UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`REGENERON PHARMACEUTICALS, INC.,
`Petitioner,
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`v.
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`NOVARTIS PHARMA AG,
`NOVARTIS TECHNOLOGY LLC,
`NOVARTIS PHARMACEUTICALS CORPORATION,
`Patent Owner.
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`Case No. IPR2021-00816
`U.S. Patent No. 9,220,631
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`PETITIONER’S MOTION TO SEAL
`37 C.F.R. §§ 42.14 AND 42.54
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`REGENERON PHARMACEUTICALS, INC.,
`Petitioner,
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`v.
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`NOVARTIS PHARMA AG,
`NOVARTIS TECHNOLOGY LLC,
`NOVARTIS PHARMACEUTICALS CORPORATION,
`Patent Owner.
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`Case No. IPR2021-00816
`U.S. Patent No. 9,220,631
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`PETITIONER’S MOTION TO SEAL
`37 C.F.R. §§ 42.14 AND 42.54
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`I.
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`PRECISE RELIEF REQUESTED
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`Petitioner Regeneron Pharmaceuticals, Inc. (“Petitioner” or “Regeneron”)
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`moves to seal portions of Petitioner’s Reply to Patent Owners’ Response
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`(“Petitioner’s Reply”), portions of Petitioner’s Opposition to Patent Owner’s
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`Contingent Motion to Amend (“MTA Opposition”), portions of Exhibits 1100-
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`1102, 1105-1107, 1109, 1172, 1207-1208, 1210 that rely on confidential business
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`information, pursuant to 37 C.F.R. §§ 42.14 and 42.54. Petitioner also moves to
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`seal the entirety of Exhibits 1112-1114, 1116-1128, 1130-1162, 1167-1168, 1185,
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`1203, 1205-1206, 1211, 1213, 1215-1226, 1248-1249, and 1254-1256.
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`II. REASONS FOR THE REQUESTED RELIEF AND STATEMENT OF
`FACTS
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`A. Good Cause Exists for Sealing Confidential Information
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`The Board will seal documents for good cause. See 37 C.F.R. § 42.54(a); see
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`also Argentum Pharms. LLC v. Alcon Research, Ltd., Paper 27, 2 (2013). “The
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`rules aim to strike a balance between the public’s interest in maintaining a
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`complete and understandable file history and the parties’ interest in protecting truly
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`sensitive information.” Office Patent Trial Practice Guide, 77 Fed. Reg. 48756,
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`48760 (2012). The public’s interest in having access to confidential business
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`information that is only indirectly related to patentability is “minimal.” Garmin v.
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`Cuozzo, IPR2012-00001, Paper 36, 8-9 (2013) (granting a motion to seal an
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`agreement relating to the “commercializ[ation]” of the patent-at-issue).
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`The information that Regeneron seeks to seal is either Regeneron’s
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`confidential research and development information, Regeneron’s confidential
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`commercial and financial information, Novartis’s confidential research and
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`development information, or third party confidential information, as explained in
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`more detail below. To the undersigned’s knowledge, the information sought to be
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`sealed has not been published or otherwise made public. Public disclosure of
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`Regeneron’s, Novartis’s or third party confidential information would
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`competitively harm Regeneron’s, Novartis’s, and/or third parties’ business
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`prospects and put these companies at a competitive disadvantage relative to other
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`similarly positioned companies in the same industry. Therefore, good cause exists
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`to seal portions of Petitioner’s Reply, portions of Petitioner’s MTA Opposition,
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`portions of Exhibits 1100-1102, 1105-1107, 1109, 1172, 1207-1208, 1210 and the
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`entirety of Exhibits 1112-1114, 1116-1128, 1130-1162, 1167-1168, 1185, 1203,
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`1205-1206, 1211, 1213, 1215-1226, 1248-1249, and 1254-1256.
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`B.
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`Petitioner’s Reply and Opposition to MTA
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`Regeneron seeks to seal the portions of Petitioner’s Reply and Opposition to
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`MTA that discuss confidential information in the Exhibits that Regeneron currently
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`seeks to seal. For the same reasons that these exhibits should be sealed as discussed
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`below, there is good cause to seal the portions of the Reply and Opposition to
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`MTA that include confidential information appearing in at least Exhibits 1100-
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`1102, 1105, 1107, 1112-1114, 1116-1128, 1130-1162, 1167-1168, 1172, 1185,
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`1203, 1205-1208, 1211, 1213, 1215-1220, 1222-1226, 1248-1249, 1254-1256.
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`C. Exhibit 1100 (Agalloco Declaration)
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`Exhibit 1100 is a declaration from Petitioner’s expert witness, James
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`Agalloco. Portions of Exhibit 1100 describe and include Genentech’s and
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`Novartis’s confidential development and research information. Regeneron relies on
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`such confidential information to rebut Novartis’s arguments concerning
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`obviousness of the claims of the ’631 Patent. Portions of Exhibit 1100 describe
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`exhibits filed by Novartis under seal. See e.g. Ex. 1100, ¶ 50 (discussing Exhibit
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`2063, filed under seal). Portions of Exhibit 1100 also describe exhibits designated
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`by third party Genentech as Confidential in co-pending litigation. See e.g., Ex.
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`1100, ¶ 58 (discussing Exhibit 2106).
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`Novartis has asserted that similar confidential and proprietary research and
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`development information of Novartis and Genentech, if publicly disclosed, would
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`substantially harm Novartis’s and Genentech’s competitive positions in the pre-
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`filled syringe industry. See Paper 38 at 9-13. For example, Novartis has asserted
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`that documents with similar information, if not sealed, “would provide a
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`competitive advantage to the third party’s competitors to its detriment” and “would
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`harm Novartis because insight into its research and development processes would
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`provide a competitive advantage to Novartis’s competitors to Novartis’s
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`detriment.” Paper 38 at 10, 12. Therefore, good cause exists to seal portions of
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`Exhibit 1100.
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`D. Exhibit 1101 (Sawyer Declaration)
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`Exhibit 1101 is a declaration from Petitioner’s expert witness, Dr. Gregory
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`Sawyer. Portions of Exhibit 1101 describe and include Novartis’s and third party
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`Vetter’s confidential research and development information. Regeneron relies on
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`such information to support its argument regarding the invalidity of Novartis’s
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`proposed substitute claims. Portions of Exhibit 1101 describe exhibits filed by
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`Novartis under seal. See e.g. Ex. 1101, ¶¶ 72-73 (discussing Ex. 2143, filed under
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`seal). Portions of Exhibit 1101 also describe exhibits designated by third party
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`Vetter as Confidential in co-pending litigation. See e.g., Ex. 1101, ¶ 72.
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`Novartis has asserted that similar confidential and proprietary research and
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`development information of Novartis and its third party business partners, if
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`publicly disclosed, would substantially harm Novartis’s and its third party business
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`partner’s competitive positions in the pre-filled syringe industry. For example,
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`Novartis has asserted that documents with similar information, if not sealed,
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`“would harm Novartis and its third party business partners because Novartis’s
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`competitors would gain insight into Novartis’s business approaches and
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`commercial interests when collaborating with third parties, thereby placing
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`Novartis at a competitive disadvantage” and “would harm Novartis because insight
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`into its research and development processes would provide a competitive
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`advantage to Novartis’s competitors to Novartis’s detriment.” Paper 38 at 4, 13;
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`see also Id. at 6 (“good cause exists to seal . . . due to the presence of Novartis’s
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`confidential information and confidential information from a third party, the
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`disclosure of which would put Novartis and the third party at a competitive
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`disadvantage.”) Therefore, good cause exists to seal portions of Exhibit 1101.
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`E.
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`Exhibit 1102 (Graham Declaration)
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`Exhibit 1102 is a declaration from Petitioner’s fact witness, Dr. Kenneth
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`Graham. Portions of Exhibit 1102 describe and include Regeneron’s and third
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`party Steris’s confidential development and research information. This confidential
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`and proprietary research and development information of Regeneron and Steris, if
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`publicly disclosed, would substantially harm Regeneron’s and Steris’s competitive
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`positions in the pre-filled syringe industry. For example, this information, if not
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`sealed, would provide competitors with valuable information regarding
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`confidential research and development projects. Such information could also be
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`used by a competitor to improve its products. Moreover, portions of Exhibit 1102
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`describe exhibits designated by third party Steris as Confidential in co-pending
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`litigation. See e.g., Ex. 1102, ¶ 16. Therefore, good cause exists to seal portions of
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`Exhibit 1102.
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`F.
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`Exhibit 1105 (Koller Reply Declaration)
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`Exhibit 1105 is a declaration from Petitioner’s expert witness, Horst Koller.
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`Portions of Exhibit 1105 describe and include Novartis’s confidential development
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`and research information. Regeneron relies on such confidential information to
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`rebut Novartis’s arguments concerning obviousness of the claims of the ’631
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`Patent, and support Regeneron’s arguments concerning the unpatentability of
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`Novartis’s proposed substitute claims. Furthermore, portions of Exhibit 1105
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`describe and include confidential development, research, and regulatory
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`information from Bausch and Beckon Dickinson, which those parties designated as
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`confidential in co-pending litigation. See e.g. Ex. 1105, ¶¶ 138-141, 144-145.
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`Regeneron relies on such confidential information to support its arguments
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`regarding the unpatentability of Novartis’s proposed substitute claims. Moreover,
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`portions of Exhibit 1105 describe exhibits filed by Novartis under seal. See e.g. Ex.
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`1105, ¶¶ 117-120 (discussing Exs. 2142-2143, filed under seal).
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`This confidential and proprietary research and development information, if
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`publicly disclosed, would substantially harm Novartis, Bausch, and Beckon
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`Dickson’s competitive positions in the pre-filled syringe industry. For example,
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`this information, if not sealed, would provide competitors with valuable
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`information regarding confidential research and development projects. See also
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`Paper 38 at 12-13. Such information could also be used by a competitor to improve
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`its products. Therefore, good cause exists to seal portions of Exhibit 1105.
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`G. Exhibit 1106 (Kiss Reply Declaration)
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`Exhibit 1106 is a declaration from Petitioner’s expert witness, Dr. Szilárd
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`Kiss. Portions of Exhibit 1106 describe and include Novartis’s confidential
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`research and development information. Regeneron relies on such information to
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`rebut Novartis’s arguments concerning obviousness of the claims of the ’631
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`Patent. Moreover, portions of Exhibit 1106 describe exhibits filed by Novartis
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`under seal. See e.g. Ex. 1106, ¶ 32 (discussing Ex. 2171, filed under seal).
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`Novartis has asserted that similar confidential and proprietary research and
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`development information of Novartis, if publicly disclosed, would substantially
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`harm Novartis’s competitive positions in the pre-filled syringe industry. For
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`example, Novartis has asserted that documents with similar information, if not
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`sealed, “would provide a competitive advantage to the third party’s competitors to
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`its detriment” and “would harm Novartis because insight into its research and
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`development processes would provide a competitive advantage to Novartis’s
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`competitors to Novartis’s detriment.” Paper 38 at 10, 12. Therefore, good cause
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`exists to seal portions of Exhibit 1106.
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`H. Exhibit 1107 (Cameron Declaration)
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`Exhibit 1107 is a declaration from Petitioner’s expert witness, Lisa
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`Cameron. Portions of Exhibit 1107 describe and include Regeneron’s, Novartis’s,
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`and Genentech’s confidential financial and commercial information. Regeneron
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`relies on such confidential financial information to support its argument regarding
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`secondary considerations and nexus to the claims of the ’631 Patent. Moreover,
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`portions of Exhibit 1107 describe exhibits filed by Novartis under seal, and
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`exhibits designated as confidential by third party Genentech that were produced in
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`co-pending litigation. See e.g. Ex. 1107, ¶ 19 (discussing Ex. 2009, produced by
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`Genentech in co-pending litigation and filed under seal), ¶ 44 (discussing Ex. 2169,
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`containing Novartis CBI and filed under seal).
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`This confidential and proprietary financial and commercial information of
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`Novartis, Regeneron and Genentech, if publicly disclosed, would substantially
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`harm their competitive position in the pre-filled syringe industry. For example, this
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`information, if not sealed, would provide competitors with valuable information
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`regarding confidential research and development projects, as well as sensitive
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`financial and market information. See also Paper 38 at 9-13. Therefore, good
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`cause exists to seal portions of Exhibit 1107.
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`I.
`Exhibits 1109, 1172, 1207-1208, 1210-1211, 1213 (IPR Deposition
`Transcripts)
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`Exhibits 1109, 1172, 1207-1208, 1210-1211, and 1213 are cross-examination
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`deposition transcripts of Novartis witnesses taken in this IPR proceeding. Regeneron
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`seeks to seal portions of Ex. 1109 (Cameron Dep. Tr.), Ex. 1172 (Malackowski Dep.
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`Tr.), Ex. 1207 (Leinsing Dep. Tr.), Ex. 1208 (Calman Dep. Tr.), Ex. 1210 (Miller
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`Dep. Tr.), and the entirety of Ex. 1211 (Picci Dep. Tr.) and Ex. 1213 (Sigg Dep. Tr.).
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`Each of Exhibits 1109, 1172, 1207-1208, 1210-1211, and 1213 contain
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`confidential information from exhibits filed by Novartis under seal. See e.g. Ex. 1172
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`at 27:3-33:1 (discussing confidential Ex. 2124); Ex. 1207 at 151:15-156:9
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`(discussing confidential Ex. 2102). Moreover, Novartis filed under seal at least one
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`declaration from each of these witnesses in this IPR proceeding, whereas the
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`deposition transcripts of these witnesses discuss such declarations. Therefore,
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`Exhibits 1109, 1172, 1207-1208, 1210-1211, and 1213 contain information which
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`the Board has deemed confidential and proper for sealing. Accordingly, good cause
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`exists to seal portions of Exhibits 1109, 1172, 1207-1208, 1210, and the entirety of
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`1211 and 1213.
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`J.
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`Exhibits 1158-1161 (ITC Deposition Transcripts)
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`Exhibits 1158-1161 are deposition transcripts of Novartis fact witnesses taken
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`in related International Trade Commission (“ITC”) investigation regarding the ’631
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`Patent (the “ITC action”). See Certain Pre-Filled Syringes for Intravitreal Injection
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`and Components Thereof, Inv. No. 337-TA-1207. Exhibits 1158-1161 were marked
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`confidential and subject to the protective order entered into in the ITC action.
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`Regeneron relies on these deposition transcripts to rebut Novartis’s arguments
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`concerning the claims of the ’631 Patent, and to support its arguments concerning
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`the unpatentability of Novartis’s proposed substitute claims.
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`The transcripts contain confidential and propriety research and development
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`information of Novartis. Novartis has asserted that documents with similar
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`information, if not sealed, “would provide a competitive advantage to the third
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`party’s competitors to its detriment” and “would harm Novartis because insight into
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`its research and development processes would provide a competitive advantage to
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`Novartis’s competitors to Novartis’s detriment.” Paper 38 at 10, 12 Therefore, good
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`cause exists to seal Exhibits 1158-1161.
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`K. Exhibits 1112-1114, 1116-1125, 1127-1128, 1130-1136, 1203, 1217,
`1222-1226, 1254 (Novartis Confidential Documents)
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`Exhibits 1112-1114, 1116-1125, 1127-1128, 1130-1136, 1203, 1217, 1222-
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`1226, and 1254 are Novartis’s internal documents containing its confidential and
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`proprietary research, development, manufacture, and business information. These
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`documents were part of the record developed in the ITC action, and in that action,
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`these documents were subject to a protective order requiring that these documents
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`only be accessible by outside counsel. The parties to this IPR proceeding have
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`agreed to modify the protective order in this action to extend the same level of
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`protection for these documents as was provided in the ITC action. See Exhibit
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`2323. Regeneron relies on these exhibits to rebut Novartis’s arguments concerning
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`the claims of the ’631 Patent, and to support its arguments concerning the
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`unpatentability of Novartis’s proposed substitute claims.
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`Specifically, Exhibits 1112-1114, 1116-1125, 1127-1128, 1131-1136, 1203,
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`1217, 1222-1226, and 1254 are confidential Novartis internal memorandum and
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`presentations discussing the development and specifications of Lucentis PFS.
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`Exhibit 1130 is a confidential agreement between Novartis and a third party
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`relating to the development of Lucentis PFS.
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`Novartis has asserted that documents with similar information, if not sealed,
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`“would provide a competitive advantage to the third party’s competitors to its
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`detriment” and “would harm Novartis because insight into its research and
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`development processes would provide a competitive advantage to Novartis’s
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`competitors to Novartis’s detriment.” Paper 38 at 10, 12. Therefore, good cause
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`exists to seal Exhibits 1112-1114, 1116—1125, 1127-1128, 1130-1136, 1203,
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`1217, 1222-1226, and 1254.
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`L.
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`Exhibits 1137-1140, 1142-1157, 1185, 1205, 1248-1249 (Regeneron
`Confidential Documents)
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`Exhibits 1137-1140, 1142-1157, 1185, 1205, and 1248-1249 are
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`Regeneron’s internal documents containing its confidential and proprietary
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`research, manufacture, regulatory, financial, and business information. These
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`documents were part of the record developed in the ITC action, and in that action,
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`these documents were subject to a protective order requiring that these documents
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`only be accessible by outside counsel. The parties to this IPR proceeding have
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`agreed to modify the protective order in this action to extend the same level of
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`protection for these documents as was provided in the ITC action. See Exhibit
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`2323. Regeneron relies on these exhibits to rebut Novartis’s arguments concerning
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`the claims of the ’631 Patent, and to support its arguments concerning the
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`unpatentability of Novartis’s proposed substitute claims.
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`Specifically, Exhibits 1139-1140, 1145-1146, 1151, 1153, and 1155-1156
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`include confidential biologics license application filings for the Eylea PFS and
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`related confidential communications with the FDA, and contain Regeneron’s
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`confidential technical and regulatory information. Exhibits 1137-1138, 1142-
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`1144, 1147-1150, 1152, 1154 and 1185 are Regeneron’s internal confidential
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`documents relating to development and technical specifications of the Eylea PFS.
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`Exhibits 1157 and 1248-1249 are documents describing sales data of Eylea PFS.
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`Exhibit 1205 is a confidential manufacture agreement relating to Eylea PFS.
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`Such confidential technical information, if publically disclosed, would
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`substantially harm Regeneron’s competitive position in the pre-filled syringe
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`industry. This information, if not sealed, would provide competitors with valuable
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`information regarding confidential research and development projects. For example,
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`such information could also be used by a competitor to improve its products.
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`Moreover, disclosure of Regeneron’s financial information would lead to exposure
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`of Regeneron’s business models, thus harming Regeneron to its detriment.
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`Therefore, good cause exists to seal Exhibits 1137-1140, 1142-1157, 1185, 1205,
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`and 1248-1249.
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`M. Exhibits 1126 and 1167-1168 (Vetter Confidential Documents)
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`Exhibits 1126 and 1167-1168 consists of Vetter GmbH’s (“Vetter”) internal
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`documents produced in the ITC action. These exhibits containing Vetter’s
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`confidential and proprietary development and research information. These
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`documents were part of the record developed in the ITC action, and in that action,
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`these documents were subject to a protective order requiring that these documents
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`only be accessible by outside counsel. The parties to this IPR proceeding have
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`agreed to modify the protective order in this action to extend the same level of
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`protection for these documents as was provided in the ITC action. See Exhibit
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`2323. Regeneron relies on these exhibits to support its arguments regarding
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`secondary considerations and nexus to the claims of the ’631 Patent.
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`Specifically, Exhibit 1126 is a presentation describing Vetter’s confidential
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`development information relating to Lucentis PFS. Exhibits 1167-1168 are
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`confidential email correspondences discussing the development of Lucentis PFS.
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`Therefore, good cause exists to seal Exhibits 1126 and 1167-1168.
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`N. Exhibits 1162, 1215-1216, 1218 (Becton Dickinson Confidential
`Documents)
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`Exhibits 1162, 1215-1216, and 1218 consists of Beckon Dickinson & Co.’s
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`(“BD”) internal documents containing BD’s confidential and proprietary
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`development, research, and sales information. These documents were part of the
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`record developed in the ITC action, and in that action, these documents were
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`subject to a protective order requiring that these documents only be accessible by
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`outside counsel. The parties to this IPR proceeding have agreed to modify the
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`protective order in this action to extend the same level of protection for these
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`documents as was provided in the ITC action. See Exhibit 2323. Regeneron relies
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`on these exhibits to rebut Novartis’s arguments concerning the obviousness of the
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`631 Patent claims, and to support Regeneron’s argument relating to the
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`unpatentability of Novartis’s proposed substitute claims.
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`Specifically, Exhibit 1162 is a presentation describing confidential design
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`and specifications of certain BD products. Exhibit 1215 is the declaration of a BD
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`employee describing BD’s confidential commercial and sales information relating
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`to certain BD products. Exhibit 1216 is part of a confidential regulatory filing
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`describing confidential design and specifications of certain BD products. Exhibit
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`1218 is a confidential purchase order for certain BD products.
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`Public disclosure of the information in Exhibits 1162, 1215-1216, and 1218
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`would harm BD, a third party, because insights into BD’s technical and business
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`information would provide a competitive advantage to BD’s competitors to its
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`detriment. For example, such information could also be used by a competitor to
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`improve its products. Therefore, good cause exists to seal Exhibits 1162, 1215-1216,
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`and 1218.
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`O. Exhibits 1219-1221 (Bausch Confidential Documents)
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`Exhibits 1219-1221 consists of Bausch Health Co. Inc.’s (“Bausch”) internal
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`documents containing Bausch’s confidential and proprietary development,
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`research, and regulatory information. These documents were part of the record
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`developed in the ITC action, and in that action, these documents were subject to a
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`protective order requiring that these documents only be accessible by outside
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`counsel. The parties to this IPR proceeding have agreed to modify the protective
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`order in this action to extend the same level of protection for these documents as
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`was provided in the ITC action. See Exhibit 2323. Regeneron relies on these
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`exhibits to support its argument relating to the unpatentability of Novartis’s
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`proposed substitute claims.
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`Specifically, Exhibits 1219-1221 contain confidential FDA filings relating to
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`Macugen PFS, and confidential correspondences between Bausch and the FDA
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`regarding the same. Exhibits 1219-1221 therefore contain confidential information
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`relating the design and specifications of Macugen PFS.
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`Public disclosure of the information in Exhibits 1219-1221 would harm
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`Bausch, a third party, because insights into Bausch’s technical information would
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`provide a competitive advantage to Bausch’s competitors to its detriment. For
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`example, such information could also be used by a competitor to improve its
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`products. Therefore, good cause exists to seal Exhibits 1219-1221.
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`P.
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`Exhibit 1141 (Steris Confidential Document)
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`Exhibit 1141 is an internal development report containing Steris Co.’s
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`(“Steris”) confidential and proprietary development and research information
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`relating to Elyea PFS. Exhibit 1141 was part of the record developed in the ITC
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`action, and in that action, these documents were subject to a protective order
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`requiring that these documents only be accessible by outside counsel. The parties
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`to this IPR proceeding have agreed to modify the protective order in this action to
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`extend the same level of protection for these documents as was provided in the ITC
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`action. See Exhibit 2323.
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`Public disclosure of the information in Exhibit 1141 would harm Steris, a
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`third party, because insights into Steris technical and research information would
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`provide a competitive advantage to Genentech’s competitors to its detriment. For
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`example, such information could also be used by a competitor to improve its
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`products. Therefore, good cause exists to seal Exhibit 1141.
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`Q. Exhibit 1206 (Genentech Confidential Document)
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`Exhibit 1206 is an internal presentation that contains Genentech, Inc.’s
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`(“Genentech”) confidential and proprietary development and research information
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`16
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`relating to Lucentis PFS. Exhibit 1206 was part of the record developed in the ITC
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`action, and in that action, these documents were subject to a protective order
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`requiring that these documents only be accessible by outside counsel. The parties
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`to this IPR proceeding have agreed to modify the protective order in this action to
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`extend the same level of protection for these documents as was provided in the ITC
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`action. See Exhibit 2323.
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`Therefore, good cause exists to seal Exhibit 1206.
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`R. Exhibits 1255-1256 (Gilead Confidential Documents)
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`Exhibits 1255-1256 are Gilead Science Inc.’s (“Gilead”) confidential
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`financial documents containing sales information of Macugen PFS. Regeneron relies
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`on such information to support its arguments regarding unpatentability of Novartis’s
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`proposed substitute claims. Public disclosure of the information in Exhibit 1255-
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`1256 would lead to exposure of Gilead’s business models, thus harming Gilead, a
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`third party, to its detriment. Therefore, good cause exists to seal Exhibits 1255-1256.
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`III. CERTIFICATION OF NON-PUBLICATION
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`On Petitioner’s behalf, the undersigned counsel certifies that, to the best of
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`his knowledge, the sealed portions of Petitioner’s Reply, portions of Petitioner’s
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`MTA Opposition, portions of Exhibits 1100-1102, 1105-1107, 1172, 1207-1208,
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`1211, and 1213, and Exhibits 1112-1114, 1116-1128, 1130-1162, 1167-1168,
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`17
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`1185, 1203, 1205-1206, 1215-1226, 1248-1249, and 1254-1256 have not been
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`published or otherwise made public.
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`IV. CONCLUSION
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`Petitioner respectfully requests that the Board grant its motion to seal
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`portions of Petitioner’s Reply, portions of Petitioner’s MTA Opposition, portions
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`of Exhibits 1100-1102, 1105-1107, 1109, 1172, 1207-1208, 1210 and Exhibits
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`1112-1114, 1116-1128, 1130-1162, 1167-1168, 1185, 1203, 1205-1206, 1211,
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`1213, 1215-1226, 1248-1249, and 1254-1256.
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`Dated: April 15, 2022
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`Respectfully submitted,
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`/Anish R. Desai/ 1
`Anish R. Desai
`Reg. No. 73,760
`WEIL, GOTSHAL & MANGES LLP
`2001 M Street, NW, Suite 600
`Washington, DC 20036
`T: 212-310-8730
`E: anish.desai@weil.com
`
`Counsel for Petitioner
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`18
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on April 15, 2022, the foregoing
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`PETITIONER’S MOTION TO SEAL was served via electronic mail upon the
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`following:
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`Elizabeth J. Holland
`Daniel P. Margolis
`Allen & Overy LLP
`1221 Avenue of the Americas
`New York, NY 10020
`elizabeth.holland@allenovery.com
`daniel.margolis@allenovery.com
`
`Nicholas K. Mitrokostas
`John T. Bennett
`Allen & Overy LLP
`1 Beacon Street
`Boston, MA 02108
`nicholas.mitrokostas@allenovery.com
`john.bennett@allenovery.com
`
`William G. James
`Allen & Overy LLP
`1101 New York Avenue, NW
`Washington, D.C 20005
`william.james@allenovery.com
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`Linnea Cipriano
`Goodwin Procter LLP
`620 Eighth Avenue
`New York, NY 10018
`lcipriano@goodwinlaw.com
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`Duncan Greenhalgh
`Joshua Weinger
`Goodwin Procter LLP
`100 Northern Avenue
`Boston, MA 02210
`dgreenhalgh@goodwinlaw.com
`jweinger@goodwinlaw.com
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`/Timothy J. Andersen/
`Timothy J. Andersen
`Case Manager
`Weil, Gotshal & Manges LLP
`2001 M Street, NW, Suite 600
`Washington, D.C. 20036
`timothy.andersen@weil.com
`202-682-7000
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