cory J. Berkland regarding his declarations filed on
`
`behalf of the Patent Owner in each of the inter partes review proceedings
`
`designated above in the consolidated case caption.
`
`The deposition will commence on Wednesday, October 7, 2020, at 3:00 PM
`
`CT in St. Louis, Missouri, and will continue on October 8 and 9, 2020, at 8:30 AM
`
`CT each day, until completed. The deposition will be conducted using the secure
`
`web-based deposition option afforded by Veritext or in the alternative video
`
`teleconferencing services offered by Veritext or telephonically only to provide
`
`remote access for those parties wishing to participate in the deposition via the
`
`internet and/or telephone.
`
`The deposition will be taken before a Notary Public or other officer
`
`authorized by law to administer oaths (“Court Reporter”), and it will be recorded
`
`using stenographic means. Also take notice that the Court Reporter may also be
`
`remote via one of the options above for the purposes of reporting the proceeding
`
`and will not be in the physical presence of the deponent. The deposition will also
`
`be made available, by real-time transcript and video, to remote attendees of the
`
`deposition.
`
`Pursuant to 37 C.F.R. § 42.53(d)(1), the parties have agreed on these dates,
`
`1
`
`
`
`IPR2019-01505, IPR2019-01506, IPR2019-01508, IPR2019-01509,
`IPR2019-01617, IPR2019-01632, IPR2020-00084
`
`location, and means for Dr. Berkland’s deposition. Pursuant to 37 C.F.R.
`
`§ 42.53(c)(2), the parties have stipulated that the deposition shall be subject to the
`
`following time limits: Twelve hours for cross-examination, three hours for redirect
`
`examination, and two hours for re-cross examination.
`
`Respectfully submitted,
`
`/Warren Thomas/
`Warren J. Thomas (Reg. No. 70,581)
`
`
`
`2
`
`
`
`IPR2019-01505, IPR2019-01506, IPR2019-01508, IPR2019-01509,
`IPR2019-01617, IPR2019-01632, IPR2020-00084
`
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and consent of the Patent Owner, I certify
`that on September 25, 2020, a copy of Petitioner’s Notice of Deposition of Dr.
`Cory J. Berkland was served on the counsel of record by email to:
`aminsogna@jonesday.com
`tweisser@jonesday.com
`cplatt@jonesday.com
`sgeers@jonesday.com
`jhartjes@jonesday.com
`
`
`
`
`
`/Warren Thomas/
`Warren J. Thomas (Reg. No. 70,581)
`
`3
`
`
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