`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
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`MSN LABORATORIES PRIVATE LTD. AND MSN PHARMACEUTICALS INC.
`Petitioners
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`v.
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`BAUSCH HEALTH IRELAND LIMITED,
`Patent Owner
`_____________________
`
`IPR2023-00016
`Patent No. 7,041,786
`_____________________
`
`DECLARATION OF CHRISTOPHER J. SORENSON IN SUPPORT OF
`PETITIONERS’ MOTION FOR ADMISSION PRO HAC VICE
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`MSN Exhibit 1056 - Page 1 of 4
`MSN v. Bausch - IPR2023-00016
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`
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`IPR2023-00016
`Patent 7,041,786
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`In support of the Motion for Admission Pro Hac Vice, I, Christopher J.
`
`Sorenson, do declare and state as follows:
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`1.
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`I am a member in good standing of the Minnesota State Bar, the
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`United States District Court for the District of Minnesota, District of Southern
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`Iowa, Court of Appeals Eighth Circuit, and Court of Appeals Federal Circuit.
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`2.
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`I have no suspensions or disbarments from practice before any court
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`or administrative body.
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`3.
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`I have never had any court or administrative body deny my
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`application to practice before said court or administrative body.
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`4.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in 37 C.F.R § 42.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`7.
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`I have previously applied to appear pro hac vice before the USPTO in
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`proceeding Nos. IPR2014-00592, IPR2017-01598, IPR2017-01599, and IPR2017-
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`01603. Said applications were granted.
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`MSN Exhibit 1056 - Page 2 of 4
`MSN v. Bausch - IPR2023-00016
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`
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`IPR2023-00016
`Patent 7,041,786
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`8.
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`I am a partner in the law firm of Merchant & Gould P.C. I have
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`practiced litigation for more than twenty-six (26) years. I have represented a wide
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`range of clients in intellectual property and have been litigating patent cases for the
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`last twenty-one (21) years.
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`9.
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`I am counsel for Defendants in the case Bausch Health Ireland
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`Limited and Salix Pharmaceuticals, Inc. v. MSN Laboratories Private Ltd. and
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`MSN Pharmaceuticals Inc., U.S.D.C., New Jersey, Civil Action No. 21-10057,
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`which involves U.S. Patent No. 7,041,786.
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`10.
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`I am familiar with the subject matter of this case, which relates to U.S.
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`Patent No. 7,041,786 and its claims regarding the therapeutic use of guanylate
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`cyclase receptor agonists as a means for enhancing the intracellular production of
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`cGMP and I was involved in the preparation of the Motion for Joinder Pursuant to
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`35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b) and the Petition. have worked
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`extensively analyzing the invalidity positions, including those based on the same
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`references raised in the Petition and advanced by Petitioners MSN Laboratories
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`Private Ltd and MSN Pharmaceuticals Inc. I am thus familiar with the prior art
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`relied upon in the Petitioners’ Petition as well as the patent at issue.
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further that these statements were made with the knowledge that willful false
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`MSN Exhibit 1056 - Page 3 of 4
`MSN v. Bausch - IPR2023-00016
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`
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`IPR2023-00016
`Patent 7,041,786
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Dated: November 2, 2022
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`______________________________
`/s/ Christopher J. Sorenson /s/
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`MSN Exhibit 1056 - Page 4 of 4
`MSN v. Bausch - IPR2023-00016
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`