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` UNITED STATES PATENT AND TRADEMARK OFFICE
` ______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ______________________________________
` MYLAN INSTITUTIONAL LLC,
` Petitioner,
` v.
` NOVO NORDISK A/S,
` Patent Owner.
` ______________________________________
` Patent No. 8,114,833
` ______________________________________
` Inter Partes Review IPR2020-00324
`
` REMOTE VIDEOTAPED DEPOSITION
` OF LAIRD FORREST, Ph.D.
` Thursday, September 3, 2020
`
`Reported by:
`Anne E. Vosburgh, CSR-6804, RPR, CRR
`Job No. 28304
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Novo Nordisk Ex. 2079, P. 1
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ______________________________________
` MYLAN INSTITUTIONAL LLC,
` Petitioner,
` v.
` NOVO NORDISK A/S,
` Patent Owner.
` ______________________________________
` Patent No. 8,114,833
` ______________________________________
` Inter Partes Review IPR2020-00324
`
` REMOTE VIDEOTAPED DEPOSITION
` OF LAIRD FORREST, Ph.D.
` Thursday, September 3, 2020
`
`Reported by:
`Anne E. Vosburgh, CSR-6804, RPR, CRR
`Job No. 28304
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Novo Nordisk Ex. 2079, P. 1
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
`
`
`
`Page 2
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` -oOo-
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` On September 3, 2020, commencing at
` approximately 10:00 a.m., the deposition of
` LAIRD FORREST, PH.D., taken remotely via video
` conference, held before and stenographically
` reported by Anne E. Vosburgh, Certified
` Shorthand Reporter No. 6804, Registered
` Professional Reporter, Certified Realtime
` Reporter, and Notary Public.
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`Novo Nordisk Ex. 2079, P. 2
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 3
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`REMOTE APPEARANCES:
`
` FOR THE PETITIONER, MYLAN INSTITUTIONAL:
` PERKINS COIE
` 700 13th Street NW
` Washington DC 20005
` By: Brandon M. White, Esq.
` BMWhite@perkinscoie.com
` Lara Dueppen, Esq.
` LDueppen@perkinscoie.com
`
` FOR THE PATENT OWNER:
` FENWICK & WEST
` 902 Broadway #14
` New York, NY 10010
` By: Jeffrey Oelke, Esq.
` joelke@fenwick.com
` Kathryn Easterling, Esq.
` keasterling@fenwick.com
`
` FOR PFIZER:
` WINSTON & STRAWN
` 1901 L Street
` Washington, DC 20036
` By: Jovial Wong, Esq.
` jwong@winston.com
` Sharon Lin, Esq.
` slin@winston.com
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`Novo Nordisk Ex. 2079, P. 3
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 4
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` REMOTE APPEARANCES (continued)
`
` ALSO PRESENT IN PROCEEDINGS:
` Brandon Vosburgh, Legal Videographer
` Rich Merisier, TrialGraphix
` Karen Legge, Pfizer
` Mack Reiner, Mylan
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`Novo Nordisk Ex. 2079, P. 4
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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` I N D E X
`
`Page 5
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` ---------- EXAMINATIONS ----------
` WITNESS: LAIRD FORREST, PH.D.
` Examination by Mr. Oelke 10
`
` ---------- MARKED EXHIBITS ----------
` NUMBER DESCRIPTION PAGE
` Exhibit 1 Laird Forrest, Ph.D., Curriculum 13
` Vitae
` Exhibit 2 Expert Declaration of Laird 39
` Forrest, Ph.D. for U.S. Patent
` 8,114,833
` Exhibit 3 International Patent Application, 89
` WO 03/002136 A2, Mylan Exhibit
` 1004
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`Novo Nordisk Ex. 2079, P. 5
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`(Exhibits, continued.)
` Exhibit 4 Remington's Pharmaceutical 126
` Sciences, 18th Edition, Mylan
` Exhibit 1013
` Exhibit 5 "Hemolysis of Erythrocytes in 155
` Various Iso-osmotic Solutions, "
` by Hammarlund and
` Pedersen-Bjergaard
` Exhibit 6 "Excipient–Drug Interactions in 164
` Parenteral Formulations," by
` Akers, Mylan Exhibit 1067
` Exhibit 7 U.S. Patent 8,114,833, Mylan 177
` Exhibit 1001
` Exhibit 8 Letter to the Editor, American 185
` Journal of Hospital Pharmacy
` Exhibit 9 "Handbook of Pharmaceutical 198
` Excipients," Copyright 1986, 1994,
` 2000, Mylan Exhibit 1022
` Exhibit 10 "Handbook of Pharmaceutical 198
` Excipients," Copyright 2003, Mylan
` Exhibit 1023
`
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`Novo Nordisk Ex. 2079, P. 6
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`(Exhibits, continued.)
` Exhibit 11 "Osmolalities of Propylene 250
` Glycol-Containing Drug
` Formulations for Parenteral Use.
` Should Propylene Glycol Be Used as
` a Solvent?"
` Exhibit 12 International Patent Application 301
` WO 2004/004781 Al, Mylan Exhibit
` 1005
` (EXHIBITS ATTACHED)
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`Novo Nordisk Ex. 2079, P. 7
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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` L. Forrest
` Lawrence, Kansas
` September 3, 2020, 10:00 a.m.
` ---------------
` PROCEEDINGS
` ---------------
` THE VIDEOGRAPHER: Good morning.
` My name is Brandon Vosburgh. I'm the
` legal videographer in association with
` TransPerfect Legal Solutions.
` Due to the severity of COVID-19
` and following the practice of social
` distancing, I will not be in the same
` room as the witness but will record this
` video deposition remotely.
` Our certified court stenographer,
` Anne Vosburgh, will also be in a
` different room and will swear in the
` witness remotely.
` Do all parties stipulate to the
` validity of this video recording and
` remote swearing and that it will be
` admissible in Court as if it had been
` taken following the Federal Rules of
` Civil Procedures?
`
`TransPerfect Legal Solutions
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`Novo Nordisk Ex. 2079, P. 8
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 9
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` L. Forrest
` Your answers, please.
` MR. WHITE: No objection to Mylan,
` the petitioner.
` MR. OELKE: Yeah. And for
` Novo Nordisk, the patent owner, there's
` no objection.
` THE VIDEOGRAPHER: Thank you.
` Today is Thursday, September 3rd, 2020.
` And the time is 10:05 a.m. Eastern
` Standard Time.
` This is the beginning of media
` unit number 1 in the video-recorded
` deposition of Dr. Laird Forrest in the
` matter of Novo Nordisk, Inc., versus
` Mylan Institutional, LLC.
` At this time will counsel please
` identify yourselves for the record, and
` then our certified court stenographer,
` Anne Vosburgh, will swear in the
` witness.
` MR. OELKE: Yeah. This is
` Jeff Oelke from Fenwick & West on behalf
` of the patent owner, Novo Nordisk, and
` with me is my colleague, Katie
`
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`Novo Nordisk Ex. 2079, P. 9
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 10
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` L. Forrest
` Easterling.
` MR. WHITE: This is Brandon White
` from Perkins Coie on behalf of
` petitioner, Mylan Institutional. Also
` with me is Lara Dueppen from
` Perkins Coie and Mack Reiner (phonetic)
` from Mylan.
` MR. WONG: Also on the line is
` Jovial Wong from Winston & Strawn for
` Pfizer. Also with me is Sharon Lin as
` well as Karen Legge from Pfizer.
` LAIRD FORREST, PH.D.,
` (Having been called as a witness, was
` remotely sworn by the reporter and
` testified upon said oath as follows)
` ---
` EXAMINATION
` BY MR. OELKE:
` Q. Good morning, Dr. Forrest.
` A. Good morning.
` Q. Can you please state your full
` name for the record.
` A. Yes. Excuse me. Marcus Laird
` Forrest.
`
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`Novo Nordisk Ex. 2079, P. 10
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 11
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` L. Forrest
` Q. Okay. Can you just give your
` home address for the record, too, please.
` A. My home address is 1048 East 1135
` Road, Lawrence, Kansas.
` Q. Okay. And are you in Lawrence
` today, Doctor?
` A. Yes. I am in Lawrence.
` Q. Okay. And you've had your
` deposition taken before; isn't that right?
` A. Yes. I have had my deposition
` taken before.
` Q. So you understand the rules in a
` deposition, but I'll go over just a few of
` them for you.
` I'm going to ask you a series of
` questions. You're expected to answer those
` questions. And please give verbal answers.
` Do you understand that?
` A. Yes.
` Q. Okay. And your counsel may pose
` objections at points during the deposition,
` but after that objection, you're expected to
` answer the question unless there's an
` instruction otherwise.
`
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`Novo Nordisk Ex. 2079, P. 11
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 12
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` L. Forrest
` Do you understand that?
` A. Yes, sir.
` Q. And if you understand -- or don't
` understand a particular question, will you
` state so? Otherwise, you should just go
` ahead and answer the question verbally.
` Do you understand that?
` A. Yes.
` Q. Okay. We'll take breaks during
` this deposition about every hour or so. But
` if you need to take a break for anything,
` please let me know. Just wait until after
` you've answered the question.
` Is that okay?
` A. Yes.
` Q. Now, today I may refer to Mylan
` or defendant. You understand that's the
` petitioner in this matter?
` A. Yes, sir.
` Q. And do you understand that the
` patent at issue in this case is the 8 -- I
` can refer to it as "the '833 patent."
` You'll understand what patent that is?
` A. Yes, sir.
`
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`Novo Nordisk Ex. 2079, P. 12
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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` L. Forrest
` Q. Okay. That's U.S. Patent
` 8,114,833. Is that right?
` A. Let me -- 8,114,833.
` Q. Yeah. Okay.
` And you filed a declaration with
` respect to that patent; is that right?
` A. Yes, sir. That is correct.
` Q. And you executed that declaration
` in support of Mylan's petition, right?
` A. Yes, sir. That is correct. I
` executed in support of Mylan's petition.
` Q. Okay. And you attached your CV
` to that declaration?
` A. Yes, sir. My CV is attached to
` that declaration.
` MR. OELKE: Okay. Let's mark your
` CV as Forrest Exhibit 1.
` (Laird Forrest, Ph.D., Curriculum
` Vitae, marked as Deposition
` Exhibit 1.)
` MR. OELKE: Rich, do you have
` that?
` BY MR. OELKE:
` Q. And if you have your paper copy
`
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`Novo Nordisk Ex. 2079, P. 13
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 14
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` L. Forrest
` there, it's okay to look at that as well,
` but the actual exhibit will be up on the
` screen.
` Do you see that there?
` A. Yes, sir. Counsel provided me
` with a set of completely unmarked copies of
` exhibits. And if that's okay with you, I
` would often like to look at them because,
` quite honestly, I'm on WiFi here, and the
` occasionally the text is hard to read on my
` screen with bandwidth.
` Q. Okay. When we mark an exhibit, I
` just ask you to let me know when you have a
` paper copy of it so I know you're referring
` to the paper copy.
` But this CV, I assume you do have
` a copy of that, right?
` A. Yes, sir.
` Q. And the first degree that you
` received was from Auburn University, is that
` right, in college?
` A. Yes. My first degree was from
` Auburn University in chemical engineering.
` Q. Right.
`
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`Novo Nordisk Ex. 2079, P. 14
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 15
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` L. Forrest
` And that degree, you received
` that in 1998?
` A. That is correct.
` Q. Okay. And what did you do next
` after you graduated from Auburn?
` A. After Auburn, I went to the
` University of Illinois.
` Q. And that was to pursue a master's
` degree; is that right?
` A. To pursue a Ph.D degree, but a
` master's is part of the process.
` Q. Okay. So you went to Illinois to
` pursue a Ph.D., but you got a master's along
` the way to receiving that Ph.D.; is that
` right?
` A. That is correct, sir.
` Q. Okay. And you received your
` master's degree in 2001?
` A. That is correct, sir.
` Q. And you received your Ph.D. in
` 2003?
` A. That is correct, sir.
` Q. Okay. Now, while you were at the
` University of Illinois, was there a
`
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`Novo Nordisk Ex. 2079, P. 15
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 16
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` L. Forrest
` particular area that you were studying in
` receiving your Ph.D.?
` A. During all of my studies at
` Illinois, I was working specifically in the
` area of nonviral gene therapy, working on
` general pharmaceutical formulation
` techniques and developing new techniques to
` enhance that.
` Q. And did you have a thesis in
` pursuing your Ph.D.?
` A. Yes. I had a thesis in pursuing
` my -- well, we would call it a dissertation
` for the Ph.D., a thesis for the master's.
` Q. Okay. What was your thesis for
` the master's? Let's start with that.
` A. You know, sadly, I don't recall
` off the top of my head what the title was of
` my master's. It was essentially the first
` chapter of what later became my
` dissertation. I believe I have it on the
` bookshelf. But as I said, it's just a step.
` And it's not much hurrah around it in
` Illinois.
` Q. What was your dissertation, then,
`
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`Novo Nordisk Ex. 2079, P. 16
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
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`Page 17
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` L. Forrest
` for your Ph.D.?
` A. My thesis was on various methods
` of creating excipients and formulating
` nonviral gene therapy devices or vehicles.
` Q. And what type of gene therapy
` vehicles were these?
` A. So they were predominantly based
` upon a polymer called-- well, several
` polymers. One is a polymer called
` polyethylene lysine, and then a substantial
` effort also with polymers such as
` polylysine, and then with various
` sugar-based carriers, predominantly those
` based around cyclodextrins.
` Q. Were these for parenteral
` administration?
` A. Yes. These were predominantly
` intended for parenteral administration.
` Q. Okay. And while you were at
` Illinois, did you do any work on formulation
` of peptides or proteins?
` A. Yes. I worked some on some
` peptide protein formulation within the
` aspects of my work.
`
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`Novo Nordisk Ex. 2079, P. 17
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`IPR2020-00324
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` L. Forrest
` Q. And what types of peptides?
` A. I was most interested in using
` insulin, human-type insulin, which is
` essentially a small protein which is almost
` at the extent of a large -- what we might
` call a peptide.
` I mean, it's not very large, and
` we weren't per se trying to formulate
` insulin for the sake of formulating insulin.
` I was interested in using it in formulations
` as a targeting agent and developing
` chemistries and methods to conjugate it to
` carriers that would not disrupt its
` stability.
` Q. So you referred to peptides and
` proteins there. What's the difference
` between a peptide and a protein?
` A. Proteins are composed of
` peptides. It's really a gray area where you
` would say one stops and the other one
` begins.
` Q. Is there a number of amino acids
` that is accepted as the cutoff between
` proteins and peptides?
`
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`Novo Nordisk Ex. 2079, P. 18
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`IPR2020-00324
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` L. Forrest
` A. Not really. It would depend on
` the person talking. To me personally, I put
` it somewhere along the lines of where you
` start to have an appreciable secondary
` structure. But then, I work with one
` peptide formulation that is 47 mers and
` essentially the same size as insulin.
` So there's not a distinct cutoff.
` But generally, once they start to achieve
` higher order structure, such as tertiary
` structures, you often begin to think of them
` more as proteins. But smaller structures,
` we generally think of as peptides.
` It can also depend too within the
` body. You know, we're talking biomolecules
` that have naturally evolved. They tend to
` be larger structures that have a tertiary
` structure too, and I feel more comfortable
` with protein for those, whereas smaller
` molecules that are essentially more
` synthetic, often I might say peptide. But
` as I said, it's a very gray area.
` Q. Okay. In this matter, we talk a
` lot about GLP-1, right?
`
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`IPR2020-00324
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` L. Forrest
` A. Yes.
` Q. And you know what GLP-1 is,
` right?
` A. Yes, I know what GLP-1 is.
` Q. What is it?
` A. GLP-1 is a peptide fragment, 1 to
` 37 residues. That's -- I don't know how
` much more detail -- I can refer to my
` report, to a bit more detailed discussion of
` it.
` But, sorry, it's a bit open-ended
` question, "What is GLP-1."
` Q. So prior to working on this
` matter, did you ever work with GLP-1?
` A. No, sir. I had not worked with
` GLP-1, specifically that peptide.
` Q. Okay. And you're familiar with
` human growth hormone?
` A. Yes. I am familiar with human
` growth hormone.
` Q. And human growth hormone is a
` protein, right?
` A. It -- again, it is a very
` large -- it's a sufficiently large peptide,
`
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`Mylan Institutional v. Novo Nordisk
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` we'll say, that I would start to call it a
` protein.
` When I have myself made human
` growth hormone or the other animal analogue,
` such as a rat growth hormone, instead of
` making it synthetically, I've utilized
` E. coli, for example, a natural cell
` machinery to produce it because it's of a
` size point that that's more efficient.
` But I would say generally, we
` could call it a protein even though it could
` be made synthetically, although it would be
` a bit more expensive than to make it in a
` bio-organism.
` Q. Do you know how many amino acids
` human growth hormone is?
` A. I am forgetting off the top of my
` head, sadly. I would have to -- I just had
` a paper a few years ago where we were
` looking at the mass spectrometry of it.
` It's just around 20 kilodaltons-ish. So
` it's -- I'd have to guess.
` As I said, this is sad that I'm
` forgetting right at this moment, but I don't
`
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`Novo Nordisk Ex. 2079, P. 21
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` L. Forrest
` know if that's that important.
` Q. Does 191 amino acids sound right?
` A. 191 sounds fairly all right.
` That would make sense with about the
` relative size of it compared to insulin or
` GLP-1.
` Q. Right.
` And GLP-1, you said, is a 37
` amino acid peptide?
` A. Well, there's a pre and a post
` section of it. The full GLP-1 is a 37 amino
` acid peptide.
` Q. But the peptide that forms the
` basis for liraglutide -- first of all, you
` know what liraglutide is?
` A. Yes.
` Q. It's the compound that Mylan
` seeks to make a product with that as its
` active ingredient; is that right?
` MR. WHITE: Objection, relevance.
` THE WITNESS: Liraglutide is the
` peptide that is discussed -- or the drug
` discussed in the patent here.
`
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`Novo Nordisk Ex. 2079, P. 22
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`IPR2020-00324
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` L. Forrest
` BY MR. OELKE:
` Q. And it's the active ingredient in
` Victoza, right?
` A. I believe so, yes.
` Q. So the GLP-1 structure for
` liraglutide is the 7-37 form of GLP-1,
` right?
` A. You mean the 7 to 37 subunit or
` portion of it?
` Q. Correct.
` A. Yes.
` Q. That's right. So that's 31 amino
` acids, correct?
` A. 7 to 37, that would be 31, yes.
` Q. So human growth hormone is 191
` amino acids and GLP-1 7-37 is about 31 amino
` acids, right?
` A. Yes, about 191 and about 31,
` correct, yes.
` Q. So the human growth hormone is
` about six times the size of the GLP-1.
` MR. WHITE: Object to form.
` BY MR. OELKE:
` Q. That's relevant for the '833
`
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`IPR2020-00324
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` L. Forrest
` patent, right?
` A. The human growth hormone, yes, it
` is about approximately six times more amino
` acids than --
` Q. Right.
` A. -- GLP-1.
` Q. And the structure of human growth
` hormone has disulfide bonds, right?
` A. I do recall within it is
` disulfide bonds. Especially when we were
` working with it, that was one of the things
` we had to deal with, was correct formulation
` of the disulfide bonds, and one of the
` reasons that it was advantageous to use a
` microorganism versus purely synthetic means
` to make it.
` Q. And the human growth hormone
` molecule is a much more rigid molecule than
` the GLP-1 7-37 molecule, right?
` MR. WHITE: Objection to form.
` THE WITNESS: Well, I'm not quite
` sure what you mean with rigid.
` Understand that proteins have various
` domains to them that can have different
`
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` L. Forrest
` degrees of flexibility.
` And some of those domains may not
` be so important in their behavior, for
` example, in solution as some of the
` other domains. They certainly have
` commonality, such as alpha helix
` structures which are within human growth
` hormone, and alpha helix structures that
` are within GLP-1.
` BY MR. OELKE:
` Q. So you don't believe human growth
` hormone is a more rigid molecule than GLP-1
` 7-37?
` MR. WHITE: Objection to form.
` THE WITNESS: Again, it depends on
` what you mean by "rigid." That's a --
` within protein-speak, that is an
` incredibly vague, unqualified term.
` BY MR. OELKE:
` Q. Okay. It's not a term you would
` use to describe proteins?
` A. I said it can be vague and -- but
` you would use rigidity, say, to possibly
` refer to a specific domain or portion of a
`
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` L. Forrest
` protein. But it by itself, just saying
` "rigid" doesn't mean a great deal,
` especially for a still relatively small
` protein like human growth hormone.
` Realize, it's what we would
` call -- even if you are to just call it a
` protein, it's still quite a small one.
` Q. Six times the size of GLP-1,
` though?
` A. Six times larger, but still a
` very small protein. Compare that serum
` albumin, which is the major protein of our
` blood, is over nearly 78,000 daltons. And
` we have processes in our bodies such as
` renal filtration that works as a molecular
` sieve and filters out molecules. And we
` often think of small molecules being cleared
` renally quickly because they're very small.
` So in that context, we consider
` small to be less than 20 kilodaltons, and
` human growth hormone would fall in that
` range where it would be small enough to be
` susceptible to renal filtration, similarly
` to aspirin or, you know, even other smaller
`
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` L. Forrest
` molecules -- unlike, say, human albumin or
` IGG antibody that would be closer to
` 200 kilodaltons.
` Q. So does the FDA consider human
` growth hormone to be a protein or a peptide?
` MR. WHITE: Objection to form.
` Relevance.
` MR. OELKE: Counsel, you don't
` need to make relevance objections, as
` you know. So "form" is sufficient.
` MR. WHITE: That's permissible
` under the Trial Practice Guides, but...
` THE WITNESS: The FDA considers it
` under the subgroup of biologics.
` So I haven't looked at, say, an
` ANDA or FDA approval documents to know
` the exact terminology they used on it in
` describing it, but it falls under their
` biologics division.
` BY MR. OELKE:
` Q. Okay.
` A. Versus, say, small molecules
` division.
` Q. And what about GLP-1 products?
`
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` L. Forrest
` How does the FDA categorize those products?
` MR. WHITE: Object to form.
` THE WITNESS: Again, I haven't
` looked at the FDA's documentation or how
` this particular molecule was submitted
` to them for review, so I honestly cannot
` tell you exactly off the top of my head
` how they considered it.
` BY MR. OELKE:
` Q. After you were at the University
` of Illinois, what did you do next?
` A. After I was at the University of
` Illinois, I was -- I enjoyed analysis, and
` my friends can tell you I enjoyed arguing to
` some extent, and I thought I wanted to be
` what you are. So I applied to law schools
` and I -- because patents interest me.
` I deferred, though, and went and
` worked at a law firm in Chicago for a few
` months, assisting in the writing of patents
` and various other functions within the firm.
` Q. And that's the Beem Patent Law
` Firm?
` A. Yes, sir. That is the Beem
`
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` L. Forrest
` Patent Law Firm.
` Q. Okay. And when did you finish at
` the Beem Patent Law Firm? Was that in 2004?
` A. Yes, that was in 2004.
` Q. And what did you do next?
` A. I began a postdoc in
` pharmaceutics at the University of
` Wisconsin.
` Q. Okay. And what was the focus of
` your research in that postdoc?
` A. The focus of my research was
` predominantly drug formulation.
` Q. And did you work on peptide drug
` formulation while you were at Wisconsin?
` A. I worked on a variety of
` formulations. I worked on some small
` molecule. I worked on some polymeric
` medications, if that almost makes sense. I
` would have to -- it's a bit difficult to
` explain.
` I worked on some peptide, or
` there were peptides in formulation. I
` worked on some protein formulation. I
` didn't get into what I'd call very, very
`
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` large proteins, but I did work, again, if I
` recall -- although we didn't publish it, I
` believe I had, again, some work with insulin
` or insulin-like analogue again.
` I did some work for the --
` Wisconsin had a formulation service for
` outside companies, and I occasionally got
` pulled onto a project or two there that were
` proprietary and didn't lead to publications,
` but it paid part of my salary, so -- or gave
` my boss some money, so what do you do?
` Q. And when you completed that
` postdoc, what did you do?
` A. After I completed that postdoc, I
` had a position at Kansas already, but I
` decided to go to the Washington State
` University for a few months.
` And after that, I then started my
` position at Kansas.
` Q. And you're still at the
` University of Kansas; is that right?
` A. Yes, sir. That is correct.
` Q. Okay. And you've been in the
` Department of Pharmaceutical Chemistry at
`
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` University of Kansas the entire time you've
` been there?
` A. Yes. That is my primary
` appointment.
` Q. Okay. And while you've been at
` Kansas, have you worked on the formulation
` of peptides or proteins?
` A. Yes. Both.
` Q. And which peptides and proteins
` have you worked on?
` A. Well, two of the peptides are
` proprietary under company contracts. I can
` tell you one of them was a dimer, so a
` fairly smaller peptide. Another one
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