`16089
`
`EXHIBIT A
`DEFINITIONS
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`1.
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`The term “document” is used in a comprehensive sense as set forth in Fed. R. Civ.
`
`P. 34(a) and means all written or graphic matter, however produced or reproduced, in
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`Genentech’s actual or constructive possession, custody, care or control, including without
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`limitation, originals (or copies where originals are unavailable) of correspondence, e-mail,
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`computer storage media, computer software needed to produce in human-readable form from
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`said computer storage media, instructions for using said computer software, telegrams, notes of
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`any type of personal or telephone conversations, or of meetings or conferences, minutes of
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`directors or committee meetings, memoranda, inter-office communications, studies, analyses,
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`reports, engineering drawings, results of investigations, catalogs, contracts, licenses, agreements,
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`working papers, statistical records, ledgers, books of account, vouchers, invoices, charge slips,
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`freight bills, time sheets or logs, stenographers’ notebooks, diaries, or papers similar to any of
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`the foregoing however denominated. “Documents” shall also include drafts of any of the
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`foregoing however denominated. “Documents” shall also mean (1) any copy which is not
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`identical to the original or to any other copy and (2) any tangible thing that is called for by or
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`identified in response to a request for documents.
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`2.
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`The term “concerning” means relating to, referring to, describing, evidencing, or
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`constituting.
`
`3.
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`Something is “relating to” a subject if it makes a statement about, refers to,
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`mentions, discusses, describes, reflects, deals with, consists of, constitutes, comprises, concerns,
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`evidences, records, or in any way pertains to the subject, whether as a whole or in part, and either
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`directly or indirectly.
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`
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`Case 1:23-cv-00089-TSK-JPM Document 123-2 Filed 03/05/24 Page 2 of 2 PageID #:
`16090
`
`4.
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`The terms “and” and “or” shall be construed both conjunctively and disjunctively
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`and the plural shall be construed as the singular, and vice versa, as necessary and in order to
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`bring within the scope of these Requests any information, documents, or things that might
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`otherwise be construed to be outside their scope.
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`5.
`
`6.
`
`7.
`
`8.
`
`9.
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`The use of the singular form of any word includes the plural and vice versa.
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`The term “including” means including, without limitation.
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`The term “BLA” means Biologics License Application.
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`The term “PFS” means pre-filled syringe.
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`The term “Lucentis® PFS” means the brand ranibizumab PFS products for which
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`Genentech, Inc. holds BLA No. 125156 in the United States, including any amendments or
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`supplements thereto.
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`10.
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`The term “Lucentis® PFS Packaging Tray” means the tray in which the Lucentis®
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`PFS is packaged and sealed.
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`
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`DOCUMENTS REQUESTED
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`1. Documents sufficient to show when the Lucentis® PFS first became commercially
`available.
`
`
`2. Documents, for example from the Lucentis® BLA, sufficient to show, at the time that the
`Lucentis® PFS first became commercially available: (a) the size, composition, shape, and
`dimensions of all features on the Lucentis® PFS Packaging Tray (e.g., all geometric features,
`cavities, narrowed portions, projections, sidewalls, and packaging seal), (b) the configuration of
`the Lucentis® PFS Packaging Tray (e.g., the various states that the Lucentis® PFS Packaging
`Tray may be configured in), and (c) the terminal sterilization of the Lucentis® PFS Packaging
`Tray.
`
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`3. Documents showing any modifications to the Lucentis® PFS Packaging Tray and the
`timing of such modifications, after the Lucentis® PFS first became commercially available.
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`
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