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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PROLLENIUM US INC.,
`Petitioner
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`v.
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`ALLERGAN INDUSTRIE, SAS,
`Patent Owner
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`Case IPR2020-00084
`Patent 9,089,519
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`PATENT OWNER ALLERGAN INDUSTRIE SAS’S
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`MANDATORY NOTICES
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`Case IPR2020-00084
`Attorney Docket No: 13351-0081IP1
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`PATENT OWNER’S MANDATORY NOTICES
`UNDER 37 C.F.R. § 42.8
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`Pursuant to 37 C.F.R. § 42.8, the patent owner, Allergan Industrie, SAS
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`(“Patent Owner”), hereby submits the following Mandatory Notices in response to
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`the Petition for Inter Partes Review of U.S. Patent No. 9,089,519 (“the ‘519
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`patent”).
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`1.
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`Real Party-In-Interest under 37 CFR § 42.8(b)(1)
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`Each of Allergan Industrie, SAS; Allergan USA, Inc.; Allergan Sales, LLC;
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`Allergan Holdings France SAS; Allergan Holdings Limited; Allergan Holdings,
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`Inc.; Allergan Puerto Rico Holdings, Inc.; and Allergan, Inc. are the real parties-in-
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`interest in this proceeding.
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`2.
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`Related Matters under 37 CFR § 42.8(b)(2)
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`The following judicial or administrative matters may affect or be affected by
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`a decision in this proceeding: Allergan USA, Inc. and Allergan Industrie SAS v.
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`Prollenium US Inc. and Prollenium Medical Technologies Inc., Civil Action No.
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`19-126-CFC (D. Del.).
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`The ‘519 patent claims priority to U.S. 8,357,795 (“the ‘795 patent”). The
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`‘795 patent was previously asserted by the Patent Owner and its affiliates in an
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`Amended Complaint filed on December 6, 2013 in Allergan USA, Inc., et al. v.
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`Case IPR2020-00084
`Attorney Docket No: 13351-0081IP1
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`Medicis Aesthetics, Inc., et al., 8:13-cv-01436-AG-JPR, in the U.S. District Court
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`for the Central District of California, dismissed with prejudice June 12, 2015.
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`The ‘795 patent also was the subject of (a) IPR2014-01422 filed August 29,
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`2014 and terminated June 19, 2015 by way of joint motion to terminate, and (b)
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`IPR2017-02003 filed August 2, 2017 and denied on March 9, 2018.
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`U.S. 8,822,676 (“the ‘676 patent”) claims priority to the ‘519 patent and is
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`the subject of an IPR petition filed by Petitioner. The ‘676 patent is also the
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`subject of the aforementioned civil action.
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`Petitioner has also filed IPR petitions against U.S. 8,450,475, U.S.
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`8,357,795, U.S. 9,358,322, and U.S. 9,238,013, each of which is the subject of the
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`aforementioned civil action.
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`3.
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`Lead and Back-Up Counsel, under 37 CFR § 42.8(b)(3)
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`Patent Owners designate the following lead and back-up counsel:
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`LEAD COUNSEL
`Dorothy P. Whelan, Reg. No. 33,814
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 612-335-5070/Fax 877-769-7945
`IPR13351-0081IP1@fr.com
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`BACK-UP COUNSEL
`Michael J. Kane, Reg. No. 39,722
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Tel: 612-335-5070/Fax 877-769-7945
`PTABInbound@fr.com
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`Case IPR2020-00084
`Attorney Docket No: 13351-0081IP1
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`4.
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`Service Information under 37 CFR § 42.8(b)(4)(i) et seq.
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`Please address all correspondence and service to both counsel as listed
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`above. Patent Owner consents to service by email at IPR13351-0081IP1@fr.com
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`(ref.: Docket No. 13351-0081IP1).
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`Date: October 30, 2019
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`Customer Number 26191
`Fish & Richardson P.C.
`Telephone: (612) 335-5070
`Facsimile: (877) 769-7945
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`Respectfully submitted,
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`/Dorothy P. Whelan/
`Dorothy P. Whelan, Reg. No. 33,814
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`Case IPR2020-00084
`Attorney Docket No: 13351-0081IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4) and 42.205(b), the undersigned certifies
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`that on October 30, 2019, a complete and entire copy of this Patent Owners’
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`Mandatory Notices and Powers of Attorney were provided via electronic service,
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`to the Petitioner by serving the correspondence address of record as follows:
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`Christopher L. Curfman
`William W. Cutchins
`Meunier Carlin & Curfman LLC
`999 Peachtree St, NE, Suite 1300
`Atlanta, GA 30309
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`Email: mcc.prollenium.ipr@mcciplaw.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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