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

Filing 722

MEMORANDUM in Support re #720 Emergency MOTION to Strike Portions of Eight Exhibits Containing Roche Manufacturing Trade Secrets that are Not Necessary for Amgen's Infringement Motions or in the Alternative to Seal These Select Exhibits filed by F. Hoffmann-LaRoche LTD, Roche Diagnostics GmbH, Hoffmann LaRoche Inc.. (Attachments: #1 Civil Cover Sheet A)(Toms, Keith)

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Case 1:05-cv-12237-WGY Document 722-2 Filed 07/13/2007 Page 1 of 4 APPENDIX A Scott Declaration, Exhibit 5 Citation in Amgen's Papers 56.1 Statement, ¶ 1 56.1 Statement, ¶ 5 56.1 Statement, ¶ 39 56.1 Statement, ¶ 40 Lodish Declaration, ¶ 49 Lodish Declaration, ¶ 50 Lodish Declaration, ¶ 68 Exhibit Pages Cited by Amgen ITC-R-BLA-00004178 ITC-R-BU-00004178 ITC-R-BLA-00004200 ITC-R-BLA-00004200 ITC-R-BLA-00004061; ITC-R-BLA-00004031231 ITC-R-BLA-00004045 ITC-R-BLA-00004200 Relevance of Exhibit The only page cited by Amgen may be filed in the public record; also cumulative with Scott Ex. 3 at ITC-R-BLA-0000249 Cumulative with one other public citation The only page cited by Amgen may be filed in the public record; also cumulative with four other public citations The only page cited by Amgen may be filed in the public record; also cumulative with three other public citations Cumulative with one other public citation Cumulative with Scott Ex. 3 at ITC-R-BLA-0000249 The only page cited by Amgen may be filed in the public record Scott Declaration, Exhibit 8 Citation in Amgen's Papers 56.1 Statement, ¶8 56.1 Statement, ¶14 56.1 Statement, ¶14 Exhibit Pages Cited by Amgen ITC-R-BLA-0004667 ITC-R-BLA-00004667 ITC-R-BLA-0000467466 Relevance of Exhibit The only page cited by Amgen may be filed in the public record Cumulative with one other public citation Cumulative with one other public citation 1 Dockets.Justia.com Case 1:05-cv-12237-WGY Document 722-2 Filed 07/13/2007 Page 2 of 4 56.1 Statement, ¶15 56.1 Statement, ¶16 56.1 Statement, ¶ 16 56.1 Statement, ¶ 16 Lodish Declaration, ¶ 42 Lodish Declaration, ¶ 46 Lodish Declaration, ¶ 46 Lodish Declaration, ¶ 46 ITC-R-BLA-00004667 ITC-R-BLA00004667 ITC-R-BLA-00004682 ITC-R-BLA-00004685 ITC-R-BLA-00004667 ITC-R-BLA-00004667 ITC-R-BLA-0000467374 ITC-R-BLA-0000468283 Cumulative with one other public citation Cumulative with one other public citation Cumulative with one other public citation Cumulative with one other public citation This page is offered by Roche for public filing This page is offered by Roche for public filing Cumulative with Scott Exhibit 8 at ITC-R-BLA00004667, which has been offered by Roche for public filing Cumulative with Scott Exhibit 3 at ITC-R-BLA00000251 Scott Declaration, Exhibit 9 Citation in Amgen's Papers 56.1 Statement, ¶ 9 56.1 Statement, ¶ 10 56.1 Statement, ¶ 10 56.1 Statement, ¶ 11 56.1 Statement, ¶ 11 56.1 Statement, ¶ 12 56.1 Statement, ¶ 13 Lodish Declaration ¶ 38 Lodish Declaration ¶ 42 Lodish Declaration ¶ 43 Exhibit Pages Cited by Amgen ITC-R-BLA-00004803 ITC-R-BLA-00004723 ITC-R-BLA-00004987 ITC-R-BLA-000047354737 ITC-R-BLA-00004987 ITC-R-BLA-00004723 ITC-R-BLA-00004987 ITC-R-BLA-0000472324 ITC-R-BLA-0000480356 ITC-R-BLA-00004934; ITC-R-BLA-00004987 Relevance of Exhibit Cumulative with two other public citations Cumulative with one other public citation Cumulative with one other public citation Cumulative with two other public citations Cumulative with two other public citations Cumulative with one other public citation Cumulative with one other public citation Cumulative with one other public citation Cumulative with Scott Exhibit 66, p. 37-39 Page ITC-R-BLA-00004987 offered by Roche for public filing; remaining page is merely cumulative 2 Case 1:05-cv-12237-WGY Document 722-2 Filed 07/13/2007 Page 3 of 4 Lodish Declaration ¶ 43 Lodish Declaration ¶ 43 Lodish Declaration ¶ 44 Lodish Declaration ¶ 45 Amgen's Memorandum of Law ITC-R-BLA-00004989; ITC-R-BLA-00004987; ITC-R-BLA-00005053 ITC-R-BLA-0000498790 ITC-R-BLA-0000472425 ITC-R-BLA-00004724 ITC-R-BLA-00004987 Page ITC-R-BLA-00004987 offered by Roche for public filing; remaining pages are merely cumulative Page ITC-R-BLA-00004987 offered by Roche for public filing. Cumulative with Scott Exhibit 10 Cumulative with one other public citation Page ITC-R-BLA-00004987 offered by Roche for public filing. Scott Declaration, Exhibit 43 Citation in Amgen's Papers Lodish Declaration ¶ 53 Amgen's Memorandum of Law 56.1 Statement, ¶ 22 56.1 Statement, ¶ 26 56.1 Statement, ¶ 27 56.1 Statement, ¶ 41 Exhibit Pages Cited by Amgen R000081253 R000081258 R000081258 R000081258 R000081253 R000081253 Relevance of Exhibit The only page cited by Amgen may be filed in the public record; also, cumulative with three other public citations which Amgen cited for the same proposition The only page cited by Amgen may be filed in the public record. The only page cited by Amgen may be filed in the public record; also, cumulative with three other public citations which Amgen cited for the same proposition The only page cited by Amgen may be filed in the public record; also, cumulative with eight other public citations which Amgen cited for the same proposition The only page cited by Amgen may be filed in the public record; also, cumulative with four other public citations which Amgen cited for the same proposition The only page cited by Amgen may be filed in the public record; also, cumulative with three other public citations which Amgen cited for the same proposition 3 Case 1:05-cv-12237-WGY Document 722-2 Filed 07/13/2007 Page 4 of 4 Scott Declaration, Exhibit 45 Citation in Amgen's Papers Lodish Declaration ¶ 51 Exhibit Pages Cited by Amgen ITC-R-00050625 Relevance of Exhibit The only page cited by Amgen may be filed in the public record Scott Declaration, Exhibit 55 Citation in Amgen's Papers 56.1 Statement, ¶ 22 Exhibit Pages Cited by Amgen ITC-R-00050548 Relevance of Exhibit The only page cited by Amgen may be filed in the public record; also cumulative with four other public references that Amgen cited for the same proposition Scott Declaration, Exhibit 63 Citation in Amgen's Papers 56.1 Statement, ¶ 28 56.1 Statement, ¶ 33 Exhibit Pages Cited by Amgen ITC-R-00091008 ITC-R-00090916 Relevance of Exhibit Cumulative with two other public citations Cumulative with three other public citations Gavin Declaration, Exhibit 1 Citation in Amgen's Papers 56.1 Statement, ¶ 28 56.1 Statement, ¶ 33 03099/00501 703426.1 Exhibit Pages Cited by Amgen ITC-R-00091008 ITC-R-00090916 Relevance of Exhibit Cumulative with two other public citations Cumulative with three other public citations 4

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