John E. Flaherty 

Jonathan M.H. Short 

MCCARTER & ENGLISH, LLP 

Four Gateway Center 

1 00 Mulberry Street 

Newark, New Jersey 07102 

(973) 622-4444 

Attorneys for Plaintiffs/CountercliamDefendants ASTRAZENECA AB, 

AKTIEBOAGET HASSEL, 

ASTRAZENECA LP, 

KBI INC., and KBI-E INC. 

Of Counsel: 

Henry J. Renk 

Bruce C. Haas 

Colleen Tracy 

Joshua I. Rothman 

FITZPATRICK, CELLA, HARPER & 

SCINTO 

1290 A venue of the Americas 

New York, New York 10104-3800 

(212) 218-2100 

Einar Stole 

COVINGTON & BURLING LLP 

1201 Pennsylvania Avenue, NW 

Washington, DC 20004-2401 

(202) 662-6000 

UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF NEW JERSEY 

ASTRAZENECA AB, AKTIEBOLAGET 

HASSLE, ASTRAZENECA LP, KBI INC. 

and KBI-E INC., 

Plaintiffs and 

Counterclaim-Defendants, 

v. 

HANMI USA, INC., HANMI 

PHARMACEUTICAL CO., LTD., HANMI 

FINE CHEMICAL CO., LTD. and HANMI 

HOLDINGS CO., LTD., 

Defendants and 

Counterclaim-Plaintiffs. 

Civil Action No. 3:11-CV-00760-JAP-TJB 

Judge Joel A. Pisano 

Magistrate Judge Tonianne J. Bongiovanni 

FILED UNDER SEAL 

DECLARATION OF JESSICA L. PAREZO IN SUPPORT OF PLAINTIFFS' 

OPPOSITIONS TO DEFENDANTS' MOTIONS FOR 

SUMMARY JUDGMENT NOS. 2-4 

I, JESSICA L. P AREZO, hereby declare as follows: 

Case 3:11-cv-00760-JAP-TJB Document 159 Filed 12/03/11 Page 1 of 3 PageID: 5944
1. I am an associate at the law firm of Covington & Burling LLP, 1201 Pennsylvania 

Avenue, NW, Washington, DC 20004, counsel for Plaintiffs, in connection with the present 

action. 

2. I make this Declaration on my personal knowledge in support of Plaintiffs' 

Oppositions to Defendants' Motions for Summary Judgment Nos. 2-4. 

3. Attached as Exhibit A is a true and correct copy ofUS Patent 5,877,192. 

4. Attached as Exhibit B is a true and correct copy of US Patent 5,714,504. 

5. Attached as Exhibit Cis a true and correct copy of US Patent 5,693,818. 

6. Attached as Exhibit D is a true and correct copy of WO 94/279988. 

7. Attached as Exhibit E is a true and correct copy of US Patent Application Publication 

2007/0093533 AI. 

8. Attached as Exhibit F is a true and correct copy of "Patents Involved in S/J 2," an 

illustration by Lawrence Goffney showing the relationships between the documents in the '192 

Patent family. 

9. Attached as Exhibit G is a true and correct copy of a Table prepared by Stephen 

Davies showing a comparison of the disclosures of the '504 Patent, the '818 Patent and the 

Swedish '830 Application. 

10. Attached as Exhibit His a true and correct copy of Defendants' Initial Noninfringement and Invalidity Contentions Pursuant to L. Pat. R. 3.6, dated May 25, 2011. 

11. Attached as Exhibit I is a true and correct copy of Swedish Priority Application 

9301830. 

12. Attached as Exhibit J is a true and correct copy ofthe Department of Commerce, 

Patent and Trademark Office Revision of the Materiality to Patentability Standard for the 

2 

Case 3:11-cv-00760-JAP-TJB Document 159 Filed 12/03/11 Page 2 of 3 PageID: 5945
Duty to Disclose Information in Patent Applications, Federal Register I Vol. 76, No. 140 I 

Thursday, July 21, 2011. 

13. Attached as Exhibit K is a true and correct copy of AstraZeneca AB. v. Dr. Reddy's 

Laboratories, Ltd., Civ. A. No. 05-5553 (JAP), 2010 WL 1981790 (D.N.J. May 18, 2010) 

(Pisano, J.). 

14. Attached as Exhibit Lis a true and correct copy of DE 4 035 455. 

15. Attached as Exhibit M is a true and correct copy ofD.I. 121, a letter by Hanmi to the 

Court, dated October 19, 2011. 

16. Attached as Exhibit N is a true and correct copy ofD.I. 92, Joint Claim Construction 

and Pre hearing Statement, dated Sept. 14, 2011. 

I declare under penalty of perjury that the foreg 

Jess caL. Parezo 

Dated: December 2, 2011 

3 

Case 3:11-cv-00760-JAP-TJB Document 159 Filed 12/03/11 Page 3 of 3 PageID: 5946