Amgen Inc. v. F. Hoffmann-LaRoche LTD et al

Filing 325

DECLARATION re #322 Objection in Support of Defnendants' Opposition to Amgen's Claims Construction Brief by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: #1 Exhibit T#2 Exhibit U Part 1#3 Exhibit U Part 2#4 Exhibit U Part 3#5 Exhibit U Part 4#6 Exhibit V#7 Exhibit W#8 Exhibit X#9 Exhibit Y#10 Exhibit Z#11 Exhibit AA Part 1#12 Exhibit AA Part 2#13 Exhibit BB#14 Errata CC#15 Exhibit DD#16 Exhibit EE#17 Exhibit FF#18 Exhibit GG#19 Exhibit HH#20 Exhibit II Part 1#21 Exhibit II Part 2#22 Exhibit JJ#23 Exhibit KK#24 Exhibit LL#25 Exhibit MM#26 Exhibit NN#27 Exhibit OO#28 Exhibit PP Part 1#29 Exhibit PP Part 2#30 Exhibit QQ)(Fleming, Thomas)

Amgen Inc. v. F. Hoffmann-LaRoche LTD et al

Doc. 325 Att. 23

Case 1:05-cv-12237-WGY

Document 325-24

Filed 03/19/2007

Page 1 of 2

Goldwasser, Eugene Ph.D.

2/14/2007
Page 1

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS AMGEN INC., Plaintiff, vs. F. HOFFMANN-LA ROCHE LTD., a ) ) ) ) No. 05-12237 WGY

Swiss Company, ROCHE DIAGNOSTICS ) GmbH, a German Company, and HOFFMANN-LA ROCHE INC., a New Jersey Corporation, Defendants. ) ) ) )

Videotaped Deposition of EUGENE GOLDWASSER, Ph.D., taken before GREG S. WEILAND, CSR, RMR, CRR, Notary Public, pursuant to the Federal Rules of Civil Procedure for the United States District Court pertaining to the taking of depositions, at Suite 4100, Three First National Plaza, in the City of Chicago, Cook County, Illinois, commencing at 9:13 o'clock a.m., on the 14th day of February, 2007.

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Case 1:05-cv-12237-WGY

Document 325-24

Filed 03/19/2007

Page 2 of 2

Goldwasser, Eugene Ph.D.

2/14/2007
Page 178

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difference in molecular weight? A. Q. A. Not a discernible difference, no. Okay. So what was your understanding of

why the iodination of the epo inactivated it? Because as we published some years later, the tyrosine in urinary epo at position 15 was very much involved with the binding to the receptor and therefore the biological activity, and by putting the bulky iodine in, you got -- you changed the structure so that it no longer had any biological activity. Q. A. Q. A. Q. A. Q. A. Q. And did you know that in 1983? No. When did you learn that? '97 or something like that. 1997? '97 I think. Yeah, okay. Whenever we published that paper. Okay. So at the time in the '80s when you

were doing this iodination work, could you predict whether a substitution would impact the biological activity of the epo? A. Q. No, you couldn't. Okay. Could you --

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