Kyle Bass vs POZEN Inc. (POZN): Petition For Inter Partes Review

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Kyle Bass vs POZEN Inc. (POZN): Petition For Inter Partes Review – the latest one – we have lost count of how many he is up to but see the filing below.

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

COALITION FOR AFFORDABLE DRUGS VII LLC,

Petitioner,

v.

POZEN INC.,

Patent Owner.

IPR2015-01241

Patent 6,926,907

PETITION FOR INTER PARTES REVIEW

Kyle Bass vs POZEN – Introduction

The Coalition for Affordable Drugs VII LLC (“CFAD” or “Petitioner”) respectfully requests inter partes review of claims 1-23 of U.S. Patent No. 6,926,907 (“the ’907 Patent”) (Ex. 1001) in accordance with 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42.100 et seq. The ’907 Patent is assigned to Pozen Inc. II. Mandatory Notices Per 37 C.F.R. § 42.8

A. Real Party-In-Interest

Pursuant to 37 C.F.R. § 42.8(b)(1), CFAD certifies that Coalition For Affordable Drugs VII LLC; Hayman Credes Master Fund, L.P. (“Credes”); Hayman Orange Fund SPC – Portfolio A (“HOF”); Hayman Capital Master Fund, L.P. (“HCMF”); Hayman Capital Management, L.P. (“HCM”); Hayman Offshore Management, Inc. (“HOM”); Hayman Investments, L.L.C. (“HI”); nXn Partners, LLC (“nXnP”); IP Navigation Group, LLC (“IPNav”); J Kyle Bass; and Erich Spangenberg (collectively, “RPI”) are the real parties-in-interest. The RPI certify the following: CFAD is a wholly owned subsidiary of Credes. Credes is a limited partnership. HOF is a segregated portfolio company. HCMF is a limited partnership. HCM is the general partner and investment manager of Credes and HCMF. HCM is the investment manager of HOF. HOM is the administrative general partner of Credes and HCMF. HI is the general partner of HCM. J Kyle Bass is the sole member of HI and sole shareholder of HOM. CFAD, Credes, HOF, and HCMF act, directly or indirectly, through HCM as the general partner and/or investment manager of Credes, HOF, and HCMF. nXnP is a paid consultant to HCM. Erich Spangenberg is the Manager and majority member of nXnP. IPNav is a paid consultant to nXnP. Erich Spangenberg is the Manager and majority member of IPNav. Other than HCM and J Kyle Bass in his capacity as the Chief Investment Officer of HCM and nXnP and Erich Spangenberg in his capacity as the Manager/CEO of nXnP, no other person (including any investor, limited partner, or member or any other person in any of CFAD, Credes, HOF, HCMF, HCM, HOM, HI, nXnP, or IPNav) has authority to direct or control (i) the timing of, filing of, content of, or any decisions or other activities relating to this petition or (ii) any timing, future filings, content of, or any decisions or other activities relating to the future proceedings related to this petition. All of the costs associated with this petition are expected to be borne by HCM, CFAD, Credes, HOF, and/or HCMF.

B. Notice of Related Matters

Per 37 C.F.R. § 42.8(b)(2), CFAD is aware of the following judicial matters involving the ’907 Patent: (1) AstraZeneca AB v. Dr. Reddy’s Labs. Inc., 3:11-cv-02317 (D.N.J.); (2) AstraZeneca AB v. Dr. Reddy’s Labs., Inc., 3:13-cv-00091 (D.N.J.); (3) AstraZeneca AB v. Watson Labs., Inc.- Florida, 3:13-cv-03038 (D.N.J.); and (4) AstraZeneca AB v. Mylan Pharmas., 3:13-cv-04022 (D.N.J.). In addition, CFAD is aware of the following judicial and administrative matters involving patents related to the ’907 Patent: (1) Dr. Reddy’s Labs., Inc. v. Pozen Inc., IPR2015-00802 (P.T.A.B.); (2) Horizon Pharma, Inc. v. Actavis Labs. FL, Inc., 3:15-cv-03322 (D.N.J.); (3) Horizon Pharma, Inc. v. Dr. Reddy’s Labs., Inc., 3:15-cv-03324 (D.N.J.); (4) Horizon Pharma, Inc. v. Lupin Ltd., 3:15-cv-03326 (D.N.J.); and (5) Horizon Pharma, Inc., v. Mylan Pharmas., Inc. 3:15-cv-03327 (D.N.J.).

See full PDF below.

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