`
`Transcript of Mary Gerritsen Ph.D.
`
`Date: January 14, 2022
`Case: Mylan Pharmaceuticals Inc. -v- Regeneron Pharmaceuticals, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Exhibit 2129
`Page 001 of 162
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`MYLAN PHARMACEUTICALS, )
`INC., )
` )
` Plaintiffs, ) Inter Partes Review
` ) No.: IPR2021-00880;
` vs. ) IPR2021-00881
` )
`REGENERON )
`PHARMACEUTICALS, INC., )
` )
` Defendants. )
` ________________________)
`
` VIDEO DEPOSITION OF EXPERT
` MARY GERRITSEN, PhD
` January 14, 2022
` 9:04 a.m.
` Conducted Virtually
`
` REMOTELY REPORTED BY:
` Tammy Moon, CSR No. 13184, RMR, CRR
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`2
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`Videotaped Deposition of MARY GERRITSEN, PhD, taken
`on behalf of Plaintiff, beginning at 9:04 a.m.
`Pacific Standard Time, on JANUARY 14, 2022, before
`TAMMY MOON, Certified Shorthand Reporter No. 13184,
`RMR, CRR.
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`888.433.3767 | WWW.PLANETDEPOS.COM
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`Exhibit 2129
`Page 003 of 162
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`3
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`REMOTE APPEARANCES:
`FOR PETITIONER:
`RMMS
`BY: HEINZ J. SALMEN, ESQ.
`BY: ERIC HUNT, ESQ.
`6 West Hubbard Street, Suite 500
`Chicago, Illinois 60654
`312.222.7504
`Hsalmen@rmmslegal.com
`FOR DEFENDANT:
`ARNOLD & PORTER
`BY: JEREMY COBB, ESQ.
`BY: ALICE HO, ESQ.
`601 Massachusetts Ave., NW
`Washington DC, 20001
`202.942.5000
`Jeremy.cobb@arnoldporter.com
`ALSO PRESENT: THOMAS TRIOLO, IN-HOUSE COUNSEL FOR
`REGENERON
`EILEEN WOO, IN-HOUSE COUNSEL FOR REGENERON
`VINNY LEE, IN-HOUSE COUNSEL FOR MYLAN
`JEAN-LOUIS ZIESCH, VIDEOGRAPHER
`DANIEL LONG, THE REMOTE TECHNICIAN
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`4
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` INDEX TO EXAMINATION
` MARY GERRITSEN, PhD
` Friday, January 14, 2022
` Tammy Moon CSR No. 13184, RPR, CRR
` WITNESS: MARY GERRITSEN, PhD
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`EXAMINATION PAGE
`MR. COBB 9
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`Exhibit 2129
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`5
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` INDEX TO EXHIBITS
` MARY GERRITSEN, PhD
` Friday, January 14, 2022
` Tammy Moon CSR No. 13184, RPR, CRR
`
`MARKED DESCRIPTION PAGE
`Exhibit 1 Declaration of Mary Gerritsen, 12
` Ph.D. in Support of Petition for
` Inter Partes Review of U.S. Patent
` Number 9,254,338 B2
`Exhibit 2 United States Patent 9,254,338 28
` entitled "Use of a VEGF Antagonist
` to Treat Angiogenic Eye Disorders"
`Exhibit 3 Press release entitled "Bayer and 30
` Regeneron Dose First Patient in
` Second Phase 3 Study for VEGF
` Trap-Eye in Wet Age-Related
` Macular Degeneration"
`Exhibit 4 Document titled "ADIS R&D Profile: 41
` Aflibercept"
`Exhibit 5 Curriculum vitae 48
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`Exhibit 2129
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`6
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` INDEX TO EXHIBITS
` MARY GERRITSEN, PhD
` Friday, January 14, 2022
` Tammy Moon CSR No. 13184, RPR, CRR
`
`Exhibit 6 Document titled 58
` "Receptor-selective Variants of
` Human Vascular Endothelial Growth
` Factor: Generation and
` Characterization"
`Exhibit 7 Document titled "Altered 74
` Proliferation of Retinal
` Microvascular Cells in Response to
` Non-enzymatic Glycosylated Matrix
` Proteins"
`Exhibit 8 Press report titled "Regeneron and 89
` Bayer Health Announce Encouraging
` 32-week Follow-Up Results from a
` Phase 2 Study of VEGF Trap-Eye in
` Age-Related Macular Degeneration"
`Exhibit 9 Page from clinicaltrials.gov 98
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`Exhibit 2129
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`7
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` INDEX TO EXHIBITS
` MARY GERRITSEN, PhD
` Friday, January 14, 2022
` Tammy Moon CSR No. 13184, RPR, CRR
`
`Exhibit 10 Document titled "History of 100
` Changes for Study: NCT00637377,
` VEGF Trap-Eye: Investigation of
` Efficacy and Safety in Wet AMD
` (VIEW 2)"
`Exhibit 11 Document titled "VEGF Trap-Eye for 104
` the treatment of neovascular
` age-related macular degeneration"
`Exhibit 12 Document titled "Genetic 110
` Variations in Vascular Endothelial
` Growth Factor and Endothelial
` Nitric Oxide Synthase and Their
` Contributions to Human Disease"
`Exhibit 13 Document titled "Expert 120
` Declaration of Mary Gerritsen,
` Ph.D., in Support of Petition
` Inter Partes Review of U.S. Patent
` Number 9,669,069 B2"
`Exhibit 14 U.S. Patent Number 9,669,069 B2 121
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`8
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` Friday, January 14, 2022, 9:04 a.m. PST
` THE VIDEOGRAPHER: This is the beginning of
`Media Number 1 of the videotaped deposition of
`Dr. Mary Gerritsen in the matter of Mylan
`Pharmaceuticals, et al., v. Regeneron
`Pharmaceuticals, et al., in the USPTO Patent Trial
`and Appeal Board, Case Number IPR2021-00880 and
`IPR2021-00881.
` Today's date is January 14, 2022. The time
`on the video monitor is 9:04 a.m. Pacific Standard
`Time.
` The certified videographer today is
`Jean-Louis Ziesch, Planet Depos. This video
`deposition is taking place remotely.
` Would counsel please identify yourselves
`and state whom you represent.
` MR. COBB: Hi. This is Jeremy Cobb with
`Arnold & Porter on behalf of patent owner, Regeneron
`Pharmaceuticals, Inc.
` Also with me is Alice Ho from Arnold &
`Porter on behalf of Regeneron Pharmaceuticals, Inc.,
`as well as Eileen Woo and Tom Triolo from in-house
`counsel at Regeneron Pharmaceuticals, Inc.
` MR. SALMEN: This is Heinz Salmen of RMMS,
`LLP, on behalf of the petitioner, Mylan.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`9
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` With me today on the call is Eric Hunt,
`also of RMMS, and Vinny Lee, in-house counsel at
`Mylan.
` THE VIDEOGRAPHER: The court reporter today
`is Tammy Moon, representing Planet Depos.
` Would the court reporter please swear in
`the witness.
` MARY GERRITSEN, PhD,
` called as a witness, having been duly
` sworn, testified as follows:
` THE WITNESS: Yes, I do.
` THE VIDEOGRAPHER: Please proceed.
` EXAMINATION
` MR. COBB:
` Q. Good morning, Dr. Gerritsen. My name is
`Jeremy Cobb. And as I just said, I represent patent
`owner Regeneron Pharmaceuticals.
` Could you please state your full -- state
`and spell your full name for the record.
` A. My full name is Mary Ellen Gerritsen.
`M-A-R-Y. E-L-L-E-N. G-E-R-R-I-T-S-E-N.
` Q. And where are you sitting for today's
`deposition?
` A. I'm sitting in a conference room in the
`SpringHill Suites in Belmont, California.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`10
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` Q. And you have been retained by Mylan as an
`expert in this proceeding. Is that correct?
` A. Yes, that is correct.
` Q. Okay. And you're testifying on behalf of
`Mylan regarding Regeneron's Patent U.S. '669,069.
`Is that correct?
` A. '-69, yes, that is correct.
` Q. And going forward, I'll refer to that
`patent as the "'069 patent." Is that okay with you?
` A. Yes, I understand.
` Q. Okay. And you're also testifying on behalf
`of Mylan regarding Regeneron's Patent U.S.
`9,254,338. Is that correct?
` A. Yes, that is correct.
` Q. And going forward, I'll refer to that as
`the "'338 patent." Is that okay?
` A. Yes, I understand.
` Q. And have you -- have you -- you understand
`that you're -- you're under oath in your testimony
`that you give today. Is that correct?
` A. Yes. Yes, that is correct.
` Q. And you're aware that that oath is the same
`oath that you would have taken as if you would have
`been testifying before a court of law, right?
` A. Yes. Yes, I understand.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`11
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` Q. Okay. Have you ever testified at trial
`before?
` A. No.
` Q. Have you ever served as an expert witness?
` A. No.
` Q. Is there any reason that you cannot testify
`truthfully today, such as illness or medication?
` A. No.
` Q. And have you ever been deposed before?
` A. No.
` Q. So I'm just going to go over some of the
`ground rules for the deposition. I'm sure your
`counsel talked a little bit before the deposition
`with you.
` But -- so this is a Q and A session, so I'm
`going to ask questions. You are going to give
`answers. It's not quite a conversation. We need to
`give each other time to finish so that we can --
`don't talk over each other. That way the court
`reporter can get down my full question and your full
`answer. Does that make sense?
` A. Yes.
` Q. Now, I -- I will ask you questions, and you
`will need to answer my questions. And what I mean
`by that is, I will ask a question. From time to
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`12
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`time, your counsel will object to a question, but
`you will still need to answer my question unless
`your counsel instructs you not to answer. Does that
`make sense?
` A. Yes.
` Q. Okay. So, typically, I tend to go in about
`an hour to an hour and a half sessions, and then we
`take breaks. And so -- but if you need to take a
`break at any time, just let me know, and we can do
`so.
` The only thing that I ask is that if I have
`a question pending, I ask that you, you know, answer
`that -- that question and then we can, you know,
`find a good time to break. Is that okay with you?
` A. Yes.
` Q. Okay. And -- yeah. So I'm going to
`introduce a couple of exhibits. So the first
`exhibit that I would like to introduce has been --
` MR. COBB: Could you introduce tab 2, which
`is the Gerritsen -- the Declaration of Mary
`Gerritsen, Ph.D., in Support of Petition for Inter
`Partes Review of U.S. Patent Number 9,254,338 B2,
`which has been previously marked in the
`IPR2021-00881 proceeding as Mylan Exhibit 1003.
` (Exhibit 1 was marked for identification.)
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`13
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` THE REMOTE TECHNICIAN: Stand by.
` MR. COBB: And could we mark that Gerritsen
`Exhibit 1.
` THE REMOTE TECHNICIAN: That I can do.
`Stand by.
` MR. COBB:
` Q. And I would also like -- so do you
`recognize this document, Dr. Gerritsen?
` A. I don't see the Gerritsen Exhibit 1 in
`the -- in the files. I see tab 2 EX1003.
` Q. Let's give it a second to refresh.
` A. Okay.
` Q. I believe that the technician has put the
`cover page on the shared screen. Do you see that
`document while we wait?
` A. Yes.
` Q. And do you -- do you recognize Gerritsen
`Exhibit 1?
` A. Yes.
` Q. And what is Gerritsen Exhibit 1?
` A. That is my Declaration in Support of
`Petition for Inter Partes review of U.S. Patent
`Number 9,254,338 B2.
` MR. COBB: And could we go to page 53 of
`that document, 53 of the PDF.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`14
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` Q. Dr. Gerritsen, I'm on page 53 of the PDF.
`And at the bottom, I see your name typed out as well
`as a signature. Is that your signature?
` A. Yes, that's my signature.
` Q. And did you review the Gerritsen
`declaration concerning the -- the '338 patent prior
`to signing the document?
` A. Yes, I did.
` Q. And did you -- are there any errors in
`Exhibit 1 that you would like to correct here today?
` MR. SALMEN: Objection. Form.
` THE WITNESS: I don't have any errors to
`correct.
` MR. COBB:
` Q. How did you go about preparing your
`declaration?
` A. I worked with the attorneys at RMMS in a
`collaborative fashion. We went back and forth with
`various emails and phone calls to go over the
`contents of the declaration. And then developed
`the -- the final version of it, and that's what I
`signed.
` Q. And did you write your declaration?
` A. It was a collaborative effort with the
`attorneys at RMMS. I did not actually type it, but
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`15
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`all of the words that are in there are my own.
` Q. And how many hours did you spend preparing
`your declaration?
` A. Many hours. I don't know the exact number.
`But, basically, I had to review all of the
`documents, and it was probably well in excess of
`40 hours.
` Q. And did you talk to any of Mylan's other
`experts in forming your opinions?
` A. No, I did not.
` Q. And did you -- were -- are you aware that
`Dr. Albini supported -- provided a declaration --
` MR. SALMEN: Objection.
` MR. COBB:
` Q. -- proceeding?
` MR. SALMEN: Objection. Foundation.
` THE WITNESS: I have seen his name on
`documents. So in that aspect I'm aware, but I have
`not met or communicated with Dr. Albini.
` MR. COBB:
` Q. And have you -- and have you reviewed a
`declaration prepared by Dr. Albini in this
`proceeding?
` MR. SALMEN: Same objection.
` THE WITNESS: No, I have not.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`16
`
` MR. COBB: And if I could ask -- if -- if
`we could go to paragraph 29 of Exhibit 1.
` THE REMOTE TECHNICIAN: Stand by.
` (Brief pause.)
` THE WITNESS: Can I ask that you make --
`yeah, larger. Thank you.
` MR. COBB:
` Q. Can you read that now, Dr. Gerritsen?
` A. Yes.
` Q. Okay.
` MR. COBB: Could you scroll up just a
`slight bit.
` Thank you.
` Q. And in your declaration, you state that the
`'338 patent has two independent claims. Is that
`correct?
` A. Yes, that is correct.
` Q. Okay. And claim 1 identifies a specific
`VEGF agonist for use in the recited method, correct?
` MR. SALMEN: Objection. Form.
`Mischaracterizes. Also, objection outside the
`scope.
` MR. COBB: What the patent states is outside
`the scope?
` Heinz, is that where we're going to go in the
`
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`17
`
`deposition today?
` MR. SALMEN: Are you withdrawing your
`previous question and asking me a question?
` MR. COBB:
` Q. Dr. Gerritsen, claim 1 identifies a
`specific VEGF agonist for use in the recited method,
`correct?
` A. Claim 1 provides or specifies the VEGF
`antagonist as highlighted in yellow on the screen.
` Q. And the VEGF agonist of claim 1 has a VGFR
`[sic] with an amino acids of 27 to 129 of sequence
`ID number two, correct?
` MR. SALMEN: Objection. Form and
`mischaracterizes.
` THE WITNESS: That is what is typed on the
`screen.
` MR. COBB:
` Q. And the claimed VEGF agonist has a VGFR
`[sic] with amino acids 130 through 231 of sequence
`ID number two, correct?
` MR. SALMEN: I'm going to interject for a
`second to ask the court reporter -- Mr. Cobb, you
`keep saying "VEGF agonist," and the court reporter
`is transcribing "VEGF antagonist." So there's a
`miscommunication here and the record is not properly
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`18
`
`reflecting your questions. And I don't want to --
`and I don't want to confuse the witness.
` MR. COBB: Sure. Let me be more -- let me
`be more precise, Heinz. Okay. I don't have my
`realtime up, so --
` (Brief pause.)
` Q. Claim 1 identifies a specific VEGF
`antagonist for use in the recited method, correct?
` MR. SALMEN: Objection. Form.
` THE WITNESS: Claim 1 includes the phrase
`where it defines the VEGF antagonist.
` MR. COBB:
` Q. And the VEGF antagonist claimed -- strike
`that. The claimed VEGF antagonist has a VGFR1 [sic]
`amino acid 27 through 129 of sequence ID number two,
`correct?
` MR. SALMEN: Objection. Form.
`Mischaracterizes and scope.
` THE WITNESS: In claim 1, this is what
`is -- is written in the -- in the patent. However,
`I was not asked for -- to review the sequence, the
`amino acid sequences that are included in the
`patent.
` My role as an expert witness was to review
`and attest to the public availability and the
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`19
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`accessibility of prior art as indicated in the
`declaration.
` MR. COBB:
` Q. Are you a person of ordinary skill in the
`art?
` A. Yes, I am.
` Q. Okay.
` MR. COBB: And if you could go to paragraph
`23 of Exhibit 1, Dr. Gerritsen's declaration.
` (Reporter clarification.)
` Q. Dr. Gerritsen, you are not an
`ophthalmologist, correct?
` A. That is correct.
` Q. And, Dr. Gerritsen, you do not have a
`medical doctorate, correct?
` A. That is correct.
` Q. Dr. Gerritsen, you do not administer
`medicine to patients, correct?
` A. That is correct, but I do administer
`medications to animals as being a practicing
`pharmacologist.
` Q. Dr. Gerritsen, you do not administer
`medicine to human beings, correct?
` A. That is correct.
` Q. Dr. Gerritsen, you have never provided a
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`20
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`diagnosis as to whether a human patient has an
`angiogenic eye disorder, correct?
` MR. SALMEN: Objection. Form. Lacks
`foundation.
` THE WITNESS: I am not a practicing
`physician, and I have not provided a diagnosis to a
`patient, although I have recognized age-related
`macular degeneration in several of my friends and
`sent them to an ophthalmologist to get a proper
`diagnosis and treatment.
` MR. COBB:
` Q. Dr. Gerritsen, you have never provided a
`diagnosis, as a medical doctor --
` (Reporter clarification.)
` Q. Dr. Gerritsen, you have never provided a
`diagnosis, as a medical clinician, as to whether a
`patient has an angiogenic eye disorder, correct?
` MR. SALMEN: Objection. Asked and
`answered.
` THE WITNESS: Yes, I -- I answered that
`question already. And the answer is, no, I have not
`provided a diagnosis for a patient.
` MR. COBB: If we could look at paragraph
`23.
` Q. Do I understand that you have knowledge
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`21
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`regarding the diagnosis and treatment of angiogenic
`eye disorders? Is that correct?
` A. Yes, that is correct.
` Q. And do I also understand that you have the
`ability to understand the results and findings
`presented or published by others in the field,
`including publications discussed within your
`declaration? Is that correct?
` A. That is correct.
` Q. So you have the ability to understand the
`results and findings of all of the prior art
`references cited within your declaration, correct?
` MR. SALMEN: Objection. Form. Foundation.
` THE WITNESS: I have the ability to
`understand the results and findings presented by
`others in the field.
` MR. COBB:
` Q. Do you have the ability to understand the
`results and findings presented in the publications
`and references cited within your declaration?
` MR. SALMEN: Asked and answered. Same
`objections.
` THE WITNESS: As I mentioned, I've answered
`that question already. But the answer is yes.
` ///
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`22
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` MR. COBB:
` Q. And you would agree that you cite the '338
`patent within your declaration. Is that correct?
` A. That is correct. It says right there on
`paragraph 23, line number one, with respect to the
`'338 patent.
` Q. So, Dr. Gerritsen, you have the ability to
`understand the results and findings presented in the
`338 patent. Is that correct?
` A. That is correct.
` MR. COBB: Could we go back to paragraph
`29.
` Q. Do you understand that the VEGF agonist
`that is claimed in invention has a VGFR1 [sic]
`component comprising amino acids 27 through 129 of
`sequence ID number two?
` MR. SALMEN: Object to the form. That
`mischaracterizes. Again, it's compound. It's
`outside the scope.
` MR. COBB: Heinz, are you going to have
`these extensive speaking objections all day?
` MR. SALMEN: If you're going to -- if
`you're going to ask improper questions --
` (Simultaneous colloquy.)
` MR. SALMEN: If you're going to ask
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
`
`23
`
`improper questions. You're mischaracterizing.
`You're calling it an "agonist." It doesn't say that
`in the claim. If -- if you're going to keep asking
`these types of questions, yes, you're going to get
`lengthy objections.
` This is outside the scope.
` MR. COBB: It is a claim of the patent.
` Q. Dr. Gerritsen?
` A. Will you please repeat the question.
` Q. You would agree that the VEGF antagonist of
`claim 1 has a VEGFR1 component comprising amino
`acids 27 to 129 of sequence ID number two?
` MR. SALMEN: Objection. Form.
` THE WITNESS: I understand that that is
`what is defined in claim number 1.
` MR. COBB:
` Q. And you would agree that the VEGF
`antagonist of claim 1 has a VEGFR2 component
`comprising amino acids 130 through 231 of sequence
`ID number two?
` MR. SALMEN: Objection. Form.
`Mischaracterizes.
` THE WITNESS: This is what is written in --
`in the patent claim, as you said.
` ///
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`24
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` MR. COBB:
` Q. And you would also agree that the VEGF
`antagonist of claim 1 has a multimerization --
`multimerization component comprising amino acids 232
`through 457 of sequence ID number two, correct?
` MR. SALMEN: Objection. Form.
`Mischaracterizes.
` THE WITNESS: And as I've answered
`previously, that is what it states in the patent.
` MR. COBB:
` Q. And if we look at claim 14 of the '338
`patent, do you see that, Dr. Gerritsen?
` A. Yes, I do.
` Q. Okay.
` A. Sorry. Could you make it a little bigger
`because it's -- thank you.
` MR. COBB: Could you scroll out -- there
`you go.
` Q. Do you see claim 14 now, Dr. Gerritsen?
` A. Yes, I do.
` Q. And claim four recites a VEGF -- strike
`that. Claim 14 recites a VEGF antagonist comprising
`VEGFR1R2-Fc delta C1(a) encoded by nucleic acid
`sequence of sequence ID number two, correct?
` MR. SALMEN: Objection. Form.
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`25
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`Mischaracterizes.
` THE WITNESS: Again, that is what is
`written in the patent.
` MR. COBB:
` Q. What is a VEGF receptor-based chimeric
`molecule?
` MR. SALMEN: Form. Scope.
` THE WITNESS: Okay.
` MR. COBB:
` Q. Go ahead.
` A. It's well understood in the field that a
`chimeric molecule is a molecule comprised of
`different components.
` In the case of the VEGF antagonist here,
`there are two domains of the VEGF receptors.
`There's two receptors for VEGF: VEGF receptor 1 and
`VEGF receptor 2.
` So, basically, this molecule contains
`portions of -- of each of those receptors,
`specifically, certain domains. And then they are
`attached to the Fc component of the IGG, which
`results in a molecule that has chimeric properties,
`it has VEGF receptor properties, and it also has
`some of the properties of amino globulants.
` Q. And forgive me if this question sounds --
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`Transcript of Mary Gerritsen Ph.D.
`Conducted on January 14, 2022
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`sounds ignorant, but VEGF receptor-based chimeric
`molecule is a protein. Is that correct?
` A. Yes, that's correct.
` Q. And is the VEGF --
` A. Actually, I just want to step back here for
`a second. So the protein is the consequence of
`translation of a nucleic acid sequence. So in this
`case, you could be referring to either the nucleic
`acid sequence or the amino acid sequence.
` Q. Right.
` MR. COBB: And if you could, could you
`scroll back up to claim 1, please. And zoom in for
`Dr. -- no, no, no. You had it. Go back. P
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