The Board of Regents of the University of Texas System, the University of Texas System, and the University of Texas M.D. Anderson Cancer Center v. Gensetix, Inc.

ACCEPTED 15-25-00011-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/31/2025 4:58 PM No. 15-25-00011-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN FOR THE FIFTEENTH DISTRICT OF TEXAS 15th COURT OF APPEALS AUSTIN, TEXAS AT AUSTIN 10/31/2025 4:58:47 PM THE BOARD OF REGENTS OF THE UNIVERSITY OF TEXAS SYSTEM, CHRISTOPHER Clerk A. PRINE THE UNIVERSITY OF TEXAS SYSTEM, and THE UNIVERSITY OF TEXAS M.D. ANDERSON CANCER CENTER Appellants vs. GENSETIX, INC. Appellee Appealed from the District Court, 152nd Judicial District Harris County, Texas, The Honorable Robert Schaffer (Presiding) Cause No. 2021-73071 APPELLEE’S BRIEF IN SURREPLY REGARDING CURADEV* Anthony Buzbee Cabrach Connor Tex. Bar No. 24001820 Tex. Bar No. 24036390 Ryan Pigg Jennifer Tatum Lee Tex. Bar No. 24088227 Tex. Bar No. 24046950 THE BUZBEE LAW FIRM Sergio R. Dávila Travis Street, Suite 7500 Tex. Bar No. 24079795 Houston, TX 77002 CONNOR LEE & SHUMAKER PLLC (713) 223-5393 609 Castle Ridge Road, Suite 450 (512) 777-1254 ATTORNEYS FOR APPELLEE GENSETIX, INC.

(ORAL AGUMENT NOT REQUESTED)

*Curadev Pharma Pvt. Ltd. v. The Univ. of Tex. Sw. Med. Ctr., No. 15-25-00004-CV, 2025 Tex. App. LEXIS 6472 (Tex. App.—15th Dist. Aug. 21, 2025, pet. filed).

TABLE OF CONTENTS I. Curadev ..............................................................................................................................2 II. The trial court in Curadev ruled on undisputed facts. But the trial court in Gensetix did not, and that material distinction affects how the STANDARD OF REVIEW applies here. .........................................................................................................3 III. MDA’s 2017 Taking is wholly unaffected by Curadev .................................................5 IV. MDA’s 2020 Taking is distinguishable from Curadev ............................................................ 7 V. Neither Curadev nor any other case says that Takings lasting less than months are non-actionable.......................................................................................8 VI. MDA misreads Chief Justice Brister’s .........................................................................9 dissenting opinion in Curadev.

VII. Gensetix respectfully asks this Court to disregard unpreserved, untimely arguments raised in MDA’s Reply. .............................................................................11 XIII. Conclusion .......................................................................................................................12 CERTIFICATE OF COMPLIANCE ...........................................................................................16 i TABLE OF AUTHORITIES Cases BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002).......................... 3 Cedar Point Nursery v. Hassid, 594 U.S. 139 (2021) ............................................... 9, 10 City of Dallas v. VSC, LLC, 242 S.W.3d 584 (Tex. App.—Dallas 2008) rev’d on other grounds, 347 S.W.3d 231 (Tex. 2011) ............................................................................. 2 Curadev Pharma Pvt. Ltd. v. The Univ. of Tex. Sw. Med. Ctr., No. 15-25-00004-CV, 2025 Tex. App. LEXIS 6472 (Tex. App.—15th Dist. Aug. 21, 2025, pet. filed) .passim Fed. Land Bank of Houston v. United States, 168 F.Supp. 788 (Ct. Cl. 1958) ........... 10 First English Evangelical Lutheran Church of Glendale v. Los Angeles Cty., 482 U.S. 304 (1987) ....................................................................................................................... 9 Ford ex rel. Williams v. City of Lubbock, 76 S.W.3d 795 (Tex. App.—Amarillo 2002, no pet.) .................................................................................................................................. 5 Gen Servs. Comm’n v. Little-Tex Insulation Co., 39 S.W.3d 591 (Tex. 2001) ................... 2 Greater Houston Radiation Oncology v. Sadler Clinic Ass’n, PA, 384 S.W.3d 875 (Tex. App.—Beaumont 2012, pet. denied) .................................................................. 12 Hardy v. Chemetron Corp., 870 F.2d 1007 (5th Cir. 1989) ............................................... 8 Hartwell v. Lone Star, PCA, 528 S.W.3d 750 (Tex. App.—Texarkana 2017, pet. dism’d) 6 Hicks v. Tex. Health & Human Servs. Comm’n, No. 10-19-00256-CV, 2021 Tex. App. LEXIS 6612 (Tex. App.—Waco Aug. 11, 2021, no pet.) ................................................... 5 Houston R.E. Income Props. XV, Ltd. v. Waller Cty. Appraisal Dist., 123 S.W.3d 859 (Tex. App.—Houston [14th Dist.] 2003, no pet.) ........................................................ 11 In re LAF, No. 14-21-00046-CV, 2022 Tex. App. LEXIS 5532 (Tex. App.—Houston [14th Dist.] Aug. 4, 2022, no pet.) ............................................................................................ 6 Lexington Ins. Co. v. Daybreak Exp., Inc., 393 S.W.3d 242 (Tex. 2013) ...................... 8 MBP v. Bd. of Trustees of the Galveston Wharves, 297 S.W.3d 483 (Tex. App.—Houston [14th Dist.] 2009) ............................................................................................................ 2 ii Methodist Hosps. v. Tex. Workers’ Compensation Comm’n, 874 SW 2d 144 (Tex. App.— Austin 1994, no writ) ....................................................................................................... 6 Moore v. NY Cotton Exch., 270 U.S. 593 (1926) ............................................................. 8 Piazzola v. Watkins, 442 F.2d 284 (5th Cir. 1971) ........................................................ 10 Sefzik v. Mady Dev’t, LP, 231 S.W.3d 456 (Tex. App.—Dallas 2007, no pet.) ............. 11 SITQ EU, Inc. v. Reata Rests., Inc., 111 S.W.3d 638 (Tex. App.—Fort Worth 2003, pet. denied) ............................................................................................................................. 3 Smith v. Grace, 919 S.W.2d 673 (Tex. App.—Dallas 1996, writ denied)............................ 6 State v. Holland, 221 S.W.3d 639 (Tex. 2007). .................................................................. 2 State v. Volkswagen Aktiengesellschaft, 669 SW 3d 399 (Tex. 2023) .............................. 3 Tex. Dep't of Crim. Just. v. Rangel, 595 S.W.3d 198 (Tex. 2020) ..................................... 6 TRT Holdings, Inc. v. Ace Am. Ins. Co., No. 05-23-00868-CV, 2025 Tex. App. LEXIS 7407 (Tex. App.—Dallas Sep. 18, 2025, n.p.h.) .......................................................... 12 United States v. General Motors Corp., 323 U.S. 373 (1945) .................................. 9, 10 UV Logistics, LLC v. Patsfield, No. 01-20-00191-CV, 2022 Tex. App. LEXIS 2118 (Tex. App.—Houston [1st Dist.] Mar. 31, 2022, no pet.).......................................................... 6 Rules Tex. R. App. P. 33.1(a)(1)(A) ................................................................................................... 11 TEX. R. APP. P. 44.1(a) .................................................................................................................. 6 iii RECORD/BRIEF CITATIONS The brief cites the record and briefs in the following way

CR Clerk’s Record

SuppCR Supplemental Clerk’s Record

2SuppCR Second Supplemental Clerk’s Record

RR Transcript of March 11, 2022, hearing

OB Appellant’s Opening Brief

Reply Appellant’s Reply Brief iv Curadev is materially distinguishable. Here, the governmental party (MDA) used the ELEVENTH AMENDMENT to effect a multi-year Taking of Gensetix’s exclusive, primary right to commercialize its patents.

Table 1 (Abridged)1 Material Distinctions Between Gensetix and Curadev Gensetix Curadev Sovereign Power employed by Governmental Party ELEVENTH AMENDMENT None motion to dismiss Governmental Party’s Mental State and Conduct Bad Faith intent to interfere with Gensetix’s Good Faith right to sue intent to publish research findings Nature of the Property Conveyance Gov’t relinquished commercialization rights to Gov’t obtained Mirrow, who sold them to Gensetix information from Takeda Source of the Private Party’s Property Interest Statutory right to exclude granted by Promise Takeda Patent Office to inventors’ assignees made to Curadev in a contract Conflicting Evidence of Governmental Scienter MDA’s Exhibits 6-7 vs. None Mousa Declaration w/ 21 Exhibits Disputed Jurisdictional Facts (1) MDA’s 2017 side-deal was illicit (2) Gensetix’s 2017 patent suit was strong None (3) The 2019 clinical trials were commercial (4) MDA cooked up a pretext in 2020 Circumstances Extraordinary Common Inducements, lies, and calculated betrayal aided Study submitted a by abuse of ELEVENTH AMENDMENT few months early See Tab 1 for record citations and pincites to Curadev in support of Table 1.

For the reasons explained in this supplemental brief, the trial court did not err in finding MDA failed to carry its burden on its immunity plea.

I. Curadev This Court’s Divided Opinion (Takings). The Curadev Court was the first panel of this Court to examine the Texas Supreme Court’s holding in Self. 2025 Tex. App. LEXIS 6472 at **15-16, 35-37 (citing TxDOT v. Self, 690 S.W.3d 12 (Tex. 2024)). While the Curadev majority characterized TxDOT’s appropriation in Self as “exercising its eminent domain powers[] mistakenly[,]” Id. at **15, the dissenting opinion read Self as “say[ing] just the opposite[.]’” Id. at *36.

The Curadev majority relied on State v. Holland2, 2025 Tex. App. LEXIS 6472 at **12-15, but overlooked the Self Court’s express3 disapproval of subordinate courts reading the Little-Tex4 line of cases5 as imposing a specific intent requirement. The government cannot avoid liability “merely by asserting that [it] thought at the time of the taking that it” had a right to do so. Self, 690 S.W.3d at 29 (emphasis in original).

Of which Holland is a part. 221 S.W.3d at 642, 643-644. As is MBP v. Bd. of Trustees of the Galveston Wharves, 297 S.W.3d 483, 488-493 (Tex. App.—Houston [14th Dist.] 2009), a case MDA asks this Court to follow. (Reply at 31-32).

Factual Basis for Holding (UTSW’s means of acquisition).

The Curadev majority held dispositive that UTSW had “no knowledge[6] [that Curadev] had any rights that could be violated” if certain information were to be published. 2025 Tex. App. LEXIS 6472 at **15-16. That is the sole factual basis the Curadev majority relied on when it distinguished its opinion from Self’s holding. Id. Standard of Review. Curadev did not overturn Volkswagen or BMC Software7, nor does it alter the STANDARD OF REVIEW applicable in cases with disputed jurisdictional facts. 2025 Tex. App. LEXIS 6472.

II. The trial court in Curadev ruled on undisputed facts.

But the trial court in Gensetix did not, and that material distinction affects how the STANDARD OF REVIEW applies here.

Curadev’s BRIEF IN OPPOSITION to UTSW’s PLEA TO THE JURISDICTION filed in Dallas County reveals that, in that case, there were “no facts contradicting [Curadev’s] allegations” bearing on jurisdiction. Tab 2 (No. 15-25-00004, BRIEF OF APPELLANTS, Appendix, Tab 9, p.5). Curadev maintained that position in this Court. (No. 15-25-00004, APPELLANTS’

REPLY BRIEF at 2) Tab 3. Consequently, the Curadev panel characterized the relevant jurisdictional facts in that case as undisputed. 2025 Tex. App. LEXIS 6472 at **11-12.

The parties in Curadev agreed that UTSW obtained the trade secret chemical compound by entering an agreement with Takeda Pharmaceutical, and they agreed that UTSW continued to use the information after the Takeda agreement expired, against the express terms of the Takeda agreement. 2025 Tex. App. LEXIS 6472 at **11-12.

Unlike the parties in Curadev, the parties here sharply dispute key jurisdictional facts. First, whether MDA’s illicit side-deal with Diakonos motivated MDA to misappropriate Gensetix’s property in 2017. Second, whether MDA truly thought, in 2017, that Gensetix’s patent infringement case against Diakonos was weak. Third, whether the medication expenses for the 2019 clinical trials were paid by a third party. Fourth, whether the grounds for the purported termination in 2020 were pretextual.

Under Self, intent no longer matters, so Gensetix wins; but even if it still mattered (as MDA argues on Reply), disputed jurisdictional facts were resolved below in Gensetix’s favor, so Gensetix would still win.

Unlike UTSW in Curadev, here MDA introduced, and asked Judge Schaffer to consider, evidence beyond the four corners of Gensetix’s pleading, (CR:134), (RR at 26:5-12), in an attempt to carry its burden of conclusively negating Gensetix’s pleaded allegation that the grounds for the termination in 2020 were pretextual. (CR:104, ¶ 26; CR:107, ¶ 50).

To rebut the evidence incorporated in MDA’s jurisdictional plea, Gensetix adduced countervailing evidence (CR:455-461), including details about MDA’s bad faith conduct towards Gensetix in the lead-up to the 2019 clinical trials, the pretextual demands for maintenance fees, and the purported termination in 2020. (CR:460, ¶¶ 34-38).

Because competing narratives, supported by competing evidence, were weighed and resolved in the trial court, MDA cannot rely on Curadev (or other cases where the evidence offered was unrelated8 to jurisdiction or the facts were undisputed9) to suggest that the STANDARD OF REVIEW applicable here, a case with disputed jurisdictional fact issues, is less deferential. Volkswagen and BMC Software continue to control, so all relevant facts upholding the order, with record support, must be implied.

III. MDA’s 2017 Taking is wholly unaffected by Curadev MDA nowhere denies that invoking ELEVENTH AMENDMENT immunity is a clear-cut abuse of eminent domain power. (Reply). Instead, MDA

Ford ex rel. Williams v. City of Lubbock, 76 S.W.3d 795, 797-798 (Tex. App.—Amarillo 2002, no pet.).

suggests that its misconduct in the patent litigation, extensively discussed in Gensetix’s operative complaint, was categorically excluded by Gensetix as a ground for MDA’s liability for Takings. (Reply at 8).

It was not. (CR:104-105, ¶¶ 29-31; CR:167-168; CR:598-603, ¶¶ 11, 16- 20; RR at 21:24-22:1). MDA has a fair opportunity to prepare defenses in response to Gensetix’s theory of MDA’s liability: that MDA’s invocation, in 2017, of the ELEVENTH AMENDMENT during the patent litigation—and MDA’s persistent refusal to abandon that meritless, gratuitous legal maneuver into 2018, 2019, and 2020—misappropriated Gensetix’s exclusive right to commercialize the technology. That the court below liberally 10 construed Gensetix’s pleadings was neither error nor reversible. Tex. Dep't of Crim.

Just. v. Rangel, 595 S.W.3d 198, 205 (Tex. 2020); TEX. R. APP. P. 44.1(a).

Curadev, a case where the ELEVENTH AMENDMENT was not invoked, has no bearing on Gensetix’s right to seek just compensation for the Taking embodied by MDA’s gratuitous invocation of the ELEVENTH AMENDMENT and

the years of gratuitous litigation that accompanied and facilitated MDA’s clear-cut exercise of MDA’s eminent domain powers.

IV. MDA’s 2020 Taking is distinguishable from Curadev Over a persuasive dissent, the Curadev majority held that the Dallas trial court did not err in declining to find that UTSW used eminent domain power when it obtained trade secret chemical compound. 2025 Tex. App. LEXIS 6472 at **17-18, 33-37. Unlike here, where MDA relinquished rights, UTSW obtained rights with clean hands in Curadev. Id. The Dallas trial court may have found differently if Curadev had adduced competent evidence of a logical nexus between (1) UTSW’s subjective state of mind at the time it exceeded the scope of the Takeda agreement and (2) UTSW’s exercise of a uniquely sovereign power.

Here, Judge Schaffer had sufficient evidence to treat MDA’s pretextual 2020 Taking as factually intertwined11 with, and part of the same “transaction” as, the ELEVENTH AMENDMENT-based Taking of 2017 that continued as of the date of the exhibit MDA introduced. See Lexington

See https://www.cafc.uscourts.gov/home/oral-argument/listen-to-oral-arguments/ (Appeal No. 19-1424) (Oral Argument Date, Feb. 4, 2020). That finding must be upheld.

Ins. Co. v. Daybreak Exp., Inc., 393 S.W.3d 242, 244 (Tex. 2013) (citing Moore v. NY Cotton Exch., 270 U.S. 593, 610 (1926)).

The court below did not err when it declined MDA’s invitation to find (1) the condition precedent to MDA’s right to terminate was fulfilled (it was not); (2) the professed grounds MDA asserted were non-pretextual (they were); and/or (3) the decision to terminate was isolated from the ongoing exercise of eminent domain power that commenced in 2017 (the two Takings were factually intertwined and logically related).

MDA had a full, fair opportunity to present the evidence necessary to persuade Judge Schaffer otherwise.

Gensetix is confident the evidence does not exist, but even if it did, MDA strategic decision to withhold it below cannot be cured on appeal.

Nor does Curadev give MDA a second12 bite at the apple; MDA must live with the consequences of introducing evidence that fell short of disproving Gensetix’s allegations of non-breach and of MDA’s pretext.

V. Neither Curadev nor any other case says that Takings lasting less than 33 months are non-actionable.

MDA reasons that—since its gratuitous ELEVENTH AMENDMENT theory didn’t hold up on appeal—the years-long effect of its abuse of

sovereign power is unlike the permanent loss of secrecy UTSW’s publication caused in Curadev, therefore it is non-actionable. (Reply at 9).

MDA’s reasoning fails. The duration of MDA’s misappropriation is immaterial to MDA’s liability, so MDA must “provide compensation for the period during which the taking was effective.” First English Evangelical Lutheran Church of Glendale v. Los Angeles Cty., 482 U.S. 304, 321, 317-322 (1987); United States v. General Motors Corp., 323 U.S. 373, 375, 378 (1945); Cedar Point Nursery v. Hassid, 594 U.S. 139, 156 (2021). Here, the misappropriation occasioned by MDA’s ELEVENTH AMENDMENT filing in 2017 effectively abated the patent litigation against Diakonos up to (and after) the purported “termination” in 2020. MDA’s years-long Taking is actionable and compensation is due to Gensetix.

VI. MDA misreads Chief Justice Brister’s dissenting opinion in Curadev.

MDA cites its nominal ownership of the patents as a reason not to recognize Gensetix’s exclusive right to commercialize the patented technology. (Reply at 33-34). In support of that argument, MDA says “[t]his case does not implicate any of Chief Justice Brister’s concerns in Curadev.” (Reply at 34, n.14) (emphasis supplied). MDA is wrong.

First, property interests less than outright ownership are cognizable. Fed. Land Bank of Houston v. United States, 168 F.Supp. 788,

789 n.1, 790, 791-792, 792 n.4 (Ct. Cl. 1958); Gen. Motors, 323 U.S. at 375, 378. Second, MDA already conceded below that “the existence of a contract by itself is insufficient to invalidate [Gensetix’s] Takings claim[.]” (CR:251); see also Self, 690 S.W.3d at 15, 17-19, 27, 29-32.

By MDA’s newfound logic, the mere existence of contractual privity between UT and a family living in a UT-owned apartment on Lake Austin Blvd would leave the family without recourse, and at UT’s mercy, if Diakonos were to sponsor unauthorized bullfights in the family’s apartment. Worse, UT could impute the resulting damage to the family and, if the family cannot afford to repair the damage, unilaterally declare the family in breach and evict them. This remains so, by MDA’s logic, even if UT knows Diakonos, and Diakonos alone, caused the damage.

MDA’s logic fails. After the State conveys the right to exclude, the State can no longer appropriate that exclusionary right without paying just compensation to the holder of that exclusionary right. Cf. Piazzola v. Watkins, 442 F.2d 284. 290 (5th Cir. 1971); Hassid, 594 U.S. at 156. Here, MDA did not even arguably act within the scope of its rights in 2017. The concerns Chief Justice Brister raised in Curadev plainly apply here.

VII. Gensetix respectfully asks this Court to disregard unpreserved, untimely arguments raised in MDA’s Reply.

In the court below, MDA advanced no interpretations of any License Agreement provisions relating to whether an annual maintenance fee was due in 2020. (CR). Nor did MDA do so in its Opening Brief. (OB).

But now, on Reply—to address an allegation pleaded in 2021— MDA unveils for the first time a novel legal argument surrounding the interpretations of §§ 2.3, 2.11 of the License Agreement. (Reply at 16-17, n.3) (citing ¶ 50 of Gensetix’s First Amended Petition).

“An objection at trial not comporting with the complaint on appeal presents nothing for appellate review.” Houston R.E. Income Props. XV, Ltd. v. Waller Cty. Appraisal Dist., 123 S.W.3d 859, 862 (Tex. App.— Houston [14th Dist.] 2003, no pet.). Nor may parties “enlarge a ground of error on appeal to include an objection not asserted at trial.” Sefzik v. Mady Dev’t, LP, 231 S.W.3d 456 (Tex. App.—Dallas 2007, no pet.).

Courts of appeal may not address issues of contract interpretation that were not the subject of a “complaint [that] was made to the trial court by a timely request, objection, or motion that stated the grounds []with sufficient specificity to make the trial court aware of the complaint[.]” Tex. R. App. P. 33.1(a)(1)(A) (emphasis supplied); see TRT Holdings, Inc. v. Ace Am. Ins. Co., No. 05-23-00868-CV, 2025 Tex. App.

11 LEXIS 7407 at **23-24 (Tex. App.—Dallas Sep. 18, 2025, n.p.h.) (insured could not raise new contract interpretation argument on appeal); Greater Houston Radiation Oncology v. Sadler Clinic Ass’n, PA, 384 S.W.3d 875, 890 (Tex. App.—Beaumont 2012, pet. denied) (panel did not address “arguments regarding the construction of the Management Agreement” because the appellant failed to make those arguments in the trial court).

For substantially the same reasons, MDA’s newly unveiled positions regarding the interpretations of §§ 7.1, 7.2, and its alleged non-breach of those obligations, are improper. (Reply at 14-16).

Accordingly, Gensetix respectfully OBJECTS on Tex. R. App. P. 33.1 and 38.1(f) grounds to MDA’s untimely-raised legal arguments concerning the interpretation and MDA’s purported non-breach of the License.

XIII. Conclusion MDA’s Reply accuses Gensetix of “creative pleading,” (Reply at 26), but MDA’s own choices, not artful pleading, are what erected insurmountable obstacles for MDA in this appeal.

First, MDA, not artful pleading, introduced evidence beyond the four corners of Gensetix’s pleadings. (CR:134), (RR at 26:5-12).

That means the court below resolved jurisdictional fact issues and the STANDARD OF REVIEW requires this Court to defer to those findings.

Second, MDA, not Gensetix, perfected its appeal before seeking narrower findings and rulings below. (CR:733-735). As a result, this Court must draw all record-supported inferences favorable to the order, and affirm on any legal basis ascertainable from the record.

Third, MDA “creatively” used the ELEVENTH AMENDMENT in the patent litigation. (CR:419, ¶¶ 54-55; CR:221-228). So, MDA can no longer say it acted “as any private party could have” in 2017. (Reply at 32).

MDA understandably wishes to put the genie back in the bottle, on all three counts, but no genie can rewrite history. These facts—fatal to MDA’s appeal notwithstanding Curadev—may not, through attorney argument, be brushed off as “creative pleading” because the record clearly shows they are MDA’s choices, which cannot be retracted on appeal.

Gensetix respectfully asks this Court to affirm the district court’s denial of Appellants’ plea to the jurisdiction.

Respectfully submitted, CONNOR LEE & SHUMAKER PLLC Castle Ridge Road, Suite 450 Austin, Texas 78746 512.777.1254 (main) 888.387.1134 (fax) By: /s/ Cabrach Connor Cabrach J. Connor State Bar No. 24036390 Email: [email protected] Jennifer Tatum Lee State Bar No. 24046950 Email: [email protected] Sergio R. Davila State Bar No. 24079795 Email: [email protected] THE BUZBEE LAW FIRM Anthony G. Buzbee State Bar No. 24001820 Ryan S. Pigg State Bar No. 24088227 [email protected] [email protected] 713-223-5393 ATTORNEYS FOR APPELLEE

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument was forwarded, on this the 31st day of October 2025, to the counsel of record for each of the parties via the service method indicated as follows: VIA ELECTRONIC SERVICE Alyssa Bixby-Lawson David E. Harrell, Jr. GENERAL LITIGATION DIVISION Deanna Markowitz Willson OFFICE OF THE ATTORNEY GENERAL Monika Dziemianczuk PO Box 12548, Capitol TROUTMAN PEPPER LOCKE LLP Austin, TX 78711 600 Travis Street, Suite 2800 Houston, TX 77002

/s/ Cabrach Connor Cabrach Connor

CERTIFICATE OF COMPLIANCE I hereby certify that the number of words contained in the non-exempt portions of this Sur-reply (including Tab 1) is 4,714 and that the undersigned relied on the word count of the computer program used to prepare the document to determine the number of words.

/s/ Cabrach Connor Cabrach Connor

No. 15-25-00011-CV IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN THE BOARD OF REGENTS OF THE UNIVERSITY OF TEXAS SYSTEM, THE UNIVERSITY OF TEXAS SYSTEM, and THE UNIVERSITY OF TEXAS M.D. ANDERSON CANCER CENTER Appellants vs. GENSETIX, INC. Appellee Appealed from the District Court, 152nd Judicial District Harris County, Texas, The Honorable Robert Schaffer (Presiding) Cause No. 2021-73071 TAB 1 APPELLEE’S BRIEF IN SURREPLY REGARDING CURADEV Table 1 (Unabridged) With Citations to the Record and pincites to Curadev opinion Material Distinction Between Gensetix and Curadev Sovereign Power employed by Governmental Party Gensetix Curadev ELEVENTH AMENDMENT None motion to dismiss CR:98-99 (Gensetix pleaded that MDA’s refusal to cooperate included its ELEVENTH AMENDMENT motion); CR:104-105, ¶¶ 30-32, 37 (Gensetix pleaded that MDA’s refusal to cooperate deprived Gensetix of its property right to enforce the patents against Diakonos); CR:170 (Gensetix successfully opposed dismissal by arguing that deprivation of IP rights are Takings); CR:174-175, CR:183, CR:221-228 (Gensetix successfully opposed dismissal by arguing MDA used the ELEVENTH AMENDMENT to effect the deprivation of MDA’s IP rights, citing MDA’s unambiguous “have their cake and eat it too” position in federal court); CR:400-452 (Gensetix successfully opposed MDA’s plea to the jurisdiction by arguing MDA used the ELEVENTH AMENDMENT to deprive Gensetix of IP rights) CR:600-602, ¶¶16-19 (a liberal interpretation of Gensetix’s pleadings means MDA’s refusal to cooperate included its ELEVENTH AMENDMENT motion); RR at 7:19-24 (emphasis supplied) [Counsel for MDA:] Gensetix filed [a patent infringement suit] and tried to make the Board of Regents an Involuntary Plaintiff in the lawsuit it had filed in the Southern District of Texas. That’s where the [ELEVENTH AMENDMENT] sovereign immunity plea started by the Board of Regents[.]

Curadev, 2025 Tex. App. LEXIS 6472 (no sovereign power of any kind used by UTSW) Material Distinction Between Gensetix and Curadev Governmental Party’s Mental State and Conduct Gensetix Curadev Bad Faith intent to interfere with Good Faith Gensetix’s right to sue intent to publish research findings CR:95-105 (Gensetix pleaded a detailed account of MDA’s bad faith at all relevant times); CR:177-182 (Gensetix successfully opposed dismissal because MDA lacked “good faith” at all relevant times); CR:354-368 (Gensetix propounded discovery requests seeking evidence of MDA’s purported “good faith”) CR:406-423, ¶¶ 2-75 (Gensetix successfully opposed MDA’s plea to the jurisdiction by providing a detailed account of MDA’s bad faith at all relevant times); CR:455-461 (Declaration of Rita Mousa in opposition to Defendants’ plea to the jurisdiction, evidence considered by Judge Schaffer consisting of a detailed account of MDA’s bad faith at all relevant times); Curadev, 2025 Tex. App. LEXIS 6472 at *5 In October or November 2020, Curadev learned that Bai and Zhang "had generated data showing that Curadev's test compound [Company Material] indeed bound to a unique allosteric transmembrane site on STING." At that time, Appellees "were not aware that Curadev was the inventor of the test compound or of the chemical structure of the test compound or any of Curadev's other compounds." Material Distinction Between Gensetix and Curadev Nature of the Property Conveyance Gensetix Curadev Gov’t relinquished commercialization Gov’t obtained rights to Mirrow, who sold them to Gensetix information from Takeda CR:102, ¶¶ 13, 16 (Gensetix pleaded that MDA conveyed the exclusive rights to Mirrow, who then conveyed the exclusive rights to Gensetix); Curadev, 2025 Tex. App. LEXIS 6472 at *11 The record reflects that Southwestern entered into a Research Agreement with Takeda Curadev, 2025 Tex. App. LEXIS 6472 at *12 The crux of Curadev's takings claim is that Southwestern used Company Material it acquired by agreement, which led to its published discovery about the compound C53. Curadev cannot show Southwestern waived sovereign immunity by exercising its eminent domain power because Southwestern acquired Curadev's test compound—Company Material—through a valid contract with Takeda.

Material Distinction Between Gensetix and Curadev Source of the Private Party’s Property Interest Gensetix Curadev Statutory right to exclude granted by Promise UTSW made to Patent Office to inventors’ assignees Takeda in a contract CR:169-170 (citing 35 U.S.C. § 261); CR:455-456, ¶ 5 (Declarant, Rita Mousa, explaining that no rights existed at the time of Mirrow’s conveyance to Gensetix in January 2014); CR:455-456, ¶ 9 (Declarant, Rita Mousa, explaining that the Patent Office granted a patent in May 2014); Curadev, 2025 Tex. App. LEXIS 6472 at *3 [A] Takeda subsidiary, Takeda California, Inc., entered into a Sponsored Collaboration Research Agreement (the Research Agreement) with Southwestern.

Pursuant to the Research Agreement, Takeda provided Southwestern with one of Curadev's STING agonist test compounds (Company Material).

Curadev, 2025 Tex. App. LEXIS 6472 at *4 []The Research Agreement defined "Confidential Information" as "any scientific, technical, trade or business information possessed or obtained by, developed for or given to the recipient Party which is treated by the disclosing Party as confidential or proprietary." The Research Agreement noted that the parties would use reasonable efforts to prevent disclosure of the other party's confidential information for five years after receipt.

Material Distinction Between Gensetix and Curadev Conflicting Evidence of Governmental Scienter Gensetix Curadev MDA’s Exhibits 6-7 vs. None Mousa Declaration w/ 21 Exhibits CR:134, n.7 (MDA, within its jurisdictional plea, asking the court below to consider “Exhibit 6” and “Exhibit 7” as evidence that the technology had not been commercialized and that Gensetix did not pay the fee owed to MDA when the technology isn’t commercialized.); CR:92-94 (MDA’s “Exhibit 6”); 2SuppCR:3-4 (MDA’s “Exhibit 7”); CR:454-595 (Declaration of Rita Mousa with 21 Exhibits); CR:460, ¶¶ 34-38 (Mousa detailing MDA’s bad faith behavior and disputing MDA’s allegations of the validity of its demand for a maintenance fee payment) RR at 7:25-8:9 (emphasis supplied) [Counsel for MDA:] And that evidence that we’ve provided with our Answer and incorporated through the Plea to the Jurisdiction shows with our Exhibit 6 [MDA accused Gensetix of breach] And with our Exhibit 7 we show that in May of 2020 that Contract was terminated.

RR at 26:9-10 (emphasis supplied) [Counsel for MDA:] We’ve provided the Court with Exhibit 7[.]

Curadev, 2025 Tex. App. LEXIS 6472 at **11-12 Curadev does not dispute that Southwestern and Takeda had an agreement, nor does it dispute that Takeda provided Company Material to Southwestern under the Research Agreement.

Material Distinction Between Gensetix and Curadev Disputed Jurisdictional Facts Gensetix Curadev (1) MDA’s 2017 side-deal was illicit None CR:97-99, CR:103-105 (Gensetix pleaded that MDA entered an unauthorized side-deal with Diakonos and Baylor) CR:133 (MDA’s jurisdictional plea denies that it entered an unauthorized side-deal with Diakonos and Baylor, claiming Gensetix’s allegations are “imagined facts” and that MDA “never conspired” with Diakonos or Baylor) CR:697, CR:697 n.12 (MDA in its reply brief to the court below maintained that the side deal did not “exist” and that Gensetix’s allegation was “categorically false.”)

OB at 45 (MDA on appeal “vigorously denies” the side- deal) Curadev, 2025 Tex. App. LEXIS 6472 at **12-13 Curadev does not dispute that Southwestern and Takeda had an agreement, nor does it dispute that Takeda provided Company Material to Southwestern under the Research Agreement.

Material Distinction Between Gensetix and Curadev Disputed Jurisdictional Facts Gensetix Curadev (2) Gensetix’s 2017 patent suit was strong None CR:96 (Gensetix pleaded that Diakonos officer William Decker developed unauthorized “improvements” to the patented technology, which infringed the patents); CR:104, ¶ 27 (Gensetix pleaded that Diakonos knew it lacked the “freedom to operate” to engage in the same commercial activities that would form the basis of the patent infringement suit; that is willful infringement); CR:133 (MDA’s jurisdictional plea claimed Gensetix’s allegations are “imagined facts”); Reply at 15 (On appeal, MDA clarifies that it meant it subjectively believed Gensetix’s infringement suit against Diakonos was too “weak” to be allowed to proceed); Curadev, 2025 Tex. App. LEXIS 6472 at **12-13 Curadev does not dispute that Southwestern and Takeda had an agreement, nor does it dispute that Takeda provided Company Material to Southwestern under the Research Agreement.

Material Distinction Between Gensetix and Curadev Disputed Jurisdictional Facts Gensetix Curadev (3) The 2019 clinical trials were commercial None CR:103, ¶ 24 (Gensetix pleaded Phase I manufacturing activities were funded by Diakonos, third party, and that clinical trials were conducted); CR:107, ¶ 50 (Gensetix pleaded that commercial activity took place prior to 2020); CR:419, ¶ 58 (Gensetix adduced evidence, Exhibit 21 to the Declaration of Rita Mousa, in opposition to MDA’s jurisdictional plea establishing that “in 2019, Phase I Clinical Trials in New Jersey . . . were underway[.]”)

CR:460, ¶36 (Mousa attesting to facts establishing that Phase I clinical trials were taking place, supporting the inference that infringing medications were developed with outside funding for commercial purposes); CR:591-594 (Exhibit 21, a press release dated June 7, 2019, announcing the clinical trials to take place in Camden, New Jersey); CR:134, n.7 (MDA, within its jurisdictional plea, contending the technology had not been commercialized and that Gensetix did not pay the fee owed to MDA when the technology isn’t commercialized.); Curadev, 2025 Tex. App. LEXIS 6472 at **12-13 Curadev does not dispute that Southwestern and Takeda had an agreement, nor does it dispute that Takeda provided Company Material to Southwestern under the Research Agreement.

Material Distinction Between Gensetix and Curadev Disputed Jurisdictional Facts Gensetix Curadev (4) MDA cooked up a pretext in 2020 None CR:107, ¶ 50 (Gensetix pleaded both that MDA was not entitled to maintenance fees in 2020, and that MDA refused to substantiate its position that commercial activities had not taken place) CR:419-420, ¶¶ 57-60; CR:421, ¶ 64; CR:435, ¶ 104 (Gensetix argued that the alleged entitlement to a maintenance fee was a “pretext” and in support of that argument adduced evidence, Exhibit 21 to the Declaration of Rita Mousa, establishing that no maintenance fee was owed) CR:460, ¶36 (Mousa attesting to facts establishing that Phase I clinical trials were taking place, supporting the inference that infringing medications were developed with outside funding for commercial purposes); CR:591-594 (Exhibit 21, a press release dated June 7, 2019, announcing the clinical trials to take place in Camden, New Jersey); Curadev, 2025 Tex. App. LEXIS 6472 at **12-13.

Curadev does not dispute that Southwestern and Takeda had an agreement, nor does it dispute that Takeda provided Company Material to Southwestern under the Research Agreement.

Material Distinction Between Gensetix and Curadev Circumstances Gensetix Curadev Extraordinary Common Inducements, lies, and calculated Study submitted a few betrayal aided by abuse of ELEVENTH months early AMENDMENT CR:95-105, ¶¶ preamble, ¶¶ 1-35 (detailing MDA’s inducements, lies, and abuse of the Eleventh Amendment) CR:177-182 (detailing MDA’s lack of good faith, egregious extra-contractual activity, and the relationship between its “secret deal” with Diakonos and Baylor) CR:357-368 (detailing the relationship Gensetix’s pending discovery requests and MDA’s egregious misconduct) CR:406-423, ¶¶ 2-75 (detailing the extraordinary circumstances embodied by MDA’s egregious misconduct) CR:455-461 (Declaration of Rita Mousa in opposition to MDA’s plea to the jurisdiction, detailing the extraordinary circumstances embodied by MDA’s egregious misconduct) https://search.txcourts.gov/Case.aspx?cn=15-25- 00004-CV&coa=coa15 (Cause No. 15-25-00004-CV, BRIEF OF APPELLANT, Appendix Tab 7 -Curadev’s Operative Pleadings], Exhibit [E-mail correspondence between UTSW and Curadev], pp. 149-151) available at https://search.txcourts.gov/SearchMedia.aspx?MediaVe rsionID=e86171b9-b7a4-46a6-b445- 5ee298538dba&coa=coa15&DT=Brief&MediaID=03f4b 476-515e-4ed8-9a47-43c300380f80 (E-mail dated Jan. 4, 2021, from Xuewu Zhang to Arjun Surya) (“We can delay the publication of this structure to some later date, but the middle of 2022 seems excessive.”)

No. 15-25-00011-CV IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN THE BOARD OF REGENTS OF THE UNIVERSITY OF TEXAS SYSTEM, THE UNIVERSITY OF TEXAS SYSTEM, and THE UNIVERSITY OF TEXAS M.D. ANDERSON CANCER CENTER Appellants vs. GENSETIX, INC. Appellee Appealed from the District Court, 152nd Judicial District Harris County, Texas, The Honorable Robert Schaffer (Presiding) Cause No. 2021-73071 TAB 2 APPELLEE’S BRIEF IN SURREPLY REGARDING CURADEV

Excerpts from Curadev’s BRIEF IN OPPOSITION TO UTSW’S PLEA TO THE JURISDICTION filed in Dallas County FILED 9/24/2024 2:39 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Miranda Lynch DEPUTY

CAUSE NO. DC-24-03875 CURADEV PHARMA PVT. LTD., § IN THE DISTRICT COURT OF and CURADEV PHARMA LIMITED, § § Plaintiffs, § § V. § DALLAS COUNTY, TEXAS THE UNIVERSITY OF TEXAS § SOUTHWESTERN MEDICAL § CENTER, DR. XIAOCHEN BAI, AND § DR. XUEWU ZHANG, § § Defendants. § 101ST JUDICIAL DISTRICT

PLAINTIFFS' RESPONSE IN OPPOSITION TO DEFENDANTS' PLEA TO THE JURISDICTION Plaintiffs Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited (together, "Curadev") file this response in opposition to the Plea to the Jurisdiction filed on July 30, 2024, by Defendants The University of Texas Southwestern Medical Center ("UTSW"), Dr. Xiaochen Bai ("Bai"), and Dr. Xuewu Zhang ("Zhang," and collectively with UTSW and Bai, the "Defendants") and respectfully show the Court the following: I. INTRODUCTION Defendants ask this Court to give a free pass to the state-sanctioned theft of intellectual property. In essence, they contend that the government can plunder a company's valuable trade secrets by extending false promises of confidentiality under the guise of academic research, then secretly steal that information to enrich itself through patents and joint enterprises with other private companies-all without paying the property owner a cent. Then, if the government gets caught, the Defendants contend that the owner has no right to even seek a remedy in a court of law.

This case is why we have the Takings Clause. Even if Defendants had sovereign immunity from tort claims (which they waived in this case by their inequitable conduct), such immunity

Plaintiffs' Response in Opposition to Defendants' Plea to the Jurisdiction 1198 Cause No. DC-24-0387 1 on the argument that Plaintiffs' entire suit is barred by sovereign immunity. Defendants are incorrect. Sovereign immunity does not apply to Plaintiffs' constitutional claim at all. And, as to the TUTSA and conversion claims, Plaintiffs have pled that Defendants waived immunity through their conduct, and that Defendants Bai and Zhang have also engaged in ultra vires acts, for which no immunity applies. Notably, Defendants have submitted no facts contradicting Plaintiffs' allegations, and their legal arguments are either misguided or rely on a mischaracterization of Plaintiffs' claims. Simply put, there is no basis to dismiss this case on jurisdictional grounds, and Defendants' Plea to the Jurisdiction should be rejected.

A. Sovereign Immunity Does Not Apply to Plaintiffs' Constitutional Takings Claim against UTSW.

Sovereign immunity does not apply to a constitutional takings claim. See Harris Cnty. Flood Control Dist. v. Kerr, 499 S.W.3d 793, 799 (Tex. 2016), reh'g denied (Oct. 21, 2016) ("Sovereign immunity does not shield the government from liability for compensation under the takings clause."). Defendants do not even attempt to refute this black-letter law,1 so instead they claim sovereign immunity as a jurisdictional defense by prematurely attacking Curadev's constitutional claim on the merits. Specifically, they argue that Plaintiffs' constitutional claim is facially invalid because Plaintiffs: (1) have not pled an "actionable taking;" and (2) cannot show that UTSW acted with the requisite intent. See Plea to the Jurisd. at 22-32.

At the outset, these are quintessential merits arguments-not a basis for declining subject­ matter jurisdiction. If Defendants want to attack the legal strength of Plaintiffs' claims, they will

Defendants argue that, absent a legislative waiver, UTSW is immune from conversion and TUTSA claims. Plea to the Jurisd. at 17-20. They do not (and cannot) argue legislative waiver is required before UTSW may face constitutional takings claim. See Steele v. City ofHouston, 603 S.W.2d 786, 791 (Tex. 1980) ("The Constitution itself ... is a waiver of governmental immunity for the taking, damaging or destruction of property for public use.").

Plaintiffs' Response in Opposition to Defendants' Plea to the Jurisdiction Cause No. DC-24-0387 5 1202 Dated: September 24, 2024 Respectfully Submitted, Allen Overy Shearman Sterling US LLP

Isl David P. Whittlesey David P. Whittlesey Texas Bar No. 00791920 West 6th Street, Suite 2250 Austin, Texas 78701 (512) 647-1900 (tel) [email protected] Attorneys for Plaintiffs

CERTIFICATE OF SERVICE I hereby certify that on this the 24th day of September, 2024, I served a true and correct copy of the foregoing instrument on all attorneys of record via e-filing.

Isl David P. Whittlesey David P. Whittlesey

Plaintiffs' Response in Opposition to Defendants' Plea to the Jurisdiction Cause No. DC-24-0387 22 1219 No. 15-25-00011-CV IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS AT AUSTIN THE BOARD OF REGENTS OF THE UNIVERSITY OF TEXAS SYSTEM, THE UNIVERSITY OF TEXAS SYSTEM, and THE UNIVERSITY OF TEXAS M.D. ANDERSON CANCER CENTER Appellants vs. GENSETIX, INC. Appellee Appealed from the District Court, 152nd Judicial District Harris County, Texas, The Honorable Robert Schaffer (Presiding) Cause No. 2021-73071 TAB 3 APPELLEE’S BRIEF IN SURREPLY REGARDING CURADEV

Excerpts from Curadev’s REPLY BRIEF filed in the Fifteenth Court of Appeals ACCEPTED 15-25-00004-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/31/2025 9:12 PM CHRISTOPHER A. PRINE No. 15-25-00004-CV CLERK FILED IN 15th COURT OF APPEALS In the Court of Appeals AUSTIN, TEXAS For the Fifteenth District of Texas3/31/2025 9:12:14 PM CHRISTOPHER A. PRINE Clerk Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited, Plaintiffs-Appellants, v. The University of Texas Southwestern Medical Center, Dr. Xiaochen Bai, and Dr. Xuewu Zhang, Defendants-Appellees.

Interlocutory Appeal from the 101st District Court of Dallas County Trial Court No. DC-24-03875 APPELLANTS’ REPLY BRIEF ALLEN OVERY SHEARMAN STERLING US LLP David P. Whittlesey Trey Hebert W. 6th Street, Suite 2250 Austin, Texas 78701 (512) 647-1900 (phone) Jacob Fields 2601 Olive Street, 17th Floor Dallas, Texas 75201 (214) 271-5777 (phone) Attorneys for Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited ORAL ARGUMENT REQUESTED Appellants Curadev Pharma Pvt. Ltd. and Curadev Pharma Limited (“Curadev” or “Appellants”) file this Reply Brief and would respectfully show the Court as follows: I. INTRODUCTION Appellees present a revisionist view of what happened and what Curadev has alleged. As explained in Appellants’ opening brief, the facts as pleaded are what matter—not Appellees’ rendition of them. Despite their obfuscation, Appellees acknowledge Curadev’s core operative allegations: 1. Curadev developed a STING1 agonist that binds to an allosteric transmembrane site of the STING protein.

Appellees’ Br. at 3.

2. Curadev licensed that STING agonist to third-party Takeda.

Id. 3. To verify its binding properties, Takeda contracted The University of Texas Southwestern Medical Center (“UTSW”) to conduct certain research on Curadev’s STING agonist under the Sponsored Collaboration Research Agreement, (the “Research Agreement”). Id. at 4.

4. Pursuant to the Research Agreement, Takeda provided Curadev’s STING agonist (the “test compound”) to Appellees.

Id. 5. Appellees performed the requested tests and confirmed that the test compound bound to a unique allosteric transmembrane site on STING. Id. at 6-7.

6. Appellees did not develop the test compound or independently decide to test its allosteric binding properties. Id. 7. After the Research Agreement was terminated, Takeda informed Appellees that Curadev invented the test compound.

Id. at 7.

8. Curadev requested that Appellees delay publication on Curadev’s test compound and later offered to discuss joint publication in July 2021. Id. at 8.

9. Meanwhile, Appellees identified one of Curadev’s publicly disclosed compounds similar in structure (“C53”), and confirmed it had similar binding properties. Id. at 8.

10. Appellees then published these “findings” in Nature as their own, filed a patent application, and sought to commercialize them through a collaboration with Curadev’s competitors. See id. at 8.

Those facts appear to be undisputed. Appellees characterize Curadev’s claim as a “fruit of the poisonous tree” argument. Id. at 9. To the contrary, Appellees chopped down the tree that Curadev painstakingly grew. As public officials, Appellees unlawfully used, published, and misappropriated the proprietary fruits of Curadev’s labor.

Dated: March 31, 2025 Respectfully Submitted, Allen Overy Shearman Sterling US LLP

/s/ David P. Whittlesey David P. Whittlesey Texas Bar No. 00791920 [email protected] Trey Hebert Texas Bar No. 24067819 [email protected] West 6th Street, Suite 2250 Austin, TX 78701 (512) 647-1900 (tel) Jacob Fields Texas Bar No. 24115134 [email protected] The Link at Uptown 2601 Olive St., 17th Floor Dallas, TX 75201 (214) 271-5777 (tel) Attorneys for Appellants

Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Cabrach Connor Bar No. 24036390 [email protected] Envelope ID: 107552328 Filing Code Description: Other Brief Filing Description: Appellee's Brief in Surreply Regarding Curadev Status as of 11/3/2025 7:04 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Terri Abernathy [email protected] 10/31/2025 4:58:47 PM SENT Victoria Gomez [email protected] 10/31/2025 4:58:47 PM SENT Thomas FLoose [email protected] 10/31/2025 4:58:47 PM SENT David E.Harrell [email protected] 10/31/2025 4:58:47 PM SENT Deanna MarkowitzWillson [email protected] 10/31/2025 4:58:47 PM SENT Chris Dove [email protected] 10/31/2025 4:58:47 PM SENT Monika Dziemianczuk [email protected] 10/31/2025 4:58:47 PM SENT Cabrach Connor [email protected] 10/31/2025 4:58:47 PM SENT Jennifer TatumLee [email protected] 10/31/2025 4:58:47 PM SENT Sergio Davila [email protected] 10/31/2025 4:58:47 PM SENT Anthony Buzbee [email protected] 10/31/2025 4:58:47 PM SENT Ryan Pigg [email protected] 10/31/2025 4:58:47 PM SENT Rian Taff [email protected] 10/31/2025 4:58:47 PM SENT Mauricio Guevara [email protected] 10/31/2025 4:58:47 PM SENT Lionel Sims [email protected] 10/31/2025 4:58:47 PM SENT Alyssa Bixby-Lawson [email protected] 10/31/2025 4:58:47 PM SENT