`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`MYLAN PHARMACEUTICALS INC.,
`Petitioner
`v.
`REGENERON PHARMACEUTICALS, INC.,
`Patent Owner
`_______________
`
`Case IPR2021-00880
`Patent No. 9,669,069 B2
`_______________
`
`PRO HAC VICE MOTION TO ADMIT VICTORIA REINES PURSUANT
`TO 37 C.F.R. § 42.10(c)
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`1
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`Case IPR2021-00880
`Patent No. 9,669,069 B2
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`Pursuant to 37 C.F.R. § 42.10(c) Patent Owner Regeneron Pharmaceuticals,
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`Inc. (“Patent Owner”) hereby files this motion for Ms. Victoria Reines to appear
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`pro hac vice on its behalf before the Patent Trial and Appeal Board in this
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`proceeding. As required by the Board’s Notice of Filing Date Accorded to Petition
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`(Paper 3) this motion for pro hac vice admission under 37 C.F.R. § 42.10(c) is
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`being “filed in accordance with the ‘Order -- Authorizing Motion for Pro Hac Vice
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`Admission’ in Case IPR2013-00639” (“IPR2013-00639 Order”). (Paper 3 at 2.).
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`Patent Owner conferred with Petitioner Mylan Pharmaceuticals Inc. (“Petitioner”)
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`and Petitioner does not oppose the Motion for Admission pro hac vice.
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`I.
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`STATEMENT OF FACTS
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`The following facts, along with the attached Declaration of Victoria
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`Reines (Reines Decl.) support admission of Ms. Reines pro hac vice in this
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`proceeding.
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`1.
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`Lead Counsel Deborah E. Fishman (Reg. No. 48,621) and Back-up
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`Counsel Alice S. Ho (Lim. Rec. No. L1162) are the counsel of record for Patent
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`Owner. Ms. Fishman and Ms. Ho are experienced patent attorneys and have
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`worked closely with Ms. Reines since they became involved in these
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`proceedings, and will continue to do so.
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`2.
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`Ms. Reines has significant familiarity with the subject matter in this
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`proceeding and has substantive knowledge of the patent-at-issue (Patent No.
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`2
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`Case IPR2021-00880
`Patent No. 9,669,069 B2
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`9,669,069 B2 (the “’069 Patent”)) by virtue of her preparation for this
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`proceeding. (Reines Decl. ¶ 10). Ms. Reines has conducted a detailed review of
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`the ‘069 Patent, the relevant prior art, and the prosecution history and related
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`patents. In fact, a significant amount of Ms. Reines’ time since March 2020 has
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`been spent working on issues related to the ’069 Patent and Patent Owner’s
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`commercial product, Eylea®. Ms. Reines was substantively involved in the
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`preparation of the Patent Owner Preliminary Response. Therefore, Ms. Reines
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`has significant experience with the subject matter of this proceeding.
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`II. REASONS FOR GRANTING THE MOTION
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`The Board may recognize counsel pro hac vice during a proceeding “upon a
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`showing of good cause, subject to the condition that lead counsel be a registered
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`practitioner and to any other conditions as the Board may impose.” 37 C.F.R. §
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`42.10(c). As set forth above, lead counsel in this proceeding, Deborah E. Fishman,
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`is a registered practitioner. Moreover, as set forth above and in the accompanying
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`Reines declaration, Ms. Reines is a patent litigation attorney and has an established
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`familiarity with the subject matter at issue in the proceeding. (Reines Decl. ¶¶ 2,
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`10).
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`3
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`Case IPR2021-00880
`Patent No. 9,669,069 B2
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`III. CONCLUSION
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`Because this motion and the accompanying declaration meet all of the
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`Board’s requirements, Patent Owner respectfully requests that the Board admit Ms.
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`Victoria Reines pro hac vice, in this proceeding.
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`4
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`Case IPR2021-00880
`Patent No. 9,669,069 B2
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`Dated: November 22, 2021
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`Respectfully submitted,
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`/s/ Deborah E. Fishman
`Deborah E. Fishman (Reg. No. 48,621)
`3000 El Camino Real,
`Five Palo Alto Square, Suite 500
`Palo Alto, CA 94306-3807
`
`Counsel for Patent Owner
`Regeneron Pharmaceuticals, Inc.
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`5
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`Case IPR2021-00880
`Patent No. 9,669,069 B2
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
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`certifies that on November 22, 2021, a true and correct copy of this MOTION
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`FOR PRO HAC VICE ADMISSION OF VICTORIA REINES was served via
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`e-mail to the Patent Owner at the following email addresses:
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`MYL_REG_IPR@rmmslegal.com
`paul@rmmslegal.com
`wrakoczy@rmmslegal.com
`hsalmen@rmmslegal.com
`nmclaughlin@rmmslegal.com
`
`
`/s/ Deborah E. Fishman
`Deborah E. Fishman (Reg. No. 48,621)
`3000 El Camino Real,
`Five Palo Alto Square, Suite 500
`Palo Alto, CA 94306-3807
`
`Counsel for Patent Owner
`Regeneron Pharmaceuticals, Inc.
`
`-i-
`
`