Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` MYLAN INSTITUTIONAL
` LLC,
` Petitioner
`
` vs.
`
` NOVO NORDISK A/S,
` Patent Owner
`
` : Case No.
` : IPR2020-00324
` :
` : U.S. Patent No.
` : 8,114,833
` :
` :
` :
`* *
`*
` TUESDAY, NOVEMBER 24, 2020
`CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
`*
`* *
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` Videotaped deposition of TINA B.
`PEDERSEN, PH.D. taken remotely, commencing at
`8:04 a.m. before Debbie Leonard, Registered
`Diplomate Reporter, Certified Realtime
`Reporter.
`
`1-800-336-6646
`
`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 1
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` MYLAN INSTITUTIONAL
` LLC,
` Petitioner
`
` vs.
`
` NOVO NORDISK A/S,
` Patent Owner
`
` : Case No.
` : IPR2020-00324
` :
` : U.S. Patent No.
` : 8,114,833
` :
` :
` :
`* *
`*
` TUESDAY, NOVEMBER 24, 2020
`CONFIDENTIAL - PURSUANT TO PROTECTIVE ORDER
`*
`* *
`
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` Videotaped deposition of TINA B.
`PEDERSEN, PH.D. taken remotely, commencing at
`8:04 a.m. before Debbie Leonard, Registered
`Diplomate Reporter, Certified Realtime
`Reporter.
`
`1-800-336-6646
`
`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 1
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Page 2
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`APPEARANCES (all appearing remotely):
` PERKINS COIE LLP
` BY: EMILY J. GREB, ESQ.
` 33 East Main Street
` Suite 201
` Madison, Wisconsin 53703
`(608) 663-7494
` egreb@perkinscoie.com
` Representing the Petitioner Mylan
` Institutional
`
` PERKINS COIE LLP
` BY: BRANDON M. WHITE, ESQ.
` 700 13th Street, NW
` Suite 800
` Washington, D.C. 20005
`(202) 654.6206
` bmwhite@perkinscoie.com
` Representing the Petitioner Mylan
` Institutional
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 2
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 3
`
` WINSTON & STRAWN LLP
` BY: SHARON LIN, ESQ.
` 1901 L Street NW
` Washington, D.C. 20036
` (202) 282-5756
` slin@winston.com
` Representing the Petitioner Pfizer
` Incorporated
`
` FENWICK & WEST LLP
` BY: RYAN JOHNSON, ESQ.
` 902 Broadway
` Suite 14
` New York, New York 10010
` (212) 430-2746
` ryan.johnson@fenwick.com
` Representing the Patent Owner and the
` Witness
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`(continued)
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 3
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`APPEARANCES (continued):
`
`Page 4
`
`ALSO PRESENT:
`
` Signe Konkel, Esq.
` Novo Nordisk
`
` Sandra Weisberger Bullen, Esq.
` Novo Nordisk
`
` George Inmon, Videographer
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 4
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24. 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`INDEX TO WITNESSES
`
`WITNESS:
`
`TINA B. PEDERSEN, PH.D.
`
`BY MS. GREB
`
`BY MR.
`
`JOHNSON
`
`BY MS. GREB
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`71
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`76
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`PREVIOUSLY MARKED EXHIBITS REFERENCED
`
`EXHIBIT
`
`DESCRIPTION
`
`PAGE
`
`REFERENCED
`
`Declaration of Tina
`
`22
`
`Bjeldskov Pedersen,
`
`Ph.D.
`
`1-800-336-6646
`
`Ace-Federal Reporters. Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 5
`
`Mylan Institutional v. Novo Nordisk
`IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 6
`
` PREVIOUSLY MARKED EXHIBITS REFERENCED
` (continued)
` EXHIBIT DESCRIPTION PAGE
` REFERENCED
`Exhibit 2064
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` REPORTER'S NOTE: All quotations from exhibits
` are reflected in the manner in which they
` were read into the record and do not
` necessarily indicate an exact quote from the
` document.
`
`1-800-336-6646
`
`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 6
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 7
`
` THE VIDEOGRAPHER: Good
` morning. My name is George Inmon, and
` I'm with BlueBear Solutions.
` I will not be in the same room
` as the witness today, nor will the
` court reporter, Debbie Leonard. Thus,
` I will be recording this deposition
` remotely, and the court reporter will
` swear the witness remotely.
` This is the start of the remote
` video-recorded deposition of Tina
` Pedersen, in the case of Mylan
` Institutional LLC v. Novo Nordisk A/S,
` case number IPR2020-00324.
` We are now on the record.
` Today's date is November the 24th,
` 2020. The time is now 8:04 a.m.
` Eastern time.
` Attorneys, please make voice
` introductions.
` MS. GREB: Good morning. My
` name is Emily Greb. I represent
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`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 7
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 8
`
` petitioner Mylan Institutional.
` With me today is Brandon White,
` also from Perkins Coie.
` MR. JOHNSON: I'm Ryan Johnson,
` from Fenwick & West, on behalf of
` patent owner and the witness.
` And with me today are Signe
` Konkel and Sandra Weisberger Bullen,
` both from Novo Nordisk.
` MS. LIN: This is Sharon Lin,
` from Winston & Strawn, on behalf of
` Petitioner Pfizer Incorporated.
` THE VIDEOGRAPHER: If that's
` everyone, the court reporter will now
` swear in the witness.
` * * *
` TINA B. PEDERSEN, PH.D.,
` having been first duly sworn, testified as
` follows:
` * * *
` EXAMINATION
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 8
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 9
`
` BY MS. GREB:
` Q. Good morning. As I mentioned,
` my name is Emily Greb. It's nice to meet
` you.
` Could you please state and
` spell your name for the record to begin?
` A. Tina Bjeldskov Pedersen,
` T-I-N-A, B-J-E-L-D-S-K-O-V, P-E-D-E-R-S-E-N.
` Q. Thank you.
` And I understand that you've
` been deposed before, correct?
` A. Yes.
` Q. How many times?
` A. Three times.
` Q. Were those all related to the
` '833 patent?
` A. Yes.
` Q. So given that, I'm sure you
` know the routine today, but I'll give you a
` few quick reminders just to make sure we're
` on the same page. Okay?
` A. Yes.
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 9
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 10
`
` Q. Okay. As I think you know,
` your counsel may object to some of the
` questions I ask today, but unless you hear
` him instruct you not to answer, you should
` still answer my questions.
` Do you understand?
` A. Yes.
` Q. And I want to make sure that
` you understand the questions that I'm going
` to be asking. If you don't understand or
` need clarification, please let me know.
` Otherwise, I'll assume that you understood
` the question.
` Is that okay?
` A. Yes.
` Q. And you're doing a great job of
` it already, but just a reminder, for the
` record and the court reporter, please
` remember to give a verbal yes-or-no answer
` rather than uh-huhs or nodding your head; is
` that fair?
` A. Yes.
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`
`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 10
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 11
` Q. Do you understand that you're
` not to discuss the substance of your
` testimony with anyone, including your
` counsel, during any break today?
` A. Yes.
` Q. And given that this is a remote
` virtual deposition, can you please confirm
` that you'll also not be discussing your
` testimony with anyone via any other mediums
` today, such as e-mails, text, or instant
` messaging during the deposition?
` A. Yes.
` Q. Okay. Doctor, what did you do
` to prepare for today's deposition?
` MR. JOHNSON: Dr. Pedersen, you
` can answer that question generally,
` but don't divulge any of the details
` of any communications you may have had
` with counsel answering that question.
` Okay?
` THE WITNESS: I met with my
` lawyers.
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`
`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 11
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 12
`
` BY MS. GREB:
` Q. And which lawyers were those?
` A. That is Ryan and Jeff.
` Q. And -- oh, I'm sorry. I
` thought you were finished. Please continue.
` A. And Sandra and Signe.
` Q. And when did you meet with
` them?
` A. I met with them twice.
` Q. And when were those meetings?
` A. That was last Friday and
` yesterday.
` Q. Okay. And how long were the
` meetings?
` A. Around a couple of hours. Two,
` three hours.
` Q. You put a declaration together
` for this case; is that correct?
` A. Yes.
` Q. When you were preparing for
` your deposition, did you review that
` declaration?
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 12
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 13
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` A. Yes.
` Q. In that declaration, you cite
` to another -- a number of documents. Did you
` review those documents in preparing for your
` deposition today?
` A. Yes.
` Q. Did you review any documents
` that are not cited in your declaration when
` you prepared for today's deposition?
` MR. JOHNSON: Dr. Pedersen,
` let's start by answering that question
` "Yes" or "No" or "I don't know."
` THE WITNESS: Yes.
` BY MS. GREB:
` Q. What documents did you review
` for your deposition today that were not cited
` in your declaration?
` MR. JOHNSON: And,
` Dr. Pedersen, I'm going to instruct
` you not to answer that question on the
` grounds that it's attorney-client
` privilege and attorney work product
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 13
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 14
`
` doctrine.
` BY MS. GREB:
` Q. Did any of the documents that
` you reviewed to prepare for your deposition
` today that are not cited in your declaration
` refresh your recollection?
` MR. JOHNSON: Dr. Pedersen, you
` can answer that question "Yes" or
` "No," or "I don't know," I suppose.
` THE WITNESS: I don't know.
` BY MS. GREB:
` Q. Do you understand what the
` phrase "refresh your recollection" means?
` A. Yes.
` Q. Did any of the documents that
` you reviewed for your deposition today that
` were not cited in your declaration refresh
` your recollection?
` MR. JOHNSON: Objection. Asked
` and answered.
` Dr. Pedersen, I'm going to give
` you the same counsel that I gave you
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 14
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 15
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` last time that question was asked.
` You can answer "Yes," "No," "I don't
` know."
` THE WITNESS: I don't know.
` BY MS. GREB:
` Q. What about my question is
` confusing?
` A. I don't understand the
` question.
` Q. Okay. So you testified that
` you understand what it means to refresh your
` recollection, right?
` A. Yes.
` Q. Okay. So what part of my
` question needs to be rephrased?
` A. All of it.
` Q. You -- did you review documents
` not cited in your declaration to prepare for
` today's deposition?
` MR. JOHNSON: Objection. Asked
` and answered.
` THE WITNESS: Yes.
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`Ace-Federal Reporters, Inc.
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`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 15
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
`
`Page 16
`
` BY MS. GREB:
` Q. Did any of those documents
` cause you to have your recollection refreshed
` where you, for example, may have remembered
` something you didn't remember before
` reviewing the documents?
` MR. JOHNSON: Objection. Asked
` and answered.
` Dr. Pedersen, you can answer,
` but I'm just going to counsel you not
` to reveal the substance of any
` communications you had with counsel in
` answering the question.
` THE WITNESS: I don't know.
` BY MS. GREB:
` Q. What do you mean, you don't
` know?
` A. I don't know if it refreshed my
` memory.
` Q. Are there documents that you
` reviewed that caused you to remember
` something you may not previously have
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`Ace-Federal Reporters, Inc.
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`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 16
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 17
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` remembered?
` MR. JOHNSON: Objection. Asked
` and answered.
` THE WITNESS: I don't know.
` BY MS. GREB:
` Q. You don't know if you
` remember -- didn't remember something? I'm
` trying to understand so that we can -- we can
` get to a place where you can answer my
` question, and I'm having a little trouble
` with what you're confused about.
` Is there something that you
` reviewed that caused you to remember
` something you didn't remember before?
` MR. JOHNSON: Objection. Asked
` and answered.
` THE WITNESS: I don't know.
` BY MS. GREB:
` Q. We can come back to that later.
` Did you review -- I'm sorry.
` Let me rephrase.
` Do you understand that someone
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`Novo Nordisk Ex. 2101 P. 17
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 18
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` named Mr. Nolan submitted a declaration in
` this proceeding as well?
` A. If I understand?
` Q. Yeah, do you understand that
` someone named Mr. Nolan, who you reference in
` your declaration, also submitted a
` declaration in this case?
` A. Yes.
` Q. Have you reviewed that
` declaration?
` A. No.
` Q. Do you know -- do you
` understand that one of your co-inventors,
` Ms. Engelund, submitted a declaration in this
` proceeding as well?
` A. Yes.
` Q. Have you reviewed her
` declaration?
` A. No.
` Q. Did you -- do you understand
` that Ms. Engelund was deposed last week in
` this proceeding?
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`Novo Nordisk Ex. 2101 P. 18
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 19
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` A. Yes.
` Q. Have you reviewed her
` deposition transcript?
` A. [Indiscernible.]
` THE REPORTER: I'm sorry.
` BY MS. GREB:
` Q. Have you spoken to Ms. Engelund
` since her deposition?
` THE REPORTER: I'm sorry. I
` missed that answer.
` MS. GREB: To which question?
` MR. JOHNSON: It was a "No,"
` but I think the audio cut out.
` THE REPORTER: The question
` was, "Have you reviewed her deposition
` transcript?"
` THE WITNESS: No.
` THE REPORTER: Thank you.
` MR. JOHNSON: Dr. Pedersen, are
` you hearing us okay over there in
` Denmark? Is the Wi-Fi signal strong?
` THE WITNESS: Yes, it's fine.
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`Novo Nordisk Ex. 2101 P. 19
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 20
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` MR. JOHNSON: Okay. Sorry,
` Emily.
` BY MS. GREB:
` Q. Have you spoken to Ms. Engelund
` since her deposition last Friday?
` A. No.
` Q. Have you spoken to Ms. Engelund
` about this case at all?
` A. No.
` Q. Do you --
` A. [Indiscernible.]
` Q. I'm sorry. Go ahead.
` A. The only thing we have spoken
` about is that she is going to be deposed and
` I'm going to be deposed. We have not talked
` about the case.
` Q. Nothing about the substance?
` A. No.
` Q. Do you have any hard copies of
` documents with you today?
` A. Yes.
` Q. What do you have with you?
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`
`Novo Nordisk Ex. 2101 P. 20
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 21
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` A. I have the declaration.
` Q. Do you have any of the
` documents cited in your declaration?
` A. Yes.
` Q. Do you have all of the
` documents cited in your declaration?
` A. Yes.
` Q. Do you have any additional
` documents with you other than your
` declaration, which was marked in this
` proceeding 2024, or the documents cited in
` that declaration?
` A. No.
` Q. Are there any notes on any of
` the hard-copy documents you have with you
` today?
` A. No.
` Q. In preparing for your
` deposition today, did you discover any errors
` in your declaration?
` A. No.
` Q. So let's take a look at your
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`Novo Nordisk Ex. 2101 P. 21
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 22
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` declaration.
` MS. GREB: And, George, if we
` could also put it in the chat for
` folks. It's Exhibit 2024, please.
` * * *
` (Previously marked Exhibit 2024
` referenced.)
` * * *
` MS. GREB: And at the same
` time, we are also going to look at
` Exhibit 2068.
` * * *
` (Previously marked Exhibit 2068
` referenced.)
` * * *
` MS. GREB: So let's share that
` one as well. I think we may go back
` and forth a little bit.
` BY MS. GREB:
` Q. Do you have both of them,
` Doctor?
` A. Just a moment. I can only see
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`Novo Nordisk Ex. 2101 P. 22
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 23
`
` you on the screen.
` Q. Yeah, and if you have all the
` documents cited in your report, you should
` have the hard copy, too. This is one that
` you cited.
` A. Sorry. I couldn't hear the
` question because I looked at the screen. I
` could not see you. I was trying to solve
` that.
` Q. Oh, it's okay. I was just --
` it wasn't a question. I was just saying, if
` you have the hard copies of your declaration
` and the documents cited, you should have
` these because this is just your declaration
` and one of the documents you cite.
` A. Yes.
` Q. Okay. So let's -- so looking
` at Exhibit 2024, am I correct that this is
` the declaration you submitted in this case?
` A. That's correct.
` Q. If you could go to
` paragraph 15, which is on page 7. And this
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`Novo Nordisk Ex. 2101 P. 23
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 24
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` is the paragraph in which you discuss
` Exhibit 2068, correct?
` A. One moment.
` Yes.
` Q. And you authored Exhibit 2068;
` is that right?
` A. Yes.
`
`
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` Q.
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` Q. If we could go back to your
` declaration, paragraph 15. If you go sort of
` to the middle of that paragraph,
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` Do you see that section?
` A. Yes.
` Q. Okay. And then further down,
` you say,
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`Novo Nordisk Ex. 2101 P. 24
`Mylan Institutional v. Novo Nordisk
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`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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` Do you see that?
` A. Yes.
` Q.
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`Novo Nordisk Ex. 2101 P. 25
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
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` Q. Looking back at paragraph 15 of
` your declaration again, moving to page -- I
`
`1-800-336-6646
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`Novo Nordisk Ex. 2101 P. 26
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 27
` guess it's page 7 but page 8 of the exhibit,
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` MR. JOHNSON: Objection to
` form.
` THE WITNESS:
`
`
`
`
`
`
`
` BY MS. GREB:
` Q. And then you say that it's a
` true and correct accurate copy, correct?
` A. Correct.
` Q. You haven't offered any
` commentary in your declaration about the
` contents of Exhibit 2068, correct?
` A. I don't understand the
` question.
` Q. Your declaration doesn't say
` anything other than Exhibit 2068 is a true
` and correct copy and was made in the course
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`Novo Nordisk Ex. 2101 P. 27
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 28
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` of Novo's business, correct?
` MR. JOHNSON: Objection to
` form.
` THE WITNESS: I have to have
` the question again.
` BY MS. GREB:
` Q. Let me try one more time.
` You don't analyze Exhibit 2068
` in your declaration, do you?
` A. No, in the declaration I'm not
` concluding on the results on the report, if
` that's your question. I'm stating that
` the -- it's -- that the data has been
` generated and we have documented it and we
` have kept it as a record at Novo Nordisk.
` Q. So it would be fair to say
` that, in your declaration in this case, you
` haven't offered any opinions about the
` development of Novo's Victoza product,
` correct?
` A. Are you talking the full
` declaration now or just the paragraph 15?
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`Novo Nordisk Ex. 2101 P. 28
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 29
` Q. Let's stick with paragraph 15
` for now.
` In paragraph 15, you haven't
` offered any opinions about the development of
` Novo's Victoza product, correct?
` A. I'm stating that we have done
` the experiments at the time stated and we
` have kept the records.
` Q. And taking that out to your
` whole declaration, you also don't offer any
` opinions about the development of Novo's
` Victoza product in the entire declaration,
` correct?
` A. (Reviewing.)
` That's correct.
` Q.
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`Novo Nordisk Ex. 2101 P. 29
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
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`Novo Nordisk Ex. 2101 P. 30
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
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`Novo Nordisk Ex. 2101 P. 31
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
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` MR. JOHNSON: Objection to
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`Page 32
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`1-800-336-6646
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`Ace-Federal Reporters, Inc.
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`202-347-3700
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`Novo Nordisk Ex. 2101 P. 32
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`1-800-336-6646
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`Ace-Federal Reporters, Inc.
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`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 33
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
`
`
`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`1-800-336-6646
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`Ace-Federal Reporters, Inc.
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`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 34
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`1-800-336-6646
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`Ace-Federal Reporters, Inc.
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`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 35
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`
`Tina B. Pedersen - November 24, 2020
`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`1-800-336-6646
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`Ace-Federal Reporters, Inc.
`
`202-347-3700
`
`Novo Nordisk Ex. 2101 P. 36
`Mylan Institutional v. Novo Nordisk
` IPR2020-00324
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`Tina B. Pedersen - November 24, 2020
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