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`EXHIBIT 12
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`DECLARATION OF TRENT D. TANNER
`IN SUPPORT OF
`NUVASIVE'S OPPOSITION TO
`DEFENDANTS' MOTIONS IN LIMINE NOS. 1-10
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`Case 3:18-cv-00347-CAB-MDD Document 350-13 Filed 11/06/21 PageID.32479 Page 2 of 2
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`Alphatec
`Witness
`Michael
`Aleali
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`Kelli
`Howell
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`Scott
`Robinson
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`Frank
`Chang
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`APPENDIX A
`Alphatec Rule 26
`Alphatec Trial Witness List
`Disclosures (Doc. No.
`Disclosures (Doc. No. 342-22)
`342-23)
`Marketing of accused
`Alphatec intends to call Mr. Aleali to
`products, topics
`testify about Alphatec; his experience;
`covered in deposition;
`Alphatec’s surgical guides; Alphatec’s
`allegations in the
`technology, LLIF technique and
`complaint.
`products, including the Accused
`Products; the marketing, sales, drivers
`of demand, market, and marketplace for
`Alphatec’s technology, LLIF technique
`and products, including the Accused
`Products; the spine industry;
`technologies comparable to the Accused
`Products; technologies comparable to
`the embodying products; “noninfringing
`alternatives”; damages related issues;
`and the topics in his deposition.
`Alphatec intends to call Ms. Howell to
`testify about Alphatec; NuVasive; her
`experience; the spine industry; use of
`Alphatec’s technology, LLIF technique,
`and products, including the Accused
`Products; embodying products;
`competitive landscape; and topics in her
`deposition.
`Alphatec intends to call Mr. Robinson to
`testify regarding Alphatec; his
`experience; the design, development,
`operation, sales, performance, and use
`of Alphatec’s technology, LLIF
`technique, and products, including the
`Accused Products; the spine industry;
`technologies comparable to the Accused
`Products; technologies comparable to
`the embodying products; “noninfringing
`alternatives”; damages related issues; to
`rebut NuVasive’s allegations that
`Alphatec has willfully infringed the
`Asserted Patents; and the topics in his
`deposition.
`Mr. Chang may be called by Alphatec to
`testify regarding the design,
`development, operation, sales,
`performance, and use of Alphatec’s
`technology, LLIF technique, and
`products, including the Accused
`Products; and the topics in his
`deposition.
`
`Testing of the accused
`products, topics
`covered in deposition;
`allegations in the
`complaint.
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`Medical education,
`including surgeon
`education/training,
`topics covered in
`deposition; allegations
`in the complaint.
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`Development of
`accused products,
`topics covered in
`deposition; allegations
`in the complaint.
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`EXHIBIT 12
`Page 441
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