Case 1:18-cv-00924-CFC-SRF Document 450-2 Filed 10/25/19 Page 1 of 8 PageID
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`EXHIBIT 2
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`Case 1:18-cv-00924-CFC-SRF Document 450-2 Filed 10/25/19 Page 2 of 8 PageID
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`CONFIDENTIAL
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` IN THE UNITED STATES DISTRICT COURT
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` FOR THE DISTRICT OF DELAWARE
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`- - - - - - - - - - - - - - - x
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` GENENTECH, INC., et al., :
`
` Plaintiffs, : Case Nos.
`
` v. : 18-924-CFC
`
` AMGEN, INC., : 17-1407-CFC
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` Defendant. :
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`- - - - - - - - - - - - - - - x
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` CONFIDENTIAL VIDEOTAPED DEPOSITION OF:
`
` HANSJÖRG HAUSER, Ph.D.,
`
` Friday, October 11, 2019
`
` Washington, D.C.
`
`called for oral examination by counsel for the
`
`Defendant, pursuant to notice, at the law offices of
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`Williams & Connolly, LLP, 725 12th Street, Northwest,
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`Washington, D.C. 20005, before Christina S. Hotsko,
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`RPR, CRR, of Veritext Legal Solutions, a Notary
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`Public in and for the District of Columbia, beginning
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`at 9:20 a.m., when were present on behalf of the
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`respective parties:
`
`JOB NO. 3562182
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`PAGES 1 - 296
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`Case 1:18-cv-00924-CFC-SRF Document 450-2 Filed 10/25/19 Page 3 of 8 PageID
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`CONFIDENTIAL
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`1 A P P E A R A N C E S
`2 On behalf of Plaintiffs:
` JONATHAN S. SIDHU, ESQUIRE
`3 DAVID I. BERL, ESQUIRE
` Williams & Connolly, LLP
`4 725 12th Street, Northwest
` Washington, D.C. 20005
`5 (202) 434-5491
` dberl@wc.com
`6 jsidhu@wc.com
`7 RANA SAWAYA, Ph.D., ESQUIRE
` Wilmer Cutler Pickering Hale and Dorr LLP
`8 Seven World Trade Center 250
` New York, New York 10007
`9 (212) 230-8897
` rana.sawaya@wilmerhale.com
`
`10
`11 On behalf of Defendant:
` SIEGMUND Y. GUTMAN, ESQUIRE
`12 DAVID M. HANNA, ESQUIRE
` Proskauer Rose, LLP
`13 2029 Century Park East, Suite 2400
` Los Angeles, California 90067-3010
`14 (310) 284-4533
` sgutman@proskauer.com
`15 dhanna@proskauer.com
`16 EAMONN GARDNER, ESQUIRE
` Cooley, LLP
`17 380 Interlocken Crescent, Suite 900
` Broomfield, CO 80021-8023
`18 (858) 550-6086
` egardner@cooley.com
`
`19
`20 Also Present:
` Gene Aronov, Video Technician
`21 Drew Diamond, Amgen
` Andrew Le, Genentech
`22 Chris Meade, Amgen
`23
`24
`25
`
`1 P R O C E E D I N G S
`2 VIDEO TECHNICIAN: Good morning. We
`3 are going on the record at 9:20 a.m. on
`4 October 12th, 2019.
`5 Please note that the microphones are
`6 sensitive and may pick up whispering, private
`7 conversations, and cellular interference.
`8 Please turn off all cell phones or place them
`9 away from the microphones, as they can
`10 interfere with the deposition audio.
`11 Audio and video recording will continue
`12 to take place unless all parties agree to go
`13 off the record.
`14 This is media unit 1 of the
`15 video-recorded deposition of Hansjörg Hauser 09:20:42
`16 taken by counsel for defendant in the matter of
`17 Genentech, Inc., et al., versus Amgen, Inc.,
`18 filed in the United States District Court for
`19 the District of Delaware, case number
`20 18-924-CFC, consolidated with 17-1407-CFC. 09:21:03
`21 This deposition is being held at
`22 Williams & Connolly, located at
`23 725 12th Street, Northwest, Washington, D.C.
`24 My name is Gene Aranov from the firm
`25 Veritext Legal Solutions, and I'm the 09:21:21
`
`Page 2
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`Page 4
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`1 videographer. The court reporter is Christina
`2 Hotsko from the firm Veritext Legal Solutions.
`3 I am not authorized to administer an
`4 oath, I am not related to any party in this
`5 action, nor am I financially interested in the 09:21:33
`6 outcome.
`7 Counsel and all present in the room and
`8 everyone attending remotely will now state
`9 their appearances and affiliations for the
`10 record. If there are any objections to 09:21:42
`11 proceeding, please state them at the time of
`12 your appearance, beginning with the noticing
`13 attorney.
`14 MR. GUTMAN: Siegmund Gutman of
`15 Proskauer Rose for Amgen, Inc. 09:21:52
`16 MR. HANNA: David Hanna of
`17 Proskauer Rose for Amgen, Inc.
`18 MR. GARDNER: Eamonn Gardner of Cooley
`19 for Amgen.
`20 MR. MEADE: Chris Meade for Amgen. 09:22:01
`21 MR. DIAMOND: Drew Diamond for Amgen.
`22 MR. BERL: David Berl, Williams &
`23 Connolly, for Genentech and the witness. With
`24 me is Jonathan Sidhu, also of Williams &
`25 Connolly. 09:22:11
`
`1 C O N T E N T S
`2 EXAMINATION BY: PAGE
`3 Counsel for Defendant 06
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`4 5 6
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`HAUSER DEPOSITION EXHIBITS: * PAGE
`7 Exhibit 1 '869 Kao Patent 31
`8 Exhibit 2 Hauser Opening Expert Report 60
`9 Exhibit 3 Declaration of Dr. Hansjörg 90
` Hauser in Support of Genentech's
`10 Letter Brief Concerning
` Construction of Following
`11 Fermentation
`12 Exhibit 4 Hauser Rebuttal Expert Report 160
`13 Exhibit 5 Identification and Prevention of 229
` Antibody Disulfide Bond Reduction
`14 During Cell Culture Manufacturing
`15
`16
`17
`18
`19
`20
`21 * (Exhibits attached to transcript.)
`22
`23
`24
`25
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`Case 1:18-cv-00924-CFC-SRF Document 450-2 Filed 10/25/19 Page 4 of 8 PageID
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`CONFIDENTIAL
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`1 aspect which distinguishes the seed train from
`2 the final fermentation. It's the fact that, in
`3 the final fermentation -- this is a technical
`4 process, but it's designed to produce enough
`5 cells and to produce enough of the product. 10:21:04
`6 BY MR. GUTMAN:
`7 Q. Now, in what sort of vessel is the seed
`8 train occurring?
`9 A. At the beginning --
`10 MR. BERL: Objection. 10:21:19
`11 THE WITNESS: At the beginning, it's a
`12 cell culture flask. Later on, it's a shaker.
`13 Then we go up to small cell cult- -- small
`14 fermenters. And then it's grown up and, at a
`15 certain point, it's in a mid-sized type of cell 10:21:33
`16 culture fermenter.
`17 BY MR. GUTMAN:
`18 Q. So the seed train is happening in a
`19 fermenter, correct?
`20 A. In seed train fermenters. True. 10:21:43
`21 Q. And how large are these seed train
`22 fermenters?
`23 A. That depends on the final -- final
`24 fermentation process and depends how much cells
`25 you need there. Typically, the fermenter is -- 10:21:59
`Page 50
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`1 the final fermentation is started with 2 times
`2 10 to the 5 cells. So you need enough material
`3 to start this process.
`4 Q. Now, the next step in the process,
`5 which you referred to as fermentation or 10:22:24
`6 production, that -- you're taking cell culture
`7 fluid out of the seed train fermenter and
`8 you're transferring it into a larger fermenter,
`9 right?
`10 MR. BERL: Objection. 10:22:45
`11 THE WITNESS: Cell culture fluid
`12 including cells. Yes.
`13 BY MR. GUTMAN:
`14 Q. So you're taking cell culture fluid and
`15 cells out of the seed train fermenter, and 10:22:55
`16 you're physically removing it from the seed
`17 train fermenter and you're putting it into a
`18 larger fermenter, correct?
`19 A. It's typically pumped over.
`20 Q. Okay. And is that a process that's 10:23:09
`21 sometimes referred to as inoculation?
`22 A. It can be. The term "inoculation" can
`23 be used. Yes.
`24 Q. And so you're taking the contents of
`25 the seed train fermenter and you're inoculating 10:23:37
`Page 51
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`1 the larger production fermenter with what
`2 you've taken from the seed train fermenter,
`3 correct?
`4 A. Correct.
`5 Q. Now, during the process of transferring 10:23:48
`6 the cell culture fluid from the seed train
`7 fermenter into the larger fermenter -- and I
`8 think you -- you testified that it's pumped
`9 over, right?
`10 A. I said in most cases. 10:24:12
`11 Q. And it's pumped over in a pipe, right?
`12 A. In a pipe.
`13 Q. That process of pumping over the cell
`14 culture fluid from the seed train fermenter to
`15 the larger fermenter for production, that's -- 10:24:29
`16 that's a change of conditions from those that
`17 existed in the seed train fermenter, correct?
`18 MR. BERL: Objection.
`19 THE WITNESS: It's a change in
`20 condition because it's pumped into a new fresh 10:24:47
`21 medium. And yeah, it's a change in conditions.
`22 BY MR. GUTMAN:
`23 Q. And those -- that change of conditions,
`24 while it's being pumped over, is -- are not the
`25 optimal conditions for either cell growth or 10:25:01
`Page 52
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`1 production of the protein, correct?
`2 MR. BERL: Objection. Vague.
`3 THE WITNESS: It is -- for the
`4 inoculation of the fermenter, it is the optimal
`5 condition, but it's not the same condition as 10:25:17
`6 it is used for cell growth or for production.
`7 MR. GUTMAN: We've been going for about
`8 an hour. Why don't we take a break.
`9 VIDEO TECHNICIAN: We are going off the
`10 record. This is the end of media 10:25:54
`11 unit number 1. The time is 10:25 a.m.
`12 (A recess was taken.)
`13 VIDEO TECHNICIAN: We are back on the
`14 record. This is the beginning of media
`15 unit number 2. The time is 10:49 a.m. 10:49:44
`16 BY MR. GUTMAN:
`17 Q. Welcome back, Dr. Hauser.
`18 Before our break we were walking
`19 through the process to make a recombinant
`20 protein. And I think we ended with taking the 10:50:04
`21 cell culture fluid from the seed train and
`22 inoculating a larger fermenter with that cell
`23 culture fluid.
`24 Do you recall that?
`25 A. I do. 10:50:19
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`1 Q. And so now I want to talk about what's
`2 happening in the larger fermenter in the next
`3 step.
`4 What should we call the next step after
`5 the seed train? 10:50:33
`6 A. This is called the production fermenter
`7 or fermentation.
`8 Q. So it's the production step?
`9 A. It's a production step which includes
`10 cell growth and production. 10:50:52
`11 Q. And it's your opinion that because we
`12 are now making -- growing cells and making a
`13 protein of interest on a technical scale using
`14 a technical process, that this is now the
`15 beginning of fermentation; is that correct? 10:51:23
`16 MR. BERL: Objection.
`17 THE WITNESS: It is the beginning of
`18 the fermentation process because we are
`19 starting now to optimize the conditions for
`20 cell growth and production. 10:51:46
`21 BY MR. GUTMAN:
`22 Q. And you're doing it on a scale that --
`23 that is important for the production of a
`24 therapeutic protein, correct?
`25 MR. BERL: Objection. 10:52:07
`Page 54
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`1 be at least 10 percent in the production
`2 fermenter, correct?
`3 MR. BERL: Objection.
`4 THE WITNESS: In most cases, it is
`5 10 percent and above, but it may depend on the 10:54:13
`6 individual process a company designs, whether
`7 it's all time at the very beginning, for
`8 example, 10 percent. But basically, most
`9 cases, it is.
`10 BY MR. GUTMAN: 10:54:27
`11 Q. And you're not aware of any
`12 fermentation process that's done on a technical
`13 scale where the level of dissolved oxygen would
`14 be below 10 percent, are you?
`15 MR. BERL: Objection. 10:54:47
`16 THE WITNESS: It is possible that there
`17 are technical processes where the level is
`18 below 10 percent.
`19 BY MR. GUTMAN:
`20 Q. That's not my question. 10:55:07
`21 My question is, are you specifically
`22 aware of any fermentations that are done on a
`23 technical scale as a technical process where
`24 the dissolved oxygen level in the cell culture
`25 fluid is below 10 percent? 10:55:20
`
`Page 56
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`1 THE WITNESS: It is on the scale that
`2 is designed by the company to get enough
`3 product from one run, for example.
`4 BY MR. GUTMAN:
`5 Q. Now, during the process that's 10:52:27
`6 occurring in the production fermenter, as you
`7 described it, you're air sparging the cell
`8 culture fluid that's in the production
`9 fermenter, correct?
`10 MR. BERL: Objection. 10:52:46
`11 THE WITNESS: During the process of
`12 this fermentation, there is air sparging.
`13 BY MR. GUTMAN:
`14 Q. And just like we discussed in
`15 connection with the work that you did in the 10:53:01
`16 '80s relating to the production of
`17 Interleukin-2 and Interferon-beta, you're
`18 air sparging the cell culture fluid to provide
`19 a certain level of dissolved oxygen in the cell
`20 culture fluid, right? 10:53:18
`21 A. The -- yeah. The fermentation run is
`22 done -- the first sparging during fermentation
`23 run is done to supply cell culture fluid with
`24 enough oxygen.
`25 Q. And that level of dissolved oxygen will 10:53:40
`Page 55
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`1 MR. BERL: Objection.
`2 THE WITNESS: I am not aware of such
`3 kind of processes. But just to mention that
`4 it's easily possible that they exist.
`5 BY MR. GUTMAN: 10:55:32
`6 Q. And so there's oxygen in the cell
`7 culture fluid that is -- that is part of that
`8 fermentation process, right?
`9 MR. BERL: Objection.
`10 THE WITNESS: The oxygen in the cell 10:55:52
`11 culture fluid is to support the process of cell
`12 growth and production.
`13 BY MR. GUTMAN:
`14 Q. Now, is it possible that cells are
`15 being lysed during this fermentation process? 10:56:19
`16 MR. BERL: Objection.
`17 THE WITNESS: Cells are permanently
`18 lysed during a fermentation process.
`19 BY MR. GUTMAN:
`20 Q. What do you mean by permanently lysed? 10:56:32
`21 A. In a process where sparging and
`22 agitation by impeller is ongoing, there is
`23 always a certain amount of mechanical
`24 destruction of cells. In addition, there are
`25 cells -- cell populations in particular in the 10:56:58
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`1 of cell concentration. That's one method,
`2 right?
`3 A. (No verbal response.)
`4 Q. And then you also referred to -- you
`5 referred to thymidine incorporation as another 11:52:48
`6 method, right?
`7 A. Yes.
`8 Q. Those are two different methods?
`9 A. They are two different methods.
`10 Q. Is it possible that you would see cell 11:52:57
`11 proliferation using the thymidine incorporation
`12 method, and you could measure cell
`13 proliferation that way, but if you then looked
`14 at the same process using the cell --
`15 A. Concentration. 11:53:22
`16 Q. -- cell concentration method -- thank
`17 you -- that it's possible you wouldn't see any
`18 cell proliferation, that the different methods
`19 could lead to different observations about
`20 whether there was or was not cell 11:53:39
`21 proliferation?
`22 MR. BERL: Objection. Lack of
`23 foundation. Incomplete hypothetical.
`24 THE WITNESS: I'm taking your example
`25 to show that it's not the measurability, that 11:53:48
`Page 98
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`1 MR. BERL: Objection. Incomplete
`2 hypothetical. Lack of foundation.
`3 THE WITNESS: If I only take these
`4 measurements, you're right. But in reality,
`5 people not only look for the increase of cell 11:55:21
`6 growth. They also look for dead cells versus
`7 living cells, for example.
`8 BY MR. GUTMAN:
`9 Q. And what do you mean by that, people
`10 also look for dead cells versus living cells? 11:55:38
`11 A. The count of living versus dead cells
`12 gives you an idea about the status of the
`13 culture. So in both cases, you don't look at
`14 the number -- the absolute numbers. You
`15 compare it over time. And this gives you an 11:56:02
`16 idea of whether there is further cell growth or
`17 not.
`18 But it's not an absolute measurement, I
`19 must say. It doesn't -- at the end, it doesn't
`20 tell you all the details you want to know. 11:56:23
`21 Q. What does tell you all the details that
`22 you want to know --
`23 MR. BERL: Objection. Vague.
`24 Incomplete hypothetical.
`25 11:56:32
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`Page 100
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`1 it's what you can learn from a certain
`2 measurement. If.
`3 You measure thymidine incorporation,
`4 you can see whether DNA is newly made, and that
`5 tells you that -- indirectly, that the cells 11:54:04
`6 are proliferating, that if -- from one cell,
`7 two, and so on are produced. That's a
`8 quantitative measurement.
`9 If you look to the concentration of
`10 cells, you have to take into account whether 11:54:19
`11 there is also cell death. So the concentration
`12 is a -- is a composite of cell death and
`13 increase of -- and new proliferation.
`14 And so you cannot compare both methods
`15 because they have a different reading. That's 11:54:43
`16 what I said before.
`17 BY MR. GUTMAN:
`18 Q. Right. And so you may conclude that
`19 there is cell proliferation utilizing the
`20 thymidine incorporation method because you may 11:54:50
`21 see the thymidine being incorporated into the
`22 DNA of the cell, but you may not see an
`23 increase in cell concentration because it's a
`24 different readout and it depends on whether
`25 there's cell death or not? 11:55:04
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`Page 99
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`1 BY MR. GUTMAN:
`2 Q. -- if anything?
`3 MR. BERL: Objection.
`4 THE WITNESS: In cell culture
`5 technology, there is -- if you are talking now 11:56:39
`6 of fermentation, there is no really good method
`7 that tells you whether proliferation is ongoing
`8 or not. It's based on the experience of the
`9 operators, on the data over time to determine
`10 whether the cultivation -- or the proliferation 11:57:03
`11 has been stopped.
`12 BY MR. GUTMAN:
`13 Q. And is that the same for production of
`14 the protein?
`15 MR. BERL: Objection. 11:57:12
`16 THE WITNESS: That's not the same.
`17 Production of the protein is measured by
`18 increase of the protein concentration over
`19 time. And that's a very objective and
`20 measurable amount. 11:57:23
`21 BY MR. GUTMAN:
`22 Q. So assessing -- assessing protein
`23 concentration over time is an objective and
`24 measurable -- strike that.
`25 Assessing protein concentration over 11:57:48
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`CONFIDENTIAL
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`1 antibody, that, for example, one chain has been
`2 released from the other, from the core product.
`3 Q. Now, have you ever analyzed a trace
`4 of -- that was generated by an nrCE-SDS assay?
`5 A. What are you talking about? What's a 13:42:58
`6 trace? It's a -- it's a peak or --
`7 Q. Yeah. It's -- it's a picture of the
`8 peaks that are generated from conducting the
`9 nrCE-SDS assay.
`10 MR. BERL: Objection. 13:43:17
`11 THE WITNESS: You are asking whether I
`12 have been doing that by myself?
`13 BY MR. GUTMAN:
`14 Q. Well, let me ask you --
`15 A. Or looking -- 13:43:22
`16 Q. -- have you ever done an nrCE-SDS
`17 assay?
`18 A. Not by myself. I just looked at the
`19 data.
`20 Q. So you've analyzed the data? 13:43:29
`21 A. Yeah.
`22 Q. So you've looked at the peaks --
`23 A. Yes.
`24 Q. -- that are generated from doing an
`25 nrCE-SDS -- 13:43:37
`
`Page 146
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`1 BY MR. GUTMAN:
`2 Q. Well, even with respect to
`3 intermolecular disulfide bonds -- actually, you
`4 have a nice picture in your --
`5 A. It's here. 13:45:01
`6 MR. BERL: Do you mean to say "intra"
`7 or "inter"? I think you meant to say "intra"
`8 and it's "inter."
`9 MR. GUTMAN: No, "inter."
`10 MR. BERL: Oh, you did? Okay. 13:45:09
`11 MR. GUTMAN: Thanks, David.
`12 BY MR. GUTMAN:
`13 Q. You have a nice picture in one of your
`14 reports.
`15 Well, let me ask you this -- oh, yeah. 13:45:36
`16 Here it is. If you pick up Exhibit 2 and go to
`17 page 11, you see figure 3 there.
`18 A. Yes.
`19 Q. That's a representative diagram of an
`20 antibody that has both intramolecular and 13:45:51
`21 intermolecular disulfide bonds, correct?
`22 A. Correct.
`23 Q. And there are two intermolecular
`24 disulfide bonds that bind the two heavy chains
`25 that make up that antibody, correct? 13:46:08
`Page 148
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`1 A. Correct.
`2 Q. -- assay.
`3 Now, are you familiar with what I'll
`4 refer to as a main peak?
`5 A. Yes. I'm -- 13:43:42
`6 Q. And what's the main peak in an nrCE-SDS
`7 assay?
`8 A. The main peak is defined as the
`9 molecular weight -- or the -- the material that
`10 has the expected full molecular weight. That's 13:43:59
`11 a main peak.
`12 Q. And when you say the full molecular
`13 weight, that doesn't provide any information to
`14 you about whether one or more disulfide bonds
`15 have been reduced in the antibody that's being 13:44:18
`16 assayed that would still retain all of the
`17 heavy chain and light chains of the antibody,
`18 correct?
`19 MR. BERL: Objection.
`20 THE WITNESS: This method gives 13:44:33
`21 information about intermolecular disulfide
`22 reduction, but not about intracellular
`23 disulfide production. Here, other methods have
`24 to be used.
`25 13:44:52
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`Page 147
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`1 A. Correct.
`2 Q. Now, if only one of those disulfide
`3 bonds was reduced, one of those intermolecular
`4 disulfide bonds was reduced, that would
`5 co-migrate in the main peak of an nrCE-SDS 13:46:27
`6 assay with the antibody where both disulfide
`7 bonds existed, correct?
`8 A. This is correct.
`9 Q. So the nrCE-SDS assay cannot
`10 discriminate between an antibody that has all 13:46:47
`11 of its intermolecular disulfide bonds and an
`12 antibody that may have partial reduction of
`13 those intermolecular disulfide bonds --
`14 MR. BERL: Objection.
`15 BY MR. GUTMAN: 13:47:03
`16 Q. -- correct?
`17 MR. BERL: Objection. Mischaracterizes
`18 his testimony.
`19 THE WITNESS: It does not discriminate
`20 between -- that's true. You're correct. Yeah. 13:47:10
`21 BY MR. GUTMAN:
`22 Q. And within the main peak that has the
`23 appropriate molecular weight, it also cannot
`24 discriminate between an antibody where all of
`25 the intermolecular disulfide bonds are properly 13:47:35
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`1 THE WITNESS: Inventive? To my
`2 understanding, the inventive step was the use
`3 of sparging on the basis of the recognition
`4 that thioredoxin system is the root for the
`5 antibody reduction. 18:41:51
`6 MR. GUTMAN: I have no further
`7 questions.
`8 MR. BERL: No questions.
`9 VIDEO TECHNICIAN: Are we finished?
`10 Please stand by. 18:42:04
`11 We are off the record at 6:42 p.m. And
`12 this concludes today's testimony given by
`13 Hansjörg Hauser. The total number of media
`14 units used was six and will be retained by
`15 Veritext Legal Solutions. 18:42:20
`16 (Whereupon, at 6:42 p.m., the
`17 confidential videotaped deposition of
`18 HANSJÖRG HAUSER, Ph.D. was concluded.)
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`1 CERTIFICATE OF NOTARY PUBLIC
`2 I, CHRISTINA S. HOTSKO, the officer before
`3 whom the foregoing deposition was taken, do hereby
`4 certify that the witness whose testimony appears in
`5 the foregoing deposition was duly sworn by me; that
`6 the testimony of said witness was taken by me in
`7 stenotypy and thereafter reduced to typewriting under
`8 my direction; that said statement is a true record of
`9 the proceedings; that I am neither counsel for,
`10 related to, nor employed by any of the parties to the
`11 action in which this statement was taken; and,
`12 further, that I am not a relative or employee of any
`13 counsel or attorney employed by the parties hereto,
`14 nor financially or otherwise interested in the
`15 outcome of this action.
`16 Dated: October 14, 2019
`17
`18
`19 <%14615,Signature%>
`20 CHRISTINA S. HOTSKO
`21 Notary Public in and for the
`22 District of Columbia
`23
`24 My commission expires:
`25 November 14, 2021
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`Page 294
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`Page 296
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`1 2 3 4 5 6 7 8
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` I, HANSJÖRG HAUSER, Ph.D.,, do hereby declare
`9 under penalty of perjury that I have read the foregoing
`10 transcript of my deposition; that I have made such
`11 corrections as noted herein, in ink, initialed by me, or
`12 attached hereto; that my testimony as contained herein,
`13 as corrected, is true and correct.
`14 EXECUTED this _____ day of ___________________,
`15 ______, at ________________________, __________________.
`16 (City) (State)
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`21 _____________________________________
`22 HANSJÖRG HAUSER, Ph.D.,
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`Page 295
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`Veritext Legal Solutions
`800-826-0277
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`75 (Pages 294 - 296)
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