`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 1 of 4 PagelD #: 49989
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`EXHIBIT 15
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`
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`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 2 of 4 PageID #: 49990
`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 2 of 4 PagelD #: 49990
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
`CLARKSBURG DIVISION
`
`
`
`
`REGENERON PHARMACEUTICALS, INC.,
`
`Plaintiff,
`
`Vv.
`
`MYLAN PHARMACEUTICALSINC.,
`
`Defendant.
`
`Case No. 1:22-cv-00061-TSK.
`
`CONFIDENTIAL - SUBJECT TO
`PROTECTIVE ORDER
`
`REGENERON PHARMACEUTICALS, INC.’S OBJECTIONS AND RESPONSES TO
`DEFENDANT’S FIRST SET OF INTERROGATORIES (NOS. 1-17
`
`Pursuant to Rules 33 of the Federal Rules of Civil Procedure and Rule 33.01 of the Local
`
`Rules of Civil Procedure, Plaintiff Regeneron Pharmaceuticals, Inc. (“Plaintiff and/or
`
`Regeneron’), by and through its counsel, hereby submits the following objections and responses
`
`to Defendant Mylan Pharmaceuticals Inc.’s (“Defendant” and/or “Mylan”) First Set of
`
`Interrogatories (Nos. 1-17) (“Interrogatories”).
`
`These objections and responses are based on information currently available and without
`
`prejudice to Regeneron’s right to produce evidence of any subsequently discovered fact or
`
`information, to add, modify, or otherwise change, amend, or supplementits responses as
`
`appropriate or to correct any inadvertent errors, mistakes, or omissions.
`
`GENERAL OBJECTIONS
`
`1.
`
`Regeneron incorporates by reference these General Objections into each and
`
`every specific response below. A specific response may repeat a General Objection for emphasis
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`or for other reasons. The omission of any General Objection in any specific response to an
`
`Interrogatory is not intended to be and should not be construed as a waiveror limitation of any
`
`1
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`
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`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 3 of 4 PageID #: 49991
`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 3 of 4 PagelD #: 49991
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`first publicly used upon the launch of Eylea following the first FDA approval on November18,
`
`2011.
`
`Meeeeeeeeeeeeeeeeeeeeeeeeeeeneeeeeeeeeeeeenneeeeel
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`waspublished on June 10, 2021.
`
`INTERROGATORYNO.6
`If Regeneron contends that any reference identified as prior art in Mylan’s Detailed
`Statements provided pursuant to 42 U.S.C. § 262(1)(3)(B) and/or § 262(1)(7)(B) does not qualify
`as prior art under 35 U.S.C. § 102 or 35 U.S.C. § 103 with respect to any asserted claim of the
`Initial Patents, based on the date and/or public availability of such reference (or any other
`reason), identify each such reference for each such claim and provide each basis for Regeneron’s
`contention.
`
`RESPONSE TO INTERROGATORYNO. 6:
`
`Regeneron incorporates each of its General Objectionsas if fully set forth herein.
`
`Regeneron objects to this Interrogatory to the extent that it seeks documents and things
`
`protected by the attorney-client privilege, the work-product doctrine, the common-interest
`
`privilege, or any other applicable privilege.
`
`Subject to the foregoing general and specific objections, Regeneron states as follows:
`
`With respect to U.S. Patent No. 11,084,865:
`
`e U.S. Patent No. 7,608,261 is not prior art under either 35 U.S.C. § 102 or 35
`
`
`
`USS.C. § 103.
`
`e US. Patent No. 8,110,546 is not prior art under either 35 U.S.C. § 102 or 35
`
`USS.C. § 103.
`
`e US. Patent No. 8,647,842 is not prior art under either 35 U.S.C. § 102 or 35
`
`US.C. § 103.
`
`e US. Patent No. 9,340,594 is not prior art under either 35 U.S.C. § 102 or 35
`
`18
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`
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`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 4 of 4 PageID #: 49992
`Case 1:22-cv-00061-TSK-JPM Document 633 Filed 09/01/23 Page 4 of 4 PagelD #: 49992
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`U.S.C. § 103.
`
`e US. Patent No. 9,580,489 is not prior art under either 35 U.S.C. § 102 or 35
`
`U.S.C. § 103.
`
`e US. Patent No. 9,914,763 is not prior art under either 35 U.S.C. § 102 or 35
`
`U.S.C. § 103.
`
`e US. Patent No. 10,406,226 is not prior art under either 35 U.S.C. § 102 or 35
`
`U.S.C. § 103.
`
` U.S.C. § 103.
`
`e US. Patent No. 10,464,992 is not prior art under either 35 U.S.C. § 102 or 35
`
`* The ’959 patent Petition for Patent Term Extension is not prior art under either 35
`
`U.S.C. § 102 or 35 U.S.C. § 103.
`
`e US. Patent No. 9,340,594 is not prior art under either 35 U.S.C. § 102 or 35
`
`U.S.C. § 103.
`
`e The 11/22/11 Response to 7/13/11 Office Action regarding U.S. Patent No.
`
`8,110,546 is not prior art under either 35 U.S.C. § 102 or 35 U.S.C. § 103.
`
`e U.S. Patent Application Publication No. 2016/0144025is not prior art under
`
`either 35 U.S.C. § 102 or 35 U.S.C. § 103.
`
`e The LUCENTIS® Prescribing Information (2006) is not prior art under 35 U.S.C.
`
`§ 102 or 35 U.S.C. § 103.
`
`® The EYLEA Prescribing Information (2011) is not prior art under 35 U.S.C. § 102
`
`or 35 U.S.C. § 103.
`
`With respect to the Yancopoulos Patents:
`
`* The ’959 patent Petition for Patent Term Extension is not prior art under either 35
`
`19
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`
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