Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 1 of 18 PageID# 33238
`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 1 of 18 PagelD# 33238
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`EXHIBIT 3
`EXHIBIT 3
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`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 1 of 18 PagelD# 33238
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`EXHIBIT 3
`EXHIBIT 3
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF VIRGINIA
` Alexandria Division
`RAI STRATEGIC HOLDINGS, :
`INC. and R.J. REYNOLDS :
`VAPOR COMPANY, :
` Plaintiffs/ :
` Counterclaim Defendants, : Case No.
` v. : 1:20-cv-00393-LO-TCB
`ALTRIA CLIENT SERVICES LLC; :
`PHILIP MORRIS USA INC.; and :
`PHILIP MORRIS PRODUCTS S.A., :
` Defendants/ :
` Counterclaim Plaintiffs. :
`
` CONFIDENTIAL
` VIDEOTAPED DEPOSITION of JAMES FIGLAR, Ph.D.
` Friday, June 3, 2022
` 6:54 a.m. CST
` Job No.: 450979
` Pages: 1 - 175
` Reported By: Michelle M. Yohler, CSR, RMR, CRR
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
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` A That is correct.
` Q And who is Mr. Araya?
` A He's the executive vice president of
`marketing for Reynolds in Winston-Salem. So I had
`a conversation with him to talk about marketing.
` If you remember, I think one of my earlier
`depositions you asked me about Reynolds'
`marketplace strategy and where their projections
`were and that I knew what the strategic plan was.
`And think I alluded to that in earlier
`depositions, and I wanted an update from Jorge on
`how those -- how the year went when I wasn't
`there. And so I got that update at that time in
`early April.
` Q Okay. And you also spoke with Mr. Richard
`Baker [sic]; is that right?
` A Bakker, yes, that's correct.
` Q Okay. And who is Mr. Bakker?
` A He is the CFO of Reynolds American.
` Q And just --
` A Chief financial officer of Reynolds.
` Q And just -- we'll circle back to it, but
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
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`just generally, what did you talk to Mr. Bakker
`about?
` A I wanted -- I specifically wanted to
`understand how -- well, how did the year go for
`Reynolds when I was not there in terms of the
`overall financials of the company.
` But then I also was interested in --
`because I know one of the strategic objectives we
`had was to try to make sure that the vapor
`category in total was going to be profitable for
`Reynolds, and so we talked about -- we talked
`about that and found out that -- and he was quite
`happy about it, obviously, that the Vuse portfolio
`was turning a profit in 2021 and looks to continue
`to do so moving forward.
` So that's a -- that was great news from my
`perspective for the company.
` Q And you also talked to, it looks like,
`Aaron Williams and Elaine Round?
` A That's correct.
` Q And those are both related to FDA PMTA
`issues; is that right?
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`42
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`BY MR. NAPLES:
` Q Did Reynolds make any -- reach any
`conclusions about whether using its, kind of,
`surrogate analysis for youth, whether youth are
`more likely to use menthol than regular tobacco
`products?
` MR. QUINLAN: Object to form. Beyond the
`scope.
`BY THE WITNESS:
` A Again, my recollection of the data is the
`answer to that would be, no, that the likelihood
`was the same. Especially with regard to people's
`preferences going into the survey, right? So --
`BY MR. NAPLES:
` Q Understood. Let me pause you there for a
`second, Dr. Figlar.
` A Okay.
` Q Did -- did Reynolds reach any conclusions
`about whether any particular class of people is
`more likely to use menthol than regular tobacco
`products?
` MR. QUINLAN: Object to form. And before
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`43
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`you answer, Dr. Figlar, Mr. Naples, we offered
`this deposition so that you could learn about the
`conversations that Dr. Figlar had with his
`colleagues. This isn't an opportunity for you to
`ask Dr. Figlar questions you could have asked him
`at his past two depositions.
` I'm going to give you leeway. I'm not
`trying to cut you off. I'm not trying to shut you
`down. But, as Dr. Figlar said, he's got to get on
`a plane tomorrow morning. You know, it's 2:00
`where he is, now 2:30. We're not going to go for
`eight hours today to have you ask whatever
`question you feel like you want to ask about
`whatever topic you feel like you want to ask him
`about.
` We offered him up so you can learn about
`the conversations. I've given you plenty of
`leeway so far. I just want to note for the record
`that we're not going to do this all day.
`Dr. Figlar is not going to stay here until
`10:00 p.m. his time. He's got to get ready to
`travel for this trial tomorrow.
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
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`44
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` I just want to note that for the record
`and objection, beyond the scope.
`BY THE WITNESS:
` A Can you -- can you rephrase your question,
`Counselor.
` MR. NAPLES: Can I get the question read
`back, please.
` (WHEREUPON, the record was
`read by the reporter.)
`BY THE WITNESS:
` A Not that I'm aware of. I mean, we're
`obviously aware of demographic information with
`regard to menthol cigarettes, non-menthol
`cigarettes, vapor products, et cetera, but we
`don't typically collect that information; that
`stuff is known in the literature. So --
`BY MR. NAPLES:
` Q So, Dr. Figlar, what --
` MR. QUINLAN: Objection. Objection.
`Objection. Objection. Mr. Naples, I let you cut
`him off once. You've now cut him off again. The
`witness was obviously not finished with his
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`47
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`BY MR. NAPLES:
` Q But are you aware of any targeted
`advertising of menthol products to
`African-Americans by Reynolds?
` MR. QUINLAN: Object to form. Beyond the
`scope.
`BY THE WITNESS:
` A Currently, no, I don't know -- I don't
`know of any of that. And I'm not a marketing
`person, so no.
`BY MR. NAPLES:
` Q Historically are you aware of any targeted
`marketing of menthol products to African-Americans
`by Reynolds?
` MR. QUINLAN: Object to form.
` Mr. Naples, what are we doing here? I
`mean, we're talking about historical targeted --
`potential targeted marketing of African-American
`menthol combustible cigarette smokers?
` We are so far afield from the topics that
`Dr. Figlar is going to testify at this trial, that
`he's been designated as a 30(b)(6) topic on, that
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
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`48
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`are even relevant at all to this litigation. And
`this isn't what we offered him up for a
`deposition.
` So, again, I'm not telling you that you
`can't ask him questions about the conversations he
`had with his colleagues or reasonable follow-ups
`about those conversations, but now we're so far
`afield, how did we even get here?
` So, again, I object. We urge you to focus
`on the topics that are relevant to this deposition
`today. We're not going to do this all day.
` So that's my objection.
` MR. NAPLES: Can you read my question
`back, please.
` (WHEREUPON, the record was
`read by the reporter.)
`BY THE WITNESS:
` A By -- look, by Reynolds, I'm not exactly
`sure. Look, we're going back in history, tobacco
`litigation history, and smoking and health
`litigation stuff. I haven't thought about those
`topics in a long time.
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`59
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` MR. QUINLAN: Object to form. Asked and
`answered at every depo you've taken of Dr. Figlar,
`and it's beyond the scope of this depo.
`BY THE WITNESS:
` A I'm not quite -- absent --
`BY MR. NAPLES:
` Q FDA --
` A -- I don't -- I'm not quite sure I
`understand how you worded that question.
` I mean, look, I think at the end of the
`day, if the FDA -- either the FDA is going to
`authorize the products to continue to be sold or
`they're not.
` If they do, Reynolds is going to continue
`to sell Alto. If they do not, then Reynolds
`will -- will go through their full process --
`okay? -- because they have due process with regard
`to, you know, asking for administrative review,
`blah, blah, blah, blah. But at the end of the
`day, if the FDA still refuses to authorize the
`product, they won't be able to sell it in the
`United States.
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`65
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` MR. QUINLAN: Object to form. Beyond the
`scope.
`BY THE WITNESS:
` A Again, you're asking me to -- you're
`asking me to forecast stock prices. If I could do
`that, you know, I probably would have retired from
`Reynolds a long time ago.
` But, you know, honestly, I don't know. I
`think stock prices for large companies are
`dependent on a multitude of factors. Could it?
`It might. I don't know.
`BY MR. NAPLES:
` Q Would you consider the Vuse products in
`this case successful products?
` MR. QUINLAN: Object to form. Beyond the
`scope.
` Dr. Figlar -- you haven't asked a question
`that's relevant to his conversations with the five
`individuals, which is why we offered him up for
`this deposition, in about an hour.
` So I'm going to start instructing
`Dr. Figlar not to answer questions unless it's
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`66
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`relevant in some way to his conversations, which
`is why we offered him up for this deposition.
` Dr. Figlar has to leave tomorrow for his
`flight to get here for trial. I'm not going to
`keep him there until 9:00, 10:00 at night so you
`can ask him a bunch of questions you could have
`asked him at his two other depositions.
` This is a limited deposition that we
`offered. The judge said you could take a limited
`deposition on the topics of what did he talk to
`these five people who he talked to after his
`deposition from Reynolds.
` So from now on, every question that you
`ask that's not even tangentially related to that,
`I'm going to instruct Dr. Figlar not to answer.
` MR. NAPLES: Were you at the hearing,
`Mike?
` MR. QUINLAN: I was.
` MR. NAPLES: You were. Were you -- so you
`were there when the judge said the kind of stuff
`that Reynolds pulled is the kind of thing that
`gets people disbarred, right? Were you there for
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`69
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`it out.
` Please read back the questions, Ms. Court
`Reporter.
` (WHEREUPON, the record was
`read by the reporter.)
` MR. QUINLAN: Object to form.
`BY MR. NAPLES:
` Q You can answer, Doctor.
` A Yes.
` Q Why?
` MR. QUINLAN: Object to form.
`BY THE WITNESS:
` A People buy them and use them and enjoy
`them.
`BY MR. NAPLES:
` Q Why are they successful for Reynolds?
` MR. QUINLAN: Object to form. I instruct
`Dr. Figlar, don't answer the question. It's
`beyond the scope. We're not going to do this.
`You're not going to be here all night.
` So, Dr. Figlar, I instruct you not to
`answer.
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`70
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`BY MR. NAPLES:
` Q You can answer the question, Dr. Figlar.
` A I've been instructed not to. I usually
`follow the counsel's --
` Q You're the -- you're the client here, so
`you get to do whatever you want. You don't have
`to take his advice.
` A Understood. I won't answer this one.
` Q You're not going to answer if the Vuse
`products are successful?
` MR. QUINLAN: He's not going to answer the
`question because I told him not to because we're
`so far afield of why we offered this deposition.
`BY MR. NAPLES:
` Q How about, let me do it this way:
`Dr. Figlar, when you retired at the end of
`December 2020, why, in your view, were the Vuse
`products successful?
` A Because they were an alternative to
`combustible cigarettes that are likely less
`hazardous than smoking cigarettes. And they were
`the -- in my opinion, probably one of the best
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`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 15 of 18 PageID# 33252
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`109
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`already know when you left Reynolds at the end of
`2020?
` A Yeah, again, just confirmation of
`what -- what I already knew. So I got a little
`bit more detail because I asked her, well, you
`know, how did -- you know, how did the Vuse Solo
`application look? What were -- what were FDA's,
`you know, kind of, critiques.
` The only thing that I -- I guess I didn't
`know was, in essence, FDA wants even more
`information with regard to non-tobacco flavors.
`So you're talking about the berries-type flavors.
`It's going to be a significant more --
`significantly more information's going to be
`needed before FDA is going to approve -- not
`approve -- authorize those types of flavors.
` And so I kind of knew that going in, but
`that was confirmation from my perspective from her
`and FDA, you know, through -- through the
`application process.
` Q How did she say the Vuse Solo looked --
`the Vuse Solo application looked?
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`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 16 of 18 PageID# 33253
`
`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`110
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` A Well, I mean, it's great -- right? -- I
`mean, it was authorized. The tobacco flavors were
`authorized. So I learned through her that they
`weren't going to approve menthol because it looks
`like it's going to be more of a global-type
`decision.
` And that the non-tobacco flavors, it
`wasn't going to be like what we had in our
`application -- right? -- they're going to want
`individual data -- you know, even though they
`talked about bridging, and we talked about
`bridging in our depositions, and the FDA approved
`of our -- not approved, but they liked our
`bridging strategy going in, but ultimately, it
`wasn't enough for them.
` So there's going to be a lot more data
`that's going to be needed if you have an
`expectation to getting a non-tobacco flavor
`authorized through the agency. So I learned that
`through her.
` Q Okay. Mr. Araya, same question, can you
`just tell me what Mr. Araya told you that you
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`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 17 of 18 PageID# 33254
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`174
`
` C E R T I F I C A T E O F R E P O R T E R
`
` I, MICHELLE M. YOHLER, a Certified
`Shorthand Reporter within and for the County of
`Will, State of Illinois, do hereby certify:
` That previous to the commencement of the
`examination of the witness, the witness was duly
`sworn to testify the whole truth concerning the
`matters herein;
` That the foregoing deposition transcript
`was reported stenographically by me, was
`thereafter reduced to typewriting under my
`personal direction and constitutes a true record
`of the testimony given and the proceedings had;
` That the said deposition was taken
`remotely before me at the time and place
`specified; revie was not waived.
` That I am not a relative or employee or
`attorney or counsel, nor a relative or employee of
`such attorney or counsel for any of the parties
`hereto, nor interested directly or indirectly in
`the outcome of this action.
`
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`Case 1:20-cv-00393-LO-TCB Document 1299 Filed 06/08/22 Page 18 of 18 PageID# 33255
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`Confidential
`Transcript of James Figlar, Ph.D.
`Conducted on June 3, 2022
`
`175
`
` IN WITNESS WHEREOF, I do hereunto set my
`hand and affix my seal of office at Chicago,
`Illinois, this 3rd day of June, 2022.
`
`
`
` _________________________________
` Michelle M. Yohler, CSR, RMR, CRR
` Certified Shorthand Reporter
` CSR No.: 84-4531
`
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