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`IN THE UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`TAMPA DIVISION
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`VENN THERAPEUTICS,
` Plaintiff,
`vs.
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`CORBUS PHARMACEUTICALS
`HOLDINGS, INC.
`
` Defendant.
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`
`
` Case No.
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`
`
`COMPLAINT AND DEMAND FOR A JURY TRIAL
`PRELIMINARY AND PERMANENT INJUNCTIVE REQUESTED
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`Plaintiff Venn Therapeutics sues Corbus Pharmaceuticals, Inc. and alleges as
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`follows:
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`Introduction
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`1.
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`Plaintiff Venn Therapeutics (“Venn”) is a pharmaceutical company that
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`develops therapies for cancer and other diseases.
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`2.
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`In the Fall of 2020, Venn entered discussions with Defendant Corbus
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`Pharmaceuticals, Inc. (“Corbus”) regarding a potential partnership or acquisition.
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`During these discussions, Venn shared with Corbus trade secrets and other proprietary
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`information concerning two promising immunotherapy programs it was developing—
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`one for cancer, the other for fibrosis. It did so subject to a non-disclosure agreement
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`that prohibited Corbus from using Venn’s confidential information for any purpose
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`other than its discussions with Venn.
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`3.
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`After combing through Venn’s proprietary information for months,
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`Corbus told Venn it was not interested in moving forward with any partnership or
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`acquisition. However, within weeks of cutting off ties with Venn, Corbus began using
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`Venn’s trade secrets and other proprietary information to develop competing
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`immunotherapy programs for cancer and fibrosis.
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`4.
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`Venn brings this case to stop Corbus’ improper use of its trade secrets and
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`to hold Corbus accountable for its misconduct.
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`Parties
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`5.
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`Venn is a limited liability company organized under the laws of Ohio
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`with its principal place of business in Tampa, Florida.
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`6.
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`Corbus is a corporation organized under the laws of Delaware with its
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`principal place of business in Norwood, Massachusetts.
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`Jurisdiction and Venue
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`7.
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`This Court has federal question jurisdiction over this action under the
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`Defend Trade Secrets Act of 2016, 18 U.S.C. § 1831, et seq., pursuant to 28 U.S.C. §
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`1331.
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`8.
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`This Court has supplemental jurisdiction over the state law claims under
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`28 U.S.C. § 1367 because the state law claims are related to the claim in this action
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`within the Court’s subject matter jurisdiction and they form part of the same case or
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`controversy under Article III of the United States Constitution.
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`2
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`9.
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`In addition, this Court has subject matter jurisdiction under 28 U.S.C. §
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`1332 because the parties are citizens of different states and the amount in controversy
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`is greater than $75,000.
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`10. This Court has personal jurisdiction over Corbus because Corbus does
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`business in Florida, regularly conducts business within this state and district, and
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`negotiated with and took actions that harmed Venn, which is headquartered in this
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`District in Florida, and because the information and other property and rights at issue
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`are situated within this District. Corbus purposefully availed itself of this forum by,
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`among other things, conducting business within Florida; conducting negotiations with
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`and causing harm to Venn, which is headquartered in Florida; conducting those
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`negotiations through its head of business development, Dylan Wenke, who was
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`located in Florida throughout the majority of the negotiations; negotiating for Venn’s
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`information and property rights which are situated in Florida; and misappropriating
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`Venn’s trade secrets and confidential information which are situated in Florida.
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`11. This Court’s exercise of personal jurisdiction over Corbus is consistent
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`with the Constitutions of the United States and the State of Florida.
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`12. Venue is proper in the Middle District of Florida pursuant to 28 U.S.C.
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`§1391(b)(2) because a substantial part of the events or omissions giving rise to the
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`claims occurred in this District. Venn is headquartered in this District, and Venn’s
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`information and property rights at issue are situated within this District. In addition,
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`Dylan Wenke, head of business development at Corbus and one of the primary points
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`3
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`of contact during discussions between Venn and Corbus, was located in this District
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`while the majority of the discussions between Venn and Corbus occurred.
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`Facts
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`I.
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`Venn developed confidential and trade secret information regarding its
`immunotherapy programs based on antibodies VTX-001 and VTX-002.
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`13.
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`In April 2018, Venn licensed rights to a monoclonal antibody from the
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`University of California. Venn gave that antibody the code-name VTX-001.
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`integrin αvβ8. Integrin αvβ8 plays a key role in tumor cell growth.
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`14. VTX-001 inhibits cancer growth by inhibiting a cell receptor called
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`15. From April 2018 through the present, Venn has had exclusive rights to
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`develop VTX-001 for commercial purposes.
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`16.
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`Since it licensed VTX-001, Venn has spent over three years and millions
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`of dollars developing a promising immunotherapy for cancer based on VTX-001.
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`17. During Venn’s development process, Venn conducted numerous
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`experiments and made many strategic decisions about how
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`to make
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`its
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`immunotherapy program based on VTX-001 successful.
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`18. One important aspect of drug development is effectiveness, i.e., how
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`potent the drug is at treating the target disease. Venn performed numerous
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`experiments testing the effectiveness of VTX-001 at inhibiting integrin αvβ8. The
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`results showed that VTX-001 was highly effective.
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`19. A second critical component of drug development is safety. Many
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`potential drugs that exhibit strong potency fail because they are also unsafe to use.
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`4
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`Venn performed numerous experiments testing the safety of VTX-001, including
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`animal testing. The results showed that VTX-001 was safe, even at high
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`concentrations.
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`20. A third important part of drug development is developing parameters for
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`the design, manufacture, and administration of the drug, particularly at a large scale.
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`Identifying these parameters is commonly known as “Chemistry, Manufacturing, and
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`Controls,” or “CMC.” Through a laborious CMC process, Venn identified parameters
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`for the design, manufacture, and administration of an immunotherapy based on VTX-
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`001 under which it could be manufactured and administered reliably at scale.
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`21.
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`In addition, Venn designed a detailed protocol for Phase I clinical trials
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`of an immunotherapy based on VTX-001. Phase I clinical trials are the first phase of
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`human testing and a critical stage of the drug development process.
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`22.
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`Separate from its VTX-001 cancer program, Venn also was developing
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`an immunotherapy for fibrosis based on a molecule code-named VTX-002. Fibrosis
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`is a pathological wound healing process that results in scarring and can disrupt organ
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`functionality.
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`23. Like VTX-001, VTX-002 is a monoclonal antibody that binds to integrin
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`cell receptors. Unlike VTX-001, however, VTX-002 targeted two integrins, not just
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`one. VTX-002 targeted both integrin αvβ6 and integrin αvβ8.
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`24. Venn’s strategy of targeting both integrins with a single antibody was
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`novel, and the result of Venn’s scientific and creative thinking. Until the Spring of
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`2021 (when, as alleged below, Corbus began developing a similar fibrosis program by
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`5
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`improperly using Venn’s proprietary information), Venn was the only company with
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`a fibrosis program designed to target both of these integrins with the same antibody.
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`Thus, Venn had developed confidential and proprietary information regarding both its
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`VTX-001 cancer program and its VTX-002 fibrosis program.
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`II. Venn planned to acquire exclusive rights to a child molecule of VTX-001 for
`its cancer immunotherapy program.
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`25.
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`In drug development, it is common to create new molecules by making
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`small changes to the chemical structure of existing molecules with desirable
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`pharmacological properties. The purpose of this is to further improve the existing
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`molecule’s desirable pharmacological properties. A new molecule created in this way
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`is called the “child” of the existing molecule (the “parent”).
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`26. After scientists at the University of California developed VTX-001 and
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`the University licensed VTX-001 to Venn, those scientists made small changes to VTX-
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`001’s chemical structure to create a child molecule of VTX-001. The child molecule
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`is an antibody very similar to VTX-001, but preliminary studies suggested that it was
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`potentially even more potent at inhibiting integrin αvβ8.
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`27. The University of California informed Venn about the development of
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`the child molecule. It had performed relatively little testing on the child molecule.
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`However, based on the similarities between the child molecule and VTX-001 (its
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`parent), Venn expected that the child molecule would be a very promising
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`immunotherapy lead. Because VTX-001 and the child molecule had very similar
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`structures, there was a high likelihood that they shared pharmacological attributes and
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`6
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`would behave in similar ways under similar conditions. Indeed, that is why scientists
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`and companies develop child molecules—because they expect them to behave
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`similarly to their parent.
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`28. As described above, Venn had performed extensive testing on VTX-001,
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`which established that VTX-001 was extremely promising. Therefore, the child
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`molecule’s very similar structure suggested that the child molecule would behave
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`similarly to VTX-001 and would share the same positive pharmacological
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`characteristics.
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`29.
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`In addition, there was a high likelihood that the same steps that were
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`successful in developing VTX-001 would be successful in developing the child
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`molecule. Therefore, Venn expected that it would be able to make use of the work it
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`had done on VTX-001 to develop an immunotherapy based on the child molecule
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`quickly and cost effectively.
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`30. Because Venn knew the child molecule was likely to be promising based
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`on the work it had done on VTX-001, Venn intended to license the child molecule
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`from the University of California and incorporate it into its immunotherapy program.
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`31. On March 11, 2020, Venn entered an exclusive negotiation agreement
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`with the University of California, according to which the University agreed to
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`negotiate exclusively with Venn until July 31, 2020 for the licensing of the derivative
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`molecule. The exclusive negotiations period was then extended to December 31, 2020.
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`Venn paid for the exclusive negotiating rights and the extension of the negotiating
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`period.
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`7
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`32. The exclusive negotiation agreement required Venn to obtain a certain
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`amount of funding to obtain the license. Venn was just shy of this funding requirement
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`in November 2020, and it hoped that an investment or partnership with another
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`pharmaceutical company would put it over the threshold.
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`33. Venn’s information about the child molecule of VTX-001, including that
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`a “child” molecule of VTX-001 that exhibited potentially even greater anti-integrin
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`activity than VTX-001 existed and Venn’s plans to license it, were Venn’s confidential
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`and trade secret information.
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`III. Venn’s confidential and trade secret information about its drug programs
`was valuable because it was secret.
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`34. Venn’s confidential and trade secret information about VTX-001, the
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`child molecule of VTX-001, and VTX-002 was extremely valuable. It showed that
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`Venn’s cancer immunotherapy and fibrosis programs were promising and had
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`potential to be developed into marketable, profitable drugs. Drug programs with this
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`potential have high economic value and are attractive to potential investors, partners,
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`and buyers.
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`35. Moreover, the value of Venn’s information was substantially derived
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`from its secrecy.
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`36. Venn’s proprietary information provided compelling evidence that VTX-
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`001 and VTX-002 could form the bases of promising, effective, and safe
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`immunotherapies. So long as that information was known only to Venn, Venn could
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`pursue such immunotherapies without competition. If the information became known
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`8
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`to other companies, however, those companies could use it to decide to license or
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`create antibodies that are similar to VTX-001 or VTX-002 and develop their own,
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`competing therapies based on such antibodies. Venn would then face direct
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`competition from similar programs.
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`37.
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`In addition, Venn’s proprietary information not only showed that
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`antibodies like VTX-001 could form the basis of a promising immunotherapy, but also
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`provided a roadmap showing how to develop such a therapy. For example, Venn spent
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`a substantial amount of time and money determining optimal design, manufacturing,
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`and administration conditions for an immunotherapy based on VTX-001. It also
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`developed a detailed protocol for conducting Phase I clinical trials. So long as that
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`information remained secret, only Venn could use it to advance a therapy based on
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`VTX-001 or a similar antibody into clinical trials. If it became known to competitors,
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`however, those competitors could use it for that same purpose too. This would
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`eliminate any competitive advantage that the information conferred on Venn.
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`38. Venn’s proprietary information about the child molecule of VTX-001 was
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`also valuable because it was secret. So long as that information was known only to
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`Venn, there was no risk that another company would attempt to license the child
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`molecule and develop a program that would compete with Venn’s. If a competitor
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`knew what Venn knew about the child molecule, that competitor could use that
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`information to license the child molecule and develop a competing program with it.
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`This would eliminate the competitive advantage that the information conferred on
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`Venn.
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`9
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`IV. Venn took reasonable measures to protect the secrecy of its confidential and
`trade secret information.
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`39. Because it was important to the value of Venn’s therapeutic programs
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`that the information about those programs remain confidential, Venn took affirmative
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`steps to preserve the secrecy of that information.
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`40. Venn’s physical facilities were locked at all times and required the use of
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`a trackable keycard for access.
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`41. The confidential and proprietary information concerning Venn’s drug
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`programs was stored in electronic data rooms accessible only through a password-
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`protected account that had been granted access.
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`42. Venn provided access to its electronic data rooms only on a need-to-know
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`basis and terminated access immediately when it was no longer needed.
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`43. Before granting access
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`to Venn’s confidential and proprietary
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`information, Venn required employees, contractors, and consultants to sign
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`confidentiality agreements in which they agreed not to copy, use, or disclose the
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`information for any purpose.
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`44. Venn regularly discussed confidentiality with its employees during team
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`meetings.
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`45. Venn granted access to its confidential and proprietary information to
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`third parties rarely and only on a need-to-know basis. Before Venn did so, it required
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`those third parties to sign strict confidentiality agreements prohibiting any copying,
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`use, or disclosure of the confidential and proprietary information.
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`10
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`V. Venn and Corbus entered a nondisclosure agreement.
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`46. Venn and Corbus were introduced in November 2020.
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`47. At the time Venn and Corbus were introduced, Corbus was focused
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`exclusively on drugs targeting the endocannabinoid system. It had never been
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`involved in developing a drug that targeted integrins.
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`48. After being introduced to Corbus, Venn sent Corbus a non-confidential
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`slide deck, which contained high-level, non-confidential information about Venn’s
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`drug programs. The purpose of Venn’s non-confidential slide deck was to provide
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`enough information to potential partners or investors to gauge whether they were
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`interested in learning more. If there was initial interest, then Venn would provide
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`additional, confidential information to the potential partner or investor confidentially
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`under a nondisclosure agreement, to allow the potential partner to conduct diligence.
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`This method of information-sharing is common in the pharmaceutical industry
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`because it facilitates due diligence while reducing unnecessary sharing of confidential
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`information with third parties.
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`49. After receiving Venn’s non-confidential slide deck, Corbus wanted to
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`learn more. Corbus sent Venn a Mutual Nondisclosure Agreement that Corbus had
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`prepared.
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`50. Venn executed the Mutual Nondisclosure Agreement as drafted by
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`Corbus on November 14, 2020, and sent the executed copy to Corbus for signature.
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`11
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`51. Corbus executed the Agreement and returned the fully executed copy to
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`Venn on November 16, 2020. A true and correct copy of the fully executed Agreement
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`is attached as Exhibit A.
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`52.
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`In the Agreement, Corbus promised “not to use any Confidential
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`Information disclosed to it by the other party for its own use or for any purpose other
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`than to carry out discussions concerning, and the undertaking of, the Relationship.”
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`The “Relationship” was defined as “explor[ing] a possible business opportunity of
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`mutual interest regarding [Venn] and its business operations involving the
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`development of therapeutics targeting integrins for the treatment of human conditions
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`(the ‘Relationship’).”
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`53.
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`“Confidential Information” was defined as “any oral, written, graphic or
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`machine-readable information including, but not limited to, that which relates to
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`patents, patent applications, research, product plans, products, developments,
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`inventions, processes, designs, drawings, engineering, formulae, markets, regulatory
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`information, medical reports, clinical data and analysis, reagents, cell lines, biological
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`materials, chemical formulas, business plans, agreements with third parties, services,
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`customers, marketing or finances of the disclosing party, which Confidential
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`Information is designated in writing to be confidential or, if given orally or in other
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`intangible form, provided under circumstances reasonably indicating it is confidential
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`or proprietary or confirmed in writing as having been disclosed as confidential or
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`proprietary within a reasonable time (not to exceed thirty (30) days) after the oral
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`disclosure.”
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`12
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`54. Corbus also promised not to “disclose or permit disclosure of any
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`Confidential Information of the other party to third parties or to employees of the party
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`receiving Confidential Information, other than directors, officers, employees,
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`consultants and agents who are required to have the information in order to carry out
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`the discussions regarding the Relationship and who are bound by confidentiality
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`agreements” and that it would “take all reasonable measures to protect the secrecy of
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`and avoid disclosure or use of Confidential Information of the other party in order to
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`prevent it from falling into the public domain or the possession of persons other than
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`those persons authorized under this Agreement to have any such information.”
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`55. The Agreement also provided: “Any materials or documents that have
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`been furnished by one party to the other in connection with the Relationship shall be
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`promptly returned by the receiving party, accompanied by all copies of such
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`documentation, within ten (10) days after [] the Relationship has been rejected or
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`concluded.”
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`56.
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`In the Agreement, Corbus agreed that “monetary damages would be
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`inadequate to compensate the disclosing party for any breach by the receiving party”
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`and agreed and acknowledged that any “violation or threatened violation would cause
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`irreparable injury to the disclosing party and that, in addition to any other remedies
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`that may be available, in law, in equity or otherwise, the disclosing party shall be
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`entitled to obtain injunctive relief against the threatened breach of this Agreement or
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`the continuation of any such breach by the receiving party, without the necessity of
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`proving actual damages.”
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`13
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`57. The Agreement also provides: “This agreement and all acts and
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`transactions pursuant hereto and the rights and obligations of the parties hereto shall
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`be governed, construed and interpreted in accordance with the laws of the
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`Commonwealth of Massachusetts, without giving effect to its principles of conflicts of
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`law.”
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`VI. Venn shared its confidential and trade secret information with Corbus
`under the nondisclosure agreement.
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`58. Once Corbus had signed the Agreement, Venn provided Corbus detailed
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`confidential and trade secret information about its drug development programs for the
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`purpose of exploring the possible business opportunity identified above.
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`59. This included granting Corbus access to a confidential electronic data
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`room containing information about Venn’s drug programs. Venn granted access to
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`Corbus employees and agents on a need-to-know basis, upon Corbus’ request. In total,
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`Corbus requested access for, and Venn gave access to, over 25 Corbus employees and
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`agents.
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`60. The confidential data room that Corbus had access to contained Venn’s
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`confidential and proprietary data, reports, and analyses from its work developing
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`VTX-001 and VTX-002, in addition to other confidential and proprietary documents
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`regarding its drug programs.
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`61. Venn also arranged for its expert consultants to give Corbus several
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`presentations about Venn’s drug programs. In these presentations, Venn’s consultants
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`14
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`walked Corbus through various aspects of Venn’s programs in detail, including
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`effectiveness, safety, and CMC.
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`62.
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`In addition, Venn disclosed to Corbus the existence of the child antibody
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`of VTX-001, its expectations that the child molecule would perform similarly to VTX-
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`001, and its plan to license the child molecule from the University of California.
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`63. Thus, during Corbus’ diligence, Venn provided Corbus with detailed
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`confidential and trade secret information about its drug programs. Venn designated
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`this information to be confidential in writing, and information given orally or in other
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`intangible form was provided under circumstances reasonably indicating it is
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`confidential or proprietary.
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`64. Venn provided all of the confidential and trade secret information to
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`Corbus in reliance upon Corbus’ promises in the Agreement to keep that information
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`strictly confidential and use it only for the potential business relationship between the
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`companies.
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`VI. Corbus used Venn’s confidential and trade secret information to pursue its
`own, competing drug programs.
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`65. Venn had shared its valuable confidential and trade secret information
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`with Corbus with the goal of entering into a business relationship, but Corbus used the
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`information it got from Venn for a different purpose. Rather than form a business
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`relationship with Venn, Corbus broke off negotiations with Venn and used Venn’s
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`confidential and trade secret information to develop its own, competing programs that
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`precisely mirror Venn’s programs.
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`15
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`66.
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`In February 2021, Venn and Corbus were finalizing negotiations
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`regarding an acquisition of Venn’s assets by Corbus. Corbus had sent Venn a term
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`sheet proposal for the acquisition, Venn and Corbus exchanged drafts back and forth,
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`and the parties had reached agreement on most of the core terms, including monetary
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`terms.
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`67. On Corbus’ side, the negotiations were carried out primarily by Dylan
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`Wenke, Corbus’ head of business development, and Yuval Cohen, Corbus’ Chief
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`Executive Officer.
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`68. During the negotiation process, Corbus consistently represented to Venn
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`that it was excited about the deal, that it intended to move forward with the deal, and
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`that it was committed to moving quickly. As just one example, Corbus’ CEO wrote
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`to Venn in an email that “We’re really excited about the possibility of advancing this
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`platform” and that “We’re committed to moving quickly from our side.”
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`69. On February 24, however, Corbus abruptly terminated the negotiations.
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`Corbus did not offer any explanation besides that Corbus “need[ed] more time to
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`conduct additional work” and that “it wouldn’t be right for us to hold you back from
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`moving forward with other potential partners.”
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`70. Venn was surprised. The parties had already reached agreement on core
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`terms. Corbus had repeatedly represented that it intended to move forward with the
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`deal. And Corbus provided no explanation—nothing discovered during diligence, or
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`anything else—for Corbus’ sudden change of heart.
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`16
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`71. The real reason that Corbus broke off negotiations, Venn later learned, is
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`that Corbus intended to develop its own, competing drug programs modeled off of
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`Venn’s programs and using Venn’s trade secrets, rather than acquire Venn’s assets.
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`Within two weeks of breaking off negotiations with Venn, Corbus reached out to the
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`University of California to license the child molecule of VTX-001 and develop its own
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`immunotherapy program with that antibody.
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`72. On March 10, the University of California informed Venn that another
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`company was interested in licensing the child antibody.
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`73. Venn was again surprised. Because very little testing of the molecule had
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`been done, there was nothing—other than Venn’s confidential information regarding
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`the parent, VTX-001—that would interest another company. Indeed, there was no
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`publicly available information that the child molecule even existed. And the only
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`other companies with knowledge of Venn’s confidential information had signed
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`contracts promising not to use that information for their own benefit.
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`74. The University of California requested that Venn submit a proposal to
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`license the child molecule by the end of March if it was interested in doing so. Venn
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`submitted a proposal.
`
`75. On April 7, the University of California rejected Venn’s proposal to
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`license the child antibody and indicated that it intended to negotiate with the other
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`company that had expressed interest.
`
`76. Venn later found out that company was Corbus, when Corbus issued a
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`press release on June 1 stating that it had licensed the child molecule from the
`
`17
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`
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`Case 8:21-cv-02716-JLB-TGW Document 1 Filed 11/18/21 Page 18 of 42 PageID 18
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`University of California and that it was planning to use it to develop an
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`immunotherapy to treat cancer by inhibiting integrin αvβ8 activation of TGF-β.
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`77. Corbus used Venn’s confidential and trade secret information about
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`VTX-001 in deciding to license the child antibody.
`
`78. For example, Corbus only learned of the existence of the child molecule
`
`through Venn’s confidential information.
`
`79. As a second example, because Venn’s proprietary information provided
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`evidence that VTX-001 was an extremely promising antibody for developing an
`
`immunotherapy, Corbus knew that the very similar child antibody would be similarly
`
`promising.
`
`80.
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`In addition, Venn’s confidential and trade secret information showed not
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`only that the child antibody was promising; it also showed how to develop the child
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`antibody into a promising immunotherapy program. Because of the similarity of the
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`antibodies, Corbus knew that it would be able to develop the child antibody quickly
`
`and efficiently with knowledge of the steps Venn took in developing VTX-001 that led
`
`to success.
`
`81.
`
`Indeed, Corbus would not even have known about the existence of the
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`child molecule if Venn had not disclosed to Corbus its confidential plans to license the
`
`child molecule and incorporate it into the cancer immunotherapy program.
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`82. Thus, when it decided to license the child antibody and pursue its own
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`immunotherapy program based on that antibody, Corbus knew that the child antibody
`
`was a promising candidate for a cancer immunotherapy, and that Corbus would be
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`18
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`
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`Case 8:21-cv-02716-JLB-TGW Document 1 Filed 11/18/21 Page 19 of 42 PageID 19
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`able to develop an immunotherapy based on the child antibody quickly and efficiently.
`
`Corbus had this knowledge—and indeed the knowledge that the child antibody
`
`existed—only because Venn shared its confidential and trade secret information with
`
`Corbus under the Agreement. And Corbus used this knowledge in its decision to
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`license and develop the child antibody.
`
`83.
`
`In addition, Corbus has used and is continuing to use Venn’s confidential
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`and trade secret information in developing its immunotherapy program based on the
`
`child antibody.
`
`84. For example, knowing which steps led to success in Venn’s development
`
`of VTX-001 allows Corbus to streamline its development of the child antibody because
`
`those same steps are likely to be successful for the very similar child antibody. Thus,
`
`Corbus is able to avoid spending much of the time and money that Venn did in
`
`developing VTX-001. This has and will shave substantial time and money off of
`
`Corbus’ development process.
`
`85.
`
`In addition to copying Venn’s cancer immunotherapy program, Corbus
`
`also copied Venn’s fibrosis program.
`
`antibody that targets both integrin αvβ6 and integrin αvβ8, and is now developing a
`
`86. After breaking off negotiations with Venn, Corbus acquired a different
`
`fibrosis treatment based on that antibody.
`
`87. Venn found out about Corbus’ new fibrosis program in the same June 1,
`
`2021, press release in which Corbus announced the launch of its cancer
`
`immunotherapy program. In that same press release, Corbus announced the launch
`
`19
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`
`
`Case 8:21-cv-02716-JLB-TGW Document 1 Filed 11/18/21 Page 20 of 42 PageID 20
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`of its fibrosis program with an antibody that targets both integrin αvβ6 and integrin
`αvβ8. The press release stated that “Corbus believes targeting both integrins at once
`
`is a rational approach to treating fibrotic diseases.”
`
`88. Corbus used Venn’s confidential and trade secret information regarding
`
`its fibrosis program in deciding to acquire this antibody and develop a fibrosis program
`
`around it.
`
`89. Corbus would not have understood the benefits of targeting both
`
`integrins with a single antibody if Venn had not shared confidential and trade secret
`
`information about its VTX-002 program with Corbus.
`
`90. Moreover, Corbus has used and is intending to continue using Venn’s
`
`confidential and trade secret information, including Venn’s strategies for development,
`
`in developing its new fibrosis program.
`
`VII. Corbus’ use of Venn’s confidential and trade secret information has caused
`and continues to cause Venn harm.
`
`91. Corbus’ use of Venn’s confidential trade secret information has caused
`
`significant harm to Venn.
`
`92. To begin, Venn was unable to license the child molecule that it intended
`
`to incorporate into its immunotherapy program because Corbus did so.
`
`93.
`
`In addition, Venn’s immunotherapy and fibrosis programs now face
`
`direct competition from Corbus’ mirror-image programs. This competition reduces
`
`the value of Venn’s programs.
`
`20
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`Case 8:21-cv-02716-JLB-TGW Document 1 Filed 11/18/21 Page 21 of 42 PageID 21
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`94. Moreo