UNITED STATES PATENT AND TRADEMARKOFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`STEADYMEDLTD.,
`
`Petitioner,
`
`V.
`
`UNITED THERAPEUTICS CORPORATION
`
`Patent Owner.
`
`Case IPR2016-00006
`
`Patent No. 8,497,393 B2
`
`DECLARATION OF BORIS LEVINE UNDER37 C.F.R. § 42.63(B)
`
`1, Boris Levine, hereby declare:
`
`l.
`
`I am the President, owner, and chief Japanese translator at Technical
`
`LanguageServices, Inc.
`
`I am the head of its Far Eastern Languages Department
`
`and am in charge ofits Japanese-language-training program. Technical Language
`
`Services, Inc., an ISO 9001-2008 certified translation companyincorporated in the
`
`WEST\269L07183.1
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 1
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 001
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 001
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`STEADYMEDLTD.,
`
`Petitioner,
`
`V.
`
`UNITED THERAPEUTICS CORPORATION
`
`Patent Owner.
`
`Case IPR2016-00006
`
`Patent No. 8,497,393 B2
`
`DECLARATION OF BORIS LEVINE UNDER37 C.F.R. § 42.63(B)
`
`1, Boris Levine, hereby declare:
`
`l.
`
`I am the President, owner, and chief Japanese translator at Technical
`
`LanguageServices, Inc.
`
`I am the head of its Far Eastern Languages Department
`
`and am in charge ofits Japanese-language-training program. Technical Language
`
`Services, Inc., an ISO 9001-2008 certified translation companyincorporated in the
`
`WEST\269L07183.1
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 1
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 001
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 001
`
`
`
`state of Nevada,providestranslation andinterpretation services to companiesin
`
`the United States and around the world. Under my guidance, every month our
`
`companydelivers hundredsofwritten translations from Japanese to English to the
`
`WorldIntellectual Property Organization in Geneva and numerousintellectual
`
`property law firms in Japan.
`
`2.
`
`3.
`
`I am fluentin the Japanese and English languages.
`
`I have beentranslating Japanese patents since 1978, and have been
`
`working as a Japanese translator in the United States since 1990.
`
`4,
`
`Prior to emigrating to the United States, I was employed in the Former
`
`Soviet Union at GIPRONICKELResearchInstitute in Saint Petersburg, where my
`
`role wasto translate technical scientific papers from Japanese to Russian.
`
`I was a
`
`translator there for 11 years.
`
`5.
`
`| requested that Technical Language Services employee James
`
`Dowdle, one of our company's translators whois fluent in the Japanese and
`
`English languages, provideatranslation that is a true and accurate translation of
`
`the Japanese Patent Application No. 56-122328A (Kawakami), Crystalline Amine
`
`Salt of Methanoprostacyclin Derivative, Manufacturing Method Thereof, and
`
`Purifying Method Thereof.
`
`WEST\269107183.1
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 2
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 002
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 002
`
`
`
`6.
`
`Mr. Dowdleis a Japanese-to-English translator who is competentto
`
`translate this patent application and whohasbeen receiving continuoustraining as
`
`a Japanese translator since joining the companyin 2012.
`
`ts
`
`I personally checked, using my expertise in Japanese and English, that
`
`the English translation that Mr. Dowdle createdis a true and accuratetranslation of
`
`the Japanese Patent Application No. 56-122328A (Kawakami), Crystalline Amine
`
`Salt of Methanoprostacyclin Derivative, Manufacturing Method Thereof, and
`
`Purifying Method Thereof, and provided a declaration dated September 22, 2015,
`
`to the Board.
`
`(Ex. 1011).
`
`8.
`
`It is the practice in our industry that the relevant companyofficer, not
`
`the original translator, providesthe certification that the translation is true and
`
`accurate. That is why I, and not Mr. Dowdle, provided the declaration of
`
`September 22, 2015.
`
`9.
`
`l again confirm, based on my personal knowledgeof the Japanese and
`
`English languages, that the translation my ISO-certified company provided at Ex.
`
`1007 is a true and accurate translation of the Japanese Patent Application No. 56-
`
`122328A (Kawakami), Crystalline Amine Salt of Methanoprostacyclin Derivative,
`
`Manufacturing Method Thereof, and Purifying Method Thereof.
`
`I hereby declare that all statements made herein are of my own personal
`
`knowledge;all statements made on information and belief are believed to be true;
`
`WEST\269107183.1
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 3
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 003
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 003
`
`
`
`and all statements were made with the knowledgethat willful false statements and
`
`the like so madeare punishable by fine or imprisonment, or both, under Section
`
`1001 ofTitle 18 of the United States Code.
`
`oe s Low oo
`
`Boris Levine
`President
`Technical Language Services,Inc.
`April
`| Y
`, 2016
`
`WEST\269107183 |
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 4
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 004
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 004
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the attached DECLARATION OF
`
`BORIS LEVINE UNDER37 C.F.R. § 42.63(B), was served via electronic mail to
`
`the following:
`
`Stephen B. Maebius
`George Quillin
`FOLEY & LARDNER LLP
`UT393-IPR@foley.com
`
`Shaun R. Snader
`UNITED THERAPEUTICS CORP.
`ssnader@unither.com
`
`Douglas Carsten
`Richard Torcezon
`Robert Delafield
`WILSON, SONSINI, GOODRICH & ROSATI
`dcarsten@wsegr.com
`rtorezon@wsgr.com
`bdelafield(@wsegr.com
`
`Date: April 29, 2016
`
`Respectfully submitted,
`
`/s Stuart E. Pollack /
`Stuart E. Pollack, J.D., Ph.D.
`Reg. No. 43,862
`DLA Piper LLP (US)
`
`/s Lisa A. Haile /
`Lisa A. Haile, J.D., Ph.D.
`Reg. No. 38,347
`DLA Piper LLP (US)
`
`WEST\269107183.1
`
`IPR2016-00006
`
`SteadyMed - Exhibit 1020 - Page 5
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 005
`
`Liquidia's Exhibit No. 1051
`IPR2020-00770 - Page 005
`
`
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