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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HOPEWELL PHARMA VENTURES, INC.,
`Petitioner,
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`MERCK SERONOSA,
`Patent Owner.
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`Case IPR2023-00480
`U.S. Patent No. 7,713,947
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`DECLARATION OF VINITA FERRERA
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`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
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`Merck 2003
`Merck 2003
`Hopewell v Merck
`Hopewell v Merck
`IPR2023-00480
`IPR2023-00480
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`
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`Case No. IPR2023-00480
`Declaration of Vinita Ferrera in Support of
`Motion for Admission Pro Hac Vice
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`I, Vinita Ferrera, declare as follows:
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`1.
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`I was admitted to the Massachusetts Bar in February 1996 and the
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`New York Bar in April 1996.
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`I have been practicing law for over 27 years.
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`Mypractice has focused on patentlitigation disputes in a variety of
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`jurisdictions, with a particular emphasis on patentlitigation in the life sciences
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`fields.
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`2.
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`I have been counsel of record in over 40 patentlitigations and
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`participated in all aspects of such litigation, including trials and appeals.
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`Se
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`I am a memberin goodstanding of the Bars of Massachusetts and
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`New York and am admitted to practice before the U.S. District Court for the
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`District of Massachusetts and the U.S. District Court for the District of
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`Colorado.
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`I am also admitted to practice before the U.S. Court of Appeals for
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`the Federal Circuit, the First Circuit, and the Second Circuit.
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`4.
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`MyMassachusetts Bar membership numberis 631190. My New
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`York Bar membership numberis 2750727.
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`5.
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`I have never been suspendedordisbarred from practice before any
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`court or administrative body.
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`6.
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`I have never had a court or administrative body deny my
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`application for admission to practice.
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`Case No. IPR2023-00480
`Declaration of Vinita Ferrera in Support of
`Motion for Admission Pro Hac Vice
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`7.
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`I have neverhad any sanctions or contempt citations imposed by
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`any court or administrative body.
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`8.
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`I have read and will comply with the Patent Office Trial Practice
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`Guide and the Board’s Rules for Practice for Trials, as set forth in 37 C.F.R. Part
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`42.
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`9.
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`I agree to be subject to the United States Patent and Trademark
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`Office Rules of Professional Conductset forth in 37 C.F.R. §§ 11.101 et seq.
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`and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`10._—In the past three years, I have appeared pro hac vice before the
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`United States Patent and Trademark Office in the following proceedings:
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`Foundation Medicine, Inc., v. Caris MPI, Inc. including Case Nos. IPR2019-
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`00164, IPR2019-00166, IPR2019-00170, IPR2019-00171, and IPR2019-00203.
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`11.
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`[am intimately familiar with the subject matter at issue in this
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`proceeding.
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`I have reviewed the papers and exhibits filed in this proceeding.
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`I
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`also participated in drafting papers filed thus far in this proceeding. In addition to
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`this proceeding, I participated in reviewing and drafting papers in the related inter
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`partes review matters challenging U.S. Patent No. 7,713,947 (the “’947 patent’)
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`and U.S. Patent No. 8,377,903 (the “’903 patent”), which were filed as TWi
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`Pharmaceuticals, Inc., v. Merck Serono SA, 1PR2023-00049 and TWi
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`Case No. IPR2023-00480
`Declaration of Vinita Ferrera in Support of
`Motion for Admission Pro Hac Vice
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`Pharmaceuticals, Inc., v. Merck Serono SA, IPR2023-00050, respectively.
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`Moreover, I am currently representing Merck KGaA, Merck Serono SA, and Ares
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`Trading SA (collectively “Merck”) in the following parallel district court
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`litigations, in which the ’947 patentis a patent-in-suit: Merck KGaA, Merck Serono
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`SA, and Ares Trading SA v. Accord Healthcare, Inc., No. 1:22-cv-00974-GBW (D.
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`Del.), Merck KGaA, Merck Serono SA, and Ares Trading SA v. Hopewell Pharma
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`Ventures, Inc., No. 1:22-cv-01365-GBW (D. Del.), and Merck KGaA, Merck
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`Serono SA, and Ares Trading SA v. Aurobindo Pharma USA, Inc. and Aurobindo
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`Pharma Limited, No. 1:23-cv-00039-GB W (D. Del.).
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`12.
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`Iam also familiar with pharmaceuticals, methods of treatment, and
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`small molecule therapeutics.
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`I have represented a numberoflife sciences,
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`pharmaceutical, biotechnology, and diagnostics companies, including Gilead
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`Sciences, Inc.; AbbVie, Inc.; GlaxoSmithKline; Novartis Corporation; Precision
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`Biosciences, Inc.; Palomar Medical Technologies, Inc.; Proctor & Gamble Co.;
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`Millennium Pharmaceuticals, Inc.; Shionogi, Inc.; and other companies in
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`confidential representations in many patentlitigation matters, including before
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`federal district courts.
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`13.
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`I hereby declare that all statements made herein ofmy own
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`knowledge aretrue andthat all statements made on information and beliefare
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`Case No. IPR2023-00480
`Declaration of Vinita Ferrera in Support of
`Motion for Admission Pro Hac Vice
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`believed to be true; and further that these statements are made with the knowledge
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`that willful false statements andthe like are punishable by fine, imprisonment, or
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`both under Section 1001 of Title 18 ofthe United States Code.
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`Dated: October4/_, 2023
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`Respectfully Submitted,
`Clef Teeeen—
`
`Vinita Ferrera
`Wilmer Cutler Pickering Hale and Dorr
`LLP
`60 State Street
`Boston, MA 02109
`(617) 526-6000
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