`
`
`
`Filed on behalf of: Sanofi Mature IP
`By:
`
`Daniel J. Minion
`dminion@venable.com
`(212) 218-2100
`
`Paper No. 116
`Date Filed: April 8, 2021
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`MYLAN LABORATORIES LIMITED
`Petitioner,
`
`v.
`
`SANOFI MATURE IP
`Patent Owner.
`________________
`
`Case IPR2016-00712
`U.S. Patent No. 8,927,592
` _________________
`
`PATENT OWNER’S MOTION TO EXPUNGE
`
`
`
`
`
`
`
`
`
`
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`
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`
`
`
`
`
`
`I.
`
`STATEMENT OF RELIEF REQUESTED
`
`Pursuant to the authorization granted by the Patent Trial and Appeal Board
`
`(“Board”) on April 7, 2021 and 37 C.F.R. § 42.56, Patent Owner Sanofi Mature IP
`
`(“Patent Owner” or “Sanofi”) submits this motion to expunge the previously sealed
`
`confidential versions of Exhibits 1042, 1043, 1044, 1054, 1065, 1068, 1069, 1070,
`
`1071, 1072, 1074, 1079, 2149, 2170, 2171, 2176, 2179, 2182, 2211, and 2261, and
`
`Papers 43, 53, 64, 72, 77, 81, 89, and 92 (collectively, “the Identified Exhibits and
`
`Papers”). If the Board does not expunge any of these materials from the record,
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`Sanofi requests that the sealed versions remain under seal.
`
`For the reasons set forth below, good cause exists for expunging each of the
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`Identified Exhibits and Papers. Sanofi has conferred with Petitioner concerning this
`
`motion and can represent that Petitioner does not plan to oppose the motion.
`
`The original Final Written Decision (“FWD”) in this proceeding was issued
`
`on September 21, 2017. (Paper 99). On February 5, 2019, the Court of Appeals for
`
`the Federal Circuit vacated the Board’s denial of Sanofi’s contingent motion to
`
`amend and remanded for further proceedings. (Paper 113). The Final Written
`
`Decision on Remand (“FWD on Remand”) was issued on October 22, 2019. (Paper
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`112). The Federal Circuit issued a Rule 36 affirmance on January 15, 2021 and the
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`mandate on February 23, 2021. The mandate was docketed on March 19, 2021.
`
`(Paper 115). Since the proceeding is now concluded, and the motion is timely,
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`
`
`1
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`
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`
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`Sanofi requests that the Board expunge the confidential Identified Exhibits and
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`Papers from the record in this proceeding.
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`II. LEGAL STANDARD
`
`“Confidential information that is subject to a protective order ordinarily would
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`become public 45 days after denial of a petition to institute a trial or 45 days after
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`final judgment in a trial.” Consolidated Trial Practice Guide 2019 at 21-22. “[A]fter
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`final judgment in a trial, a party may file a motion to expunge confidential
`
`information from the record.” C.F.R. § 42.56. “[C]onfidential information”
`
`protected from disclosure includes “trade secret or other confidential research,
`
`development, or commercial information.” 37 C.F.R. § 42.54(a)(7). To determine
`
`whether to expunge confidential information, the Board must “balance the needs of
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`the parties to submit confidential information with the public interest in maintaining
`
`a complete and understandable file history for public notice purposes.” Consolidated
`
`Trial Practice Guide 2019 at 22. Therefore, a party “seeking expungement of
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`material from the record must show good cause by demonstrating that any
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`information sought to be expunged constitutes confidential information, and that the
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`party’s interest in expunging it outweighs the public’s interest in maintaining a
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`complete and understandable history of this inter partes review.” Cook Group Inc.
`
`v. Boston Sci. Scimed, Inc., IPR2017-00133, Paper 75 (P.T.A.B. Mar. 4, 2021) at 2-
`
`
`
`2
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`
`
`
`
`3 (citing Atlanta Gas Light Co. v. Bennett Regulator Guards, Inc., IPR2013-00453,
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`Paper 97 (P.T.A.B. Apr. 15, 2015) at 2).
`
`III. THE IDENTIFIED EXHIBITS AND PAPERS SHOULD BE
`EXPUNGED FROM THE RECORD
`
`a. The Identified Exhibits and Papers Were Sealed Because They
`Contain Sanofi’s Confidential Information that Could Subject
`Sanofi to Harm If It Was Disclosed
`
`The Board granted Sanofi’s unopposed motion for entry of a protective order
`
`on February 10, 2017 (Paper 35), and the Stipulated Protective Order was filed on
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`February 15, 2017 (Paper 36). The parties filed various exhibits and papers under
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`seal pursuant to the protective order and motions to seal those documents. (Paper
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`24; Paper 45; Paper 54; Paper 62; Paper 65; Paper 74; Paper 76; Paper 83; Paper 88;
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`Paper 91; Paper 97). The Board granted the parties’ motions to seal on February 10,
`
`2017 (Paper 35) and September 26, 2017 (Paper 100).1 Sanofi therefore previously
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`demonstrated, and the Board agreed, that the Identified Exhibits and Papers contain
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`confidential information, and there was good cause to seal the confidential
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`information. (Paper 35; Paper 100). Sanofi seeks to maintain the confidentiality of
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`the Identified Exhibits and Papers because they discuss Sanofi’s sensitive,
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`confidential information that could cause harm to Sanofi if it was made publicly
`
`available. There are two categories of confidential information that Sanofi seeks to
`
`
`1 The only exception is the Board’s denial of Patent Owner’s request to redact one
`sentence of Exhibit 2258. (Paper 100 at 7-10).
`
`
`
`3
`
`
`
`
`
`protect—clinical research information and business and financial information
`
`relating to sales and marketing of Sanofi’s Jevtana® (cabazitaxel) product.
`
`Exhibits 1043, 1054, 2176, 2182, and 2211 and Papers 43 and 53 discuss
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`Sanofi’s confidential clinical research information regarding cabazitaxel or larotaxel
`
`(a compound investigated by Sanofi but not covered by the claims of the patent-at-
`
`issue). If the highly sensitive clinical research information contained in these
`
`exhibits and papers is made public, it could give direct competitors knowledge of
`
`Sanofi’s clinical research strategy and operations and cause competitive harm to
`
`Sanofi. A description of these exhibits and papers is set forth in the table below.
`
`Document
`
`Redacted
`Version
`(No.)
`
`Type of Confidential
`Information
`
`Exhibit 1043 – March 14,
`2017 Reply Declaration of
`Dr. Rahul Seth
`
`Yes
`
`Exhibit 1054 – Briefing
`Document for EOP2
`Meeting
`
`No
`
`Exhibit 2176 – December
`23, 2016 Declaration of Dr.
`Alton Oliver Sartor
`
`Yes
`
`Confidential clinical
`research information
`regarding cabazitaxel from
`Exhibit 2182
`
`Confidential regulatory
`submissions regarding
`clinical research of
`cabazitaxel
`
`Confidential clinical
`research information
`regarding cabazitaxel from
`Exhibits 2182 and 2211
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper 100
`
`Paper 100
`
`Paper 35
`
`
`
`4
`
`
`
`
`
`Document
`
`Exhibit 2182 – Minimum
`Information Required for
`Written Subject
`Information,
`XRP6258/EFC6193 (Oct.
`16, 2006)
`
`Redacted
`Version
`(No.)
`
`No
`
`Type of Confidential
`Information
`
`Confidential clinical
`research information
`regarding cabazitaxel,
`including clinical
`operations
`
`Exhibit 2211 – 2006-06-29
`Email with Meeting
`Minutes, Ann Staten, FDA
`to Linda Gustavson, Sanofi
`
`Yes
`
`Confidential regulatory
`correspondence regarding
`clinical research
`information for cabazitaxel
`and larotaxel
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper 35
`
`Paper 35;
`Paper 100
`(granting
`motion to
`seal
`redacted
`version)
`
`Paper 100
`
`Paper 43: Petitioner’s
`Opposition to Patent
`Owner’s Motion to Amend
`Under 37 C.F.R. § 42.121
`
`Paper 53: Patent Owner’s
`Reply in Support of the
`Contingent Motion to
`Amend
`
`Yes
`(Paper
`44)
`
`
`Yes
`(Paper
`52)
`
`
`
`
`Confidential clinical
`research information
`regarding cabazitaxel from
`Exhibit 2182
`
`Confidential clinical
`research information
`regarding cabazitaxel from
`Exhibit 2182
`
`Paper
`1002
`
`
`2 The Board recognized that Sanofi sought to seal “portions of the MTA Reply that
`discuss sealed Exhibit 2182,” and noted that “the MTA Reply has been redacted so
`that the thrust of the underlying evidence can still be reasonably discerned,” in
`determining that Sanofi’s contested motion to seal Exhibit 2182 was granted.
`(Paper 100 at 7-8). In view of the Board’s discussion of Paper 53 (redacted
`because it referred to Exhibit 2182) and denial of only the request to redact one
`sentence of Exhibit 2258, Sanofi understands that the Board also sealed Paper 53.
`
`
`
`5
`
`
`
`
`
`Exhibits 1042, 1044, 1065, 1068 – 1072, 1074, 1079, 2149, 2170, 2171,
`
`2179, and 2261, and Papers 64, 72, 77, 81, 89, and 92 contain Sanofi’s highly
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`sensitive business and financial information relating to sales and marketing of
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`Sanofi’s Jevtana® (cabazitaxel) product. If the highly sensitive business and
`
`financial information contained in these documents is made public, it could cause
`
`competitive harm to Sanofi by providing direct competitors knowledge of Sanofi’s
`
`business strategies, marketing operations, and financial operations. A description
`
`of these exhibits and papers is set forth in the table below.
`
`Document
`
`Exhibit 1042 – March
`6, 2017 Transcript of
`the Deposition of
`Michael E. Tate
`
`Redacted
`Version
`(No.)
`
`Yes
`
`Type of Confidential
`Information
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana®
`referring to Exhibits 2149,
`2170–2171, and 2179
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper
`100
`
`Exhibit 1044 – March
`14, 2017 Declaration of
`Mr. Robert McSorley
`
`Yes
`
`Paper
`100
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1065, 1068-1072,
`1074, 1079, 2149, 2170–2171,
`and 2179
`
`
`
`6
`
`
`
`Document
`
`Redacted
`Version
`(No.)
`
`Type of Confidential
`Information
`
`No
`
`Yes
`
`
`No
`
`No
`
`Exhibits 1065, 1068 –
`1072, 1074, 1079 –
`Jevtana® Marketing
`Documents
`
`Exhibit 2149 –
`December 23, 2016
`Declaration of Mr.
`Michael E. Tate
`
`Exhibit 2170 – Market
`Share with Docetaxel in
`Prior Treatment,
`BrandImpact by
`AlphaImpact Rx (June
`2016)
`
`Exhibit 2171 – Monthly
`Jevtana Prostate
`Cancer Treatment
`Report: August 2014
`Results, BrandImpact
`by AlphaImpact Rx and
`Symphony Health
`Solutions (September
`2014)
`
`
`
`
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper
`100
`
`Paper 35
`
`Paper 35
`
`Highly sensitive and
`confidential internal
`documents concerning sales
`and market share for Jevtana®
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 2170–2171 and 2179
`
`Highly sensitive and
`confidential internal document
`concerning sales and market
`share for Jevtana®
`
`Highly sensitive and
`confidential internal document
`concerning sales and market
`share for Jevtana®
`
`Paper 35
`
`7
`
`
`
`
`
`
`
`Document
`
`Exhibit 2179 –
`Underlying data for
`Market Share with
`Docetaxel in Prior
`Treatment,
`BrandImpact by
`AlphaImpact Rx (June
`2016)
`
`Exhibit 2261 – April
`19, 2017 Transcript of
`the Deposition of
`Robert McSorley
`
`Redacted
`Version
`(No.)
`
`No
`
`Yes
`
`
`Paper 64: Petitioner
`Mylan Laboratories
`Limited’s Motion to
`Exclude Evidence 37
`C.F.R. §42.64
`
`Yes
`(Paper
`68)
`
`
`Paper 72: Patent
`Owner’s Opposition to
`Petitioner’s Motion to
`Exclude
`
`Yes
`(Paper
`73)
`
`
`Type of Confidential
`Information
`
`Highly sensitive and
`confidential internal document
`concerning sales and market
`share for Jevtana®
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper 35
`
`Paper
`100
`
`Paper
`100
`
`Paper
`100
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana®
`referring to Exhibits 1044 and
`1065
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1042 and 2261
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1042, 2149, 2170–
`2171, 2179 and 2261
`
`8
`
`
`
`
`
`
`
`Document
`
`Redacted
`Version
`(No.)
`
`Type of Confidential
`Information
`
`Paper 77: Petitioner’s
`Opposition to Patent
`Owner’s Motion to
`Exclude Exhibits 1089-
`1090
`
`Yes
`(Paper
`78)
`
`
`Paper 81: Patent
`Owner’s Motion for
`Observations on Cross-
`Examination of Mr.
`Robert McSorley
`
`Yes
`(Paper
`82)
`(Public
`Redacted
`Version)
`
`
`Paper 89: Petitioner’s
`Reply in Support of
`Motion to Exclude
`(Paper 64)
`
`Yes
`(Paper
`95)
`
`
`Paper 92: Petitioner
`Mylan Laboratories
`Limited’s Response to
`Patent Owner’s Motion
`for Observations on the
`Cross-Examination of
`Mr. Robert McSorley
`
`Yes
`(Paper
`94)
`
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1042 and 1044
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1044 and 2261
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1042 and Papers 64
`and 72
`
`Highly sensitive and
`confidential business and
`financial information
`concerning sales and
`marketing of Jevtana® citing
`Exhibits 1044, 1065, 1068,
`1071, and 2261
`
`Decision
`Granting
`Motion
`to Seal
`
`Paper
`100
`
`Paper
`100
`
`Paper
`100
`
`Paper
`100
`
`9
`
`
`
`
`
`b. Sealed Versions of Documents Not Cited in the Final Written
`Decision or Final Written Decision on Remand Should Be
`Expunged
`
`None of Exhibits 2170, 2171, 2179, 2211, 2261, 1054, 1065, 1068-1072,
`
`1074, or 1079 or Papers 64, 72, 77, 81, 89, or 92 were relied upon by the Board in
`
`the FWD or FWD on Remand. Furthermore, minimally redacted versions of
`
`Exhibits 2211 and 2261 and Papers 64 (Paper 68 public version), 72 (Paper 73 public
`
`version), 77 (Paper 78 public version), 81 (Paper 82 public version), 89 (Paper 95
`
`public version), and 92 (Paper 94 public version) were filed on the public docket.
`
`Therefore, accommodating Sanofi’s interest in maintaining its confidential
`
`information by expunging the sealed versions of these documents (supra Section
`
`III.a) would have no impact on the public’s interest in maintaining a complete and
`
`understandable file history or the public’s need to understand the Board’s
`
`patentability determinations. See Cook Group Inc., IPR2017-00133, Paper 75 at 3
`
`(granting Patent Owner’s motion to expunge where the Board did not rely upon the
`
`exhibit or the confidential information contained in the exhibit in any decision or
`
`order).
`
`c. Sealed Versions of Documents Cited in the Final Written Decision
`and/or Final Written Decision on Remand Where the Confidential
`Information Was Not Relied Upon Should Be Expunged
`
`Exhibits 1042, 1043, 1044, 2149, and 2176 were referenced in the FWD
`
`and/or FWD on Remand. However, minimally redacted public versions of each of
`
`
`
`10
`
`
`
`
`
`these documents have been filed, and the Board did not rely upon the confidential
`
`portions of these exhibits and papers in reaching its conclusions on patentability.
`
`(FWD at 16-17 n.14, 31-32, 34, 36, 38, 40-41, 44-48, 49 n.16, 50, 54, 56, 64-65, 72-
`
`80; FWD on Remand at 20, 22).
`
`Therefore, accommodating Sanofi’s interest in maintaining its confidential
`
`information by expunging the sealed versions of these documents (supra Section
`
`III.a) so that only the redacted, public versions remain in the record would have no
`
`(or at least minimal) impact on the public’s interest in maintaining a complete and
`
`understandable file history or the public’s need to understand the Board’s
`
`patentability determinations. See Eli Lilly and Co. v. Teva Pharms Int’l GMBH,
`
`IPR2018-01422, Paper 80 (P.T.A.B. April 7, 2020) at 2-3 (granting Patent Owner’s
`
`motion to expunge where redacted versions of confidential documents satisfied the
`
`public’s interest in maintaining a complete record, and the Board did not cite
`
`confidential portions of the documents).
`
`d. Exhibit 2182 and Sealed Versions of Papers 43 and 53 Citing
`Exhibit 2182 Should Be Expunged
`
`Exhibit 2182 is the written subject information form provided by Sanofi to the
`
`investigators of the TROPIC study for further development of informed consent
`
`forms. (Paper 24 at 5-6; Paper 35 at 3-4; Paper 97 at 5-6; Paper 100 at 7-8). Exhibit
`
`2182 was the subject of a contested motion to seal that the Board granted because it
`
`contains confidential clinical research information regarding cabazitaxel that could
`
`
`
`11
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`
`
`
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`cause competitive harm to Sanofi by providing direct competitors with knowledge
`
`of Sanofi’s clinical research operations. (Paper 35 at 3-4; Paper 100 at 7-8).
`
`Paper 43 (Petitioner’s Opposition to Patent Owner’s Contingent Motion to
`
`Amend) and Paper 53 (Patent Owner's Reply ISO Contingent Motion to Amend)
`
`were filed under seal because they discuss information from Exhibit 2182.
`
`Minimally redacted public versions of Papers 43 (Paper 44) and 53 (Paper 52) were
`
`filed. The Board granted motions to seal Papers 43 and 53 for the same reason as
`
`Exhibit 2182 (Paper 100), and Sanofi’s interest in maintaining the confidentiality of
`
`these papers is the same as for Exhibit 2182.
`
`Exhibit 2182 is cited three times in the FWD on Remand. The first instance
`
`is merely identifying Mylan’s grounds for unpatentability. (Paper 112 at 6). In the
`
`second instance, the Board quotes part of a sentence from Exhibit 2182 that is
`
`duplicative of other public information of record in this proceeding regarding the
`
`TROPIC study: “The aim of this study is to determine whether [cabazitaxel] in
`
`combination with prednisone improves overall survival . . .” (Paper 112 at 24;
`
`compare Paper 22 at 12 (“These references merely stated that the primary endpoint
`
`of the TROPIC study is overall survival; in other words that the study is designed to
`
`determine whether cabazitaxel in combination with prednisone prolongs the life of
`
`mCRPC patients previously treated with docetaxel as compared to palliative
`
`mitoxantrone therapy.” (citing public Exhibits 1008, 1009)). Third, the Board notes
`
`
`
`12
`
`
`
`
`
`that Exhibit 2182 does not disclose the premedications recited in the amended claims
`
`of U.S. Patent No. 8,927,592 (“’592 patent”). (Paper 112 at 25).
`
`Any arguably substantive discussion of Exhibit 2182 was in the context of
`
`Petitioner’s allegations of public use. (Paper 112 at 23-25). The basis for the
`
`Board’s determination that Petitioner had not demonstrated invalidity of the
`
`amended claims of the ’592 patent for public use is readily discernable without
`
`reference to Exhibit 2182 itself. The Board found that Petitioner did not “develop”
`
`“or cite any evidence” to support the proposition that the invention was ready for
`
`patenting. (Paper 112 at 23). Nevertheless, the Board examined the evidence of
`
`record and found no evidence that the inventor had determined the invention would
`
`work for its intended purpose, including because the existence of the TROPIC study
`
`itself (in various public documents) was “strong evidence” that the determination
`
`had not yet been made by the inventor. (Id. at 24). Furthermore, the Board found
`
`no evidence of an enabling disclosure of the invention because the only reference
`
`disclosing the premedication steps of the amended claims was a publication dated
`
`after the TROPIC study was completed, and the other descriptions of the TROPIC
`
`study (including Exhibit 2182) did not disclose the premedications. (Id. at 24-25).
`
`Expunging Exhibit 2812 and Papers 43 and 53 that refer to it would not inhibit the
`
`public’s ability to understand the Board’s decisions or the record in this proceeding.
`
`
`
`13
`
`
`
`
`
`Thus, the public’s interest in knowing Sanofi’s confidential clinical research
`
`information is relatively low and is outweighed by Sanofi’s interest in keeping it
`
`confidential. See Nevro Corp. v. Boston Scientific Neuromodulation Corp.,
`
`IPR2017-01812, Paper 83 (P.T.A.B. Feb. 10, 2021) at 3-4 (granting the motion to
`
`expunge because the Board “did not rely upon confidential information contained in
`
`the majority of the Identified Documents” and “the Decision is written such that the
`
`public can understand the parties’ arguments and the bases for the Board’s
`
`determinations without access to the underlying confidential information.”).
`
`IV.
`
`IF THE BOARD DOES NOT EXPUNGE THE IDENTIFIED
`EXHIBITS AND PAPERS, THEY SHOULD REMAIN
`CONFIDENTIAL UNDER SEAL
`
`If the Board denies the motion to expunge the Identified Exhibits and Papers,
`
`Sanofi respectfully requests that the Board keep these documents under seal to
`
`maintain their confidentiality as the Board agreed to do in Ericsson Inc. v. Regents
`
`of the University of Minnesota, IPR 2017-01186, Paper 61 (P.T.A.B. Dec. 18, 2020)
`
`at 3. There, the motion to expunge was denied because confidential versions of
`
`documents subject to the motion provided bases for findings in the patentability
`
`decisions, but nevertheless the Board decided that it was “appropriate to retain the
`
`confidential versions of the identified documents under seal in the record.” Id. So
`
`here, because of Sanofi’s interest in maintaining the confidentiality of its sensitive
`
`clinical research and business and financial information (supra Section III.a), it
`
`
`
`14
`
`
`
`
`
`would be appropriate to keep the sealed versions of the Identified Exhibits and
`
`Papers under seal.
`
`V. CONCLUSION
`
`For the foregoing reasons, Sanofi respectfully requests that the Board expunge
`
`the sealed versions of Exhibits 1042, 1043, 1044, 1054, 1065, 1068, 1069, 1070,
`
`1071, 1072, 1074, 1079, 2149, 2170, 2171, 2176, 2179, 2182, 2211, and 2261, and
`
`Papers 43, 53, 64, 72, 77, 81, 89, and 92.
`
`Alternatively, if the Board is not inclined to grant the Motion to Expunge,
`
`Sanofi respectfully requests that the sealed versions be retained as confidential in the
`
`record.
`
`VI. REQUEST FOR CONFERENCE CALL WITH THE BOARD
`
`If the Board is not inclined to grant the present Motion, Sanofi requests a
`
`conference call with the Board to discuss any concerns prior to issuance of a decision
`
`on the Motion.
`
`Date: April 8, 2021
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/s/ Daniel J. Minion
`
`Daniel J. Minion (Reg. No.
`53,329)
`VENABLE LLP
`1270 Avenue of the Americas
`New York, NY 10104-3800
`Tel: (212) 218-2100
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`15
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e)(4), I certify that a copy of the foregoing
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`PATENT OWNER’S MOTION TO EXPUNGE was served on April 8, 2021 to
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`the following Counsel for Petitioner at the following e-mail addresses:
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`sparmelee@wsgr.com
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`mrosato@wsgr.com
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`jmills@wsgr.com
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`mreed@wsgr.com
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`nbrutocao@wsgr.com
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`wdevine@wsgr.com
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`Date: April 8, 2021
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`Respectfully submitted,
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`/s/ Daniel J. Minion
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`Daniel J. Minion (Reg. No.
`53,329)
`VENABLE LLP
`1270 Avenue of the Americas
`New York, NY 10104-3800
`Tel: (212) 218-2100
`
`
`16
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