Novo-Nordisk A/S v. Pfizer, Inc.
Exubera Patent Lawsuit:
Pfizer’s Answer

Jurisdiction and Venue

                  2.        Pfizer admits that this action purports to be one arising under the patent laws of the United States and purports to claim patent infringement under 35 U.S.C. §§ 271 and 281. Except as expressly admitted above, Pfizer denies the remaining allegations of this paragraph.

                  3.        Pfizer admits that this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338.

                  4.        Admitted

                  5.        Pfizer admits that venue is proper in this District under 28 U.S.C. § 1400b on the ground that it resides in this District as defined in 28 U.S.C. § 1391c.

Parties

                  6.        Pfizer is without knowledge or information sufficient to form a belief as to the truth ofparagraph 6 and, therefore, the allegations of paragraph 6 are denied.

                  7.        Admitted

The Patents

                  8.        Pfizer admits that Aradigm Corporation “Aradigm” is identified as the assignee of Reid M. Rubsamen and Lester John Lloyd on the face of United States Patent No. 5,672,581 the “581 patent”. Pfizer also admits that the ‘581 patent is entitled “Method of Administration of Insulin” and issued on September 30, 1997. Pfizer also admits that Exhibit A of the Complaint purports to be a copy of the ‘581 patent. Pfizer denies the remaining allegations of this paragraph.

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                  9.        Pfizer admits that Aradigm is identified as the assignee of Igor Gonda, Reid M. Rubsamen and Stephen J. Fan on the face of United States Patent No. 5,884,620 (the “620 patent”). Pfizer also admits that the ‘620 patent is entitled “Inhaled Insulin Dosage Control Delivery Enhanced by Controlling Total Inhaled Volume” and issued on March 23, 1999. Pfizer also admits that Exhibit B of the Complaint purports to be a copy of the ‘620 patent. Pfizer denies the remaining allegations of this paragraph.

                  10.        Pfizer admits that Aradigm is identified as the assignee of Igor Gonda, Reid M. Rubsamen and Stephen J. Farr on the face ofUnited States Patent No. 5,941,240 (the “240 patent“). Pfizer also admits that the ‘240 patent is entitled “Inhaled Insulin Dosage Control Delivery Enhanced by Controlling Total Inhaled Volume” and issued on August 24, 1999. Pfizer also admits that Exhibit C of the Complaint purports to be a copy of the ‘240 patent. Pfizer denies the remaining allegations of this paragraph.

                  11.        Pfizer admits that Aradigm is identified as the assignee of Igor Gonda, Reid M. Rubsamen and Stephen J. Fan on the face of United States Patent No. 6,167,880 (the “‘880 patent”). Pfizer also admits that the ‘880 patent is entitled “Inhaled Insulin Dosage Control Delivery Enhanced by Controlling Total Inhaled Volume” and issued on January 2, 2001. Pfizer also admits that Exhibit D of the Complaint purports to be a copy of the ‘880 patent. Pfizer denies the remaining allegations of this paragraph.

                  12.        Pfizer admits that Aradigm is identified as the assignee of Igor Gonda, Reid M. Rubsamen and Stephen J. Fan on the face of United States Patent No. 7,028,686 (the “‘686 patent”). Pfizer also admits that the ‘686 patent is entitled “Inhaled Insulin Dosage Control Delivery Enhanced by Controlling Total Inhaled Volume” and issued on April 18, 2006. Pfizer

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