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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`SAMSUNG BIOEPIS CO., LTD., CELLTRION INC,
`and BIOCON BIOLOGICS INC.
`Petitioner,
`v.
`REGENERON PHARMACEUTICALS, INC.,
`Patent Owner.
`
`Patent No. 11,253,572
`
`_______________
`Inter Partes Review No. IPR2023-008841
`____________________________________________________________
`
`
`
`DECLARATION OF JEFFREY SPADA
`
`
`
` IPR2024-00260 and IPR2024-00298 are joined with IPR2023-00884.
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` 1
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 1
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`IPR2023-00884
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`I, Jeffrey Spada, declare as follows:
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`
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`1.
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`I am Associate Director, eDiscovery and Litigation Support at
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`Regeneron Pharmaceuticals, Inc. I have personal knowledge of the facts in this
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`declaration.
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`2.
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`Regeneron has collected documents as part of the ongoing related
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`litigation. The collected documents are stored in a KLDiscovery database and can
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`be accessed through the KLDiscovery’s Relativity interface. The document
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`collection process preserves these documents’ metadata, such as the file names,
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`dates, etc. The identity of the document custodian, meaning the person from
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`whose files a document was collected, is also preserved. When emails are
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`collected, information about email and attachment relationships is preserved. The
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`collected document and its metadata and other preserved information are
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`accessible via the Relativity interface.
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`3.
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`Exhibit 2092 is a collection of screenshots from the Relativity
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`interface. These screenshots show the metadata and other information for the
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`following exhibits: 2005, 2006, 2010, 2011, 2013, 2015, 2017–2019, 2024, 2036,
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`2042, 2043, and 2069–2074. I have verified that these screenshots are true and
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`correct depictions of the information in Relativity corresponding to each exhibit.
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`4.
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`Pages 1 and 2 of Exhibit 2092 are Relativity screenshots showing the
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`metadata and attachment information for Exhibits 2005 and 2006, respectively.
`1
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 2
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`IPR2023-00884
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`Exhibit 2005 is an email sent by George Yancopoulos to Murray Goldberg on
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`March 22, 2007. The email included an attachment with the file name “Eye Ph2
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`Data_032207.doc.” The email was assigned the family ID number
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`6239292_02449774 in the Relativity database. Exhibit 2006 is a document with
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`the file name “Eye Ph2 Data_032207.doc” that was assigned the same family ID
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`number 6239292_02449774 in the Relativity database. This shows Exhibit 2006
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`was sent as an attachment to Exhibit 2005.
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`5.
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`Pages 3 and 4 of Exhibit 2092 are screenshots from the Relativity
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`interface showing the metadata for Exhibits 2010 and 2011, respectively. Exhibit
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`2010 is an email sent by Robert Terifay to George Yancopoulos on November 19,
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`2010. The email included an attachment with the file name “VGTeye VIEW 430
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`presentation.PPT.” The email was assigned the family ID number
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`6239292_02293467 in the Relativity database. Exhibit 2011 is a document with
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`the file name “VGTeye VIEW 430 presentation.PPT” that was assigned the same
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`family ID number 6239292_02293467 in the Relativity database. This shows
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`Exhibit 2011 was sent as an attachment to Exhibit 2010.
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`6.
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`Page 5 of Exhibit 2092 is a screenshot from the Relativity interface
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`showing the metadata for Exhibit 2013. Exhibit 2013 was sent as an email
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`attachment on May 20, 2008. George Yancopoulos is the custodian for this
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`document.
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`2
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 3
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`IPR2023-00884
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`7.
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`Pages 6 and 10 of Exhibit 2092 are screenshots from the Relativity
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`
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`interface showing the metadata for Exhibits 2015 and 2024, respectively. Exhibit
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`2024 is an email sent by Caroline Saxton to George Yancopoulos and other
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`Regeneron employees on December 8, 2010. The email included an attachment
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`with the file name “DA VINCI 1 year final draft.pdf.” The email was assigned the
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`family ID number 6239292_02301952 in the Relativity database. Exhibit 2015 is a
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`document with the file name “DA VINCI 1 year final draft.pdf” that was assigned
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`the same family ID number 6239292_02301952 in the Relativity database. This
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`shows Exhibit 2015 was sent as an attachment to Exhibit 2024.
`
`8.
`
`Pages 7 to 9 of Exhibit 2092 are screenshots from the Relativity
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`interface showing the metadata for Exhibits 2017, 2018, and 2019, respectively.
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`Exhibit 2017 is an email sent by Caroline Saxton to George Yancopoulos and other
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`Regeneron employees on February 1, 2010. The email included attachments with
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`the file names “VGFT-OD-0706 KRM v3.doc” and “DME 6 month data
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`020110.ppt.” The email was assigned the family ID number 6239292_03173151
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`in the Relativity database. Exhibits 2018 and 2019 are documents with the file
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`names “VGFT-OD-0706 KRM v3.doc” and “DME 6 month data 020110.ppt,”
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`respectively, that were assigned the same family ID number 6239292_03173151 in
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`the Relativity database. This shows Exhibits 2018 and 2019 were sent as
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`attachments to Exhibit 2017.
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`3
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 4
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`IPR2023-00884
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`9.
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`Page 11 of Exhibit 2092 is a screenshot from the Relativity interface
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`
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`showing the metadata for Exhibit 2036. Exhibit 2036 was sent as an email
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`attachment on September 26, 2007. George Yancopoulos is the custodian for this
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`document.
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`10. Pages 12 and 13 of Exhibit 2092 are screenshots from the Relativity
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`interface showing true and correct metadata for Exhibits 2042 and 2043,
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`respectively. Exhibit 2042 is an email sent by Yuhwen Soo to George
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`Yancopoulos on November 20, 2010. The email included an attachment with the
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`file name “Combined Analysis.PPT.” The email was assigned the family ID
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`number 6239292_02301450 in the Relativity database. Exhibit 2043 is a
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`document with the file name “Combined Analysis.PPT” that was assigned the
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`same family ID number 6239292_02301450 in the Relativity database. This
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`shows Exhibit 2043 was sent as an attachment to Exhibit 2042.
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`11. Page 14 of Exhibit 2092 is a screenshot from the Relativity interface
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`showing the metadata for Exhibit 2069. Exhibit 2069 was sent as an email
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`attachment on November 8, 2006. George Yancopoulos is the custodian for this
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`document.
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`12. Pages 15 and 16 of Exhibit 2092 are screenshots from the Relativity
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`interface showing the metadata for Exhibit 2070. Exhibit 2070 is an email sent by
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`Robert Terifay to George Yancopoulos and other Regeneron employees on March
`4
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 5
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`IPR2023-00884
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`22, 2007, and a PowerPoint dated March 22, 2007. The email included an
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`
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`attachment with the file name “Eye.ppt.ppt.” The email was assigned the family
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`ID number 6239292_02449762 in the Relativity database. The PowerPoint has the
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`file name “Eye.ppt.ppt” and was assigned the same family ID number
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`6239292_02449762 in the Relativity database. This shows the PowerPoint in
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`Exhibit 2070 was sent as an attachment to the email in Exhibit 2070.
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`13. Pages 17 and 18 of Exhibit 2092 are screenshots from the Relativity
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`interface showing the metadata for Exhibits 2071 and 2072, respectively. Exhibit
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`2071 is an email sent by Peter Powchik to George Yancopoulos on March 22,
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`2007. The email included an attachment with the file name “Presentation1.ppt.”
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`The email was assigned the family ID number 6239292_02449769 in the Relativity
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`database. Exhibit 2072 is a document with the file name “Presentation1.ppt” that
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`was assigned the same family ID number 6239292_02449769 in the Relativity
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`database. This shows Exhibit 2072 was sent as an attachment to Exhibit 2071.
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`14. Pages 19 and 21 of Exhibit 2092 are screenshots from the Relativity
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`interface showing the metadata for Exhibits 2073 and 2074, respectively. Exhibit
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`2074 is an email sent by George Yancopoulos to Leonard Schleifer on March 22,
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`2007. The email included an attachment with the file name “Eye Ph2
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`Data_032207.ppt.” The email was assigned the family ID number
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`6239292_02449786 in the Relativity database. Exhibit 2073 is a document with
`5
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 6
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`IPR2023-00884
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`the file name “Eye Ph2 Data_032207.ppt” that was assigned the same family ID
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`
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`number 6239292_02449786 in the Relativity database. This shows Exhibit 2073
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`was sent as an attachment to Exhibit 2074. Additionally, page 20 of Exhibit 2092
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`is a screenshot of the “Info” page for the native PowerPoint file of Exhibit 2073.
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`That screenshot indicates that the native PowerPoint file of Exhibit 2073 was last
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`modified by George Yancopoulos at 11:58 a.m. on March 22, 2007.
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`6
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 7
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`Samsung et al. v. Regeneron IPR2023-00884
`Regeneron Pharmaceuticals, Inc. Exhibit 2091 Page 8
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