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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`STEADWVIED LTD.,
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`Petitioner,
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`v.
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`UNITED THERAPEUTICS CORPORATION
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`Patent Owner.
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`Case IPR2016-00006
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`Patent No. 8,497,393 B2
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`DECLARATION OF BORIS LEVINE UNDER 37 C.F.R. § 42.63(B)
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`1, Boris Levine, hereby declare:
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`1.
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`I am the President, owner, and chief Japanese translator at Technical
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`Language Services, Inc.
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`I am the head of its Far Eastern Languages Department
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`and am in charge of its Japanese-language—training program. Technical Language
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`Services, Inc., an ISO 9001-2008 certified translation company incorporated in the
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`WES'IUIWHI'HSSI
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`|PR2016—00006
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`SteadyMed - Exhibit 1020 - Page 1
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`Liquidia's Exhibit No. 1051
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`IPR2020-00770 - Page 001
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`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 001
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`state of Nevada, provides translation and interpretation services to companies in
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`the United States and around the world. Under my guidance, every month our
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`company delivers hundreds of written translations from Japanese to English to the
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`World Intellectual Property Organization in Geneva and numerous intellectual
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`property law firms in Japan.
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`2.
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`3.
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`I am fluent in the Japanese and English languages.
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`I have been translating Japanese patents since 1978, and have been
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`working as a Japanese translator in the United States since 1990.
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`4.
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`Prior to emigrating to the United States, I was employed in the Former
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`Soviet Union at GIPRONICKEL Research Institute in Saint Petersburg, where my
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`role was to translate technical scientific papers from Japanese to Russian.
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`I was a
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`translator there for 1 1 years.
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`5.
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`I requested that Technical Language Services employee James
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`Dowdle, one of our company's translators who is fluent in the Japanese and
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`English languages, provide a translation that is a true and accurate translation of
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`the Japanese Patent Application No. 56-122328A (Kawakami), Crystalline Amine
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`Salt of Methanoprostacyclin Derivative, Manufacturing Method Thereof, and
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`Purifying Method Thereof.
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`WESNb‘JlUTlSJ |
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`|PR2016-00006
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`SteadyMed - Exhibit 1020 - Page 2
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`Liquidia's Exhibit No. 1051
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`IPR2020-00770 - Page 002
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`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 002
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`6.
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`Mr. Dowdle is a Japanese-to-English translator who is competent to
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`translate this patent application and who has been receiving continuous training as
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`a Japanese translator since joining the company in 2012.
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`7.
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`I personally checked, using my expertise in Japanese and English, that
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`the English translation that Mr. Dowdle created is a true and accurate translation of
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`the Japanese Patent Application No. 56-122328A (Kawakami), Crystalline Amine
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`Salt of Methanoprostacyclin Derivative, Manufacturing Method Thereof, and
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`Purifying Method Thereof, and provided a declaration dated September 22, 2015,
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`to the Board.
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`(Ex. 1011).
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`8.
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`It is the practice in our industry that the relevant company officer, not
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`the original translator, provides the certification that the translation is true and
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`accurate. That is why I, and not Mr. Dowdle, provided the declaration of
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`September 22, 2015.
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`9.
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`I again confirm, based on my personal knowledge of the Japanese and
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`English languages, that the translation my ISO-certified company provided at Ex.
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`1007 is a true and accurate translation of the Japanese Patent Application No. 56—
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`122328A (Kawakami), Crystalline Amine Salt of Methanoprostacyclin Derivative,
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`Manufacturing Method Thereof, and Purifying Method Thereof.
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`I hereby declare that all statements made herein are of my own personal
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`knowledge; all statements made on information and belief are believed to be true;
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`WESTQCI‘IIW I 83.1
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`|PR2016-00006
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`SteadyMed - Exhibit 1020 - Page 3
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`Liquidia's Exhibit No. 1051
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`IPR2020-00770 - Page 003
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`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 003
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`and all statements were made with the knowledge that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both. under Section
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`1001 of Title 18 of the United States Code.
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`$1905 (Jul/1L,»—
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`Boris Levine
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`President
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`Technical Language Services, Inc.
`April
`lg
`, 2016
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`WEST\26‘3107183 I
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`|PR2016-00006
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`SteadyMed - Exhibit 1020 - Page 4
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`Liquidia's Exhibit No. 1051
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`IPR2020-00770 - Page 004
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`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 004
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the attached DECLARATION OF
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`BORIS LEVINE UNDER 37 C.F.R. § 42.63(B), was served Via electronic mail to
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`the following:
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`Stephen B. Maebius
`George Quillin
`FOLEY & LARDNER LLP
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`UT3 93-IPR@foley.com
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`Shaun R. Snader
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`UNITED THERAPEUTICS CORP.
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`ssnader@unither.com
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`Douglas Carsten
`Richard Torczon
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`Robert Delafield
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`WILSON, SONSINI, GOODRICH & ROSATI
`dcarsten ws
`.com
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`rtorczon@wsgr.com
`bdelafield ws
`.com
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`Date: April 29, 2016
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`Respectfiilly submitted,
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`/s Stuart E. Pollack /
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`/s Lisa A. Haile /
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`Stuart E. Pollack, J .D., Ph.D.
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`Lisa A. Haile, J.D., Ph.D.
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`Reg. No. 43,862
`DLA Piper LLP (US)
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`Reg. No. 38,347
`DLA Piper LLP (US)
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`WEST\269107183.1
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`|PR2016-00006
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`SteadyMed - Exhibit 1020 - Page 5
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`Liquidia's Exhibit No. 1051
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`IPR2020-00770 - Page 005
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`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 005
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