Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 1
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` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MEDTRONIC, INC. and MEDTRONIC
`
`VASCULAR, INC.,
`
` Petitioners,
`
`v. Case IPR2014-00100
`
` Patent 5,593,417
`
`MARITAL DEDUCTION TRUST,
`
` Patent Owner.
`
`__________________________________/
`
` * * * SUBJECT TO PROTECTIVE ORDER * * *
`
` DEPOSITION OF TRAVIS ROWE
`
` THURSDAY, JUNE 26, 2014
`
` SAN FRANCISCO, CALIFORNIA
`
`Reported by:
`
`DEBORAH MAYER, CSR 9654, RPR CRR CRP CLR
`
`for ALDERSON COURT REPORTING (202) 289-2260
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 1
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` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDTRONIC, INC. and MEDTRONIC
`
`VASCULAR, INC.,
`
` Petitioners,
`
`v. Case IPR2014-00100
`
` Patent 5,593,417
`
`MARITAL DEDUCTION TRUST,
`
` Patent Owner.
`
`__________________________________/
`
` * * * SUBJECT TO PROTECTIVE ORDER * * *
`
` DEPOSITION OF TRAVIS ROWE
`
` THURSDAY, JUNE 26, 2014
`
` SAN FRANCISCO, CALIFORNIA
`
`Reported by:
`
`DEBORAH MAYER, CSR 9654, RPR CRR CRP CLR
`
`for ALDERSON COURT REPORTING (202) 289-2260
`
`Alderson Reporting Company
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`Page 1
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 2
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` BE IT REMEMBERED, pursuant to the laws
`
`governing the taking and use of depositions, that on
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`Thursday, June 26, 2014, 8:55 a.m. - 1:49 p.m., at
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`Pillsbury Winthrop Shaw Pittman LLP, 4 Embarcadero
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`Center, 22nd Floor, San Francisco, California, 94111,
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`before me, Deborah Mayer, a Certified Shorthand Reporter
`
`for the State of California, there personally appeared:
`
` TRAVIS ROWE,
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`called as a witness by the Patent Owner, who, being by
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`me first duly sworn/affirmed, was thereupon examined and
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`testified as hereinafter set forth.
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`///
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 3
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` A P P E A R A N C E S
`
`FOR THE PETITIONERS:
`
` PILLSBURY WINTHROP SHAW PITTMAN, LLP
`
` BY: JACK BARUFKA, ESQ.
`
` 1650 Tysons Boulevard, 14th Floor
`
` McLean, VA 22102-4856
`
` 703.770.7712
`
` barufka@pillsburylaw.com
`
` BY: EVAN FINKEL, ESQ.
`
` 725 South Figueroa Street, Suite 2800
`
` Los Angeles, CA 90017-6406
`
` 213.488.7307
`
` evan.finkel@pillsburylaw.com
`
`FOR THE PATENT OWNER:
`
` FRIEDMAN SUDER & COOKE
`
` BY: BRETT M. PINKUS, ESQ.
`
` Tindall Square Warehouse, No. 1
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` 604 E. 4th Street, Suite 200
`
` Fort Worth, TX 76102
`
` 817.334.0359
`
` pinkus@fsclaw.com
`
`///
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`Page 3
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 4
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` A P P E A R A N C E S (cont.)
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`ALSO PRESENT:
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` TED LOPEZ, for Medtronic.
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`///
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`Page 4
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 5
`
` I N D E X
`
`Witness: Page
`
`TRAVIS ROWE
`
` EXAMINATION BY MR. PINKUS 8
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` EXAMINATION BY MR. BARUFKA 95
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` S T I P U L A T I O N S
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` Page Line
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`MR. PINKUS: I'll preserve the option to 10 18
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`seek those later.
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`MR. BARUFKA: Before we start, I know we've 95 17
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`got this call, but we want to designate the
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`transcripts from today and yesterday under
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`the Protective Order, under the default
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`Protective Order.
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`JUDGE BONILLA: Sure. Please be sure to 107 17
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`put a copy of the transcript in the record.
`
`///
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 6
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` M O T I O N T O S T R I K E
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`MR. BARUFKA: We can scratch that last 99 10
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`question.
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`THE REPORTER: Okay.
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`///
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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`Page 7
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` E X H I B I T S
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` (PREVIOUSLY MARKED)
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`Patent Owner's: Page
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`Exhibit 2 United States Patent Rhodes 32
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` 5,593,417 (9 pages).
`
`Exhibit 4 United States Patent Lazarus 85
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` 5,104,399 (15 pages).
`
`Exhibit 5 United States Patent Marin, et 89
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` al., 5,397,355 (4 pages).
`
`Exhibit 6 United States Patent Kornberg 69
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` 4,562,596 (9 pages).
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` E X H I B I T S
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` MARKED FOR IDENTIFICATION
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`Patent Owner's: Page
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`Exhibit 7 Declaration of Travis Rowe 32
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` (14 pages).
`
`Exhibit 8 Figure A, color photo (1 page). 122
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`Exhibit 9 Figure B, color photo (1 page). 122
`
`Exhibit 10 Figure C, color photo (1 page). 122
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`Exhibit 11 Figure D, color photo (1 page). 122
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`Exhibit 12 Figure E, color photo (1 page). 122
`
`///
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`Page 7
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 8
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`(Thursday, 6-26-2014, 8:55 a.m. - 1:49 p.m.)
`
`(Witness sworn.)
`
` EXAMINATION
`
`BY MR. PINKUS:
`
` Q. This is the deposition of Travis Rowe in the
`
`inter partes review between Medtronic and Medtronic
`
`Vascular, Inc., Petitioners, vs Marital Deduction Trust,
`
`Patent Owner, case number IPR2014-00100, Patent number
`
`5,593,417. Good morning.
`
` A. Good morning.
`
` Q. Could you please state your full name for the
`
`record.
`
` A. My name is Travis Rowe.
`
` Q. Have you ever been deposed before?
`
` A. No. First time.
`
` Q. Have you ever given testimony in court before?
`
` A. No.
`
` Q. Have you ever testified before the Patent
`
`Office?
`
` A. No.
`
` Q. Have you ever submitted a declaration to the
`
`Patent Office before?
`
` A. Other than this one, no.
`
` Q. Not other than this one?
`
` A. No.
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`Travis Rowe
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`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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`Page 9
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` Q. I'm going to go over some ground rules really
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`quickly.
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` So I'm going to ask you a series of questions,
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`and it's going to be about the declaration that you
`
`submitted in this proceeding. And even though this is
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`an inter partes review, I'm going to refer to it as an
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`IPR. Is that okay with you?
`
` A. Sure.
`
` Q. If you don't hear a question please let me
`
`know. Or if you don't understand, I'll rephrase it. If
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`you gave an incomplete or inaccurate answer please let
`
`me know. And if you'd like to take a break, please let
`
`me know.
`
` Please let me complete my question before
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`answering and I'll let you complete your answer before
`
`the next question.
`
` A. Sure.
`
` Q. Your attorney may object from time to time so
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`you may want to wait for him to complete his objection
`
`before answering. Do you understand those ground rules?
`
` A. Yes.
`
` Q. Is there any reason why you can't give full and
`
`complete answers today?
`
` A. No.
`
` Q. Good. What did you do to prepare for the
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`Page 9
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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`Page 10
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`deposition today?
`
` A. Reviewed the patents, reviewed the declaration.
`
` Q. Did you review any other documentation?
`
` A. No.
`
` Q. And what patents are you referring to?
`
` A. By number, I'd have to look at them. Last
`
`three digits of the Kornberg is 596, Rhodes 417, and
`
`Rhodes 154.
`
` Q. Did you take any notes that you brought with
`
`you here today during preparation?
`
` A. Yes.
`
` MR. PINKUS: I'd ask to see those at the break.
`
` MR. BARUFKA: That's attorney/client privilege.
`
` MR. PINKUS: His notes that you've taken are
`
`not attorney/client privileged.
`
` MR. BARUFKA: It's notes that we consulted with
`
`him while he was taking them. They're privileged.
`
` MR. PINKUS: I'll preserve the option to seek
`
`those later.
`
` MR. BARUFKA: Those notes reflect discussions
`
`between attorney/client.
`
`BY MR. PINKUS:
`
` Q. I'd ask you to preserve those notes just in
`
`case we need them later.
`
` A. Sure.
`
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`Page 10
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 11
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` Q. How much time did you spend preparing for the
`
`deposition today?
`
` A. Today, I don't know, 15 minutes.
`
` Q. Just today? How about before today?
`
` A. Before today, easily, five, six hours.
`
` Q. And you didn't review any literature beyond
`
`those patents and your declaration that you mentioned
`
`previously?
`
` A. No, not in something like this, no.
`
` Q. How much time did you spend in preparing the
`
`declaration that you submitted for this proceeding?
`
` A. It was months and months ago. I honestly don't
`
`remember.
`
` Q. Could you give me an estimate?
`
` A. A few hours, possibly more.
`
` Q. And you've submitted your declaration -- or you
`
`signed your declaration on October 30th, 2013, is that
`
`correct?
`
` A. Right.
`
` Q. Do you know approximately how much before that
`
`time you were contacted to prepare your declaration?
`
` A. So, the previous is October 30th, 2013?
`
` Q. Right.
`
` A. Okay. It sounded like you said 13th. What was
`
`the question?
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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`Page 12
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` Q. How much before that time were you contacted to
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`begin the preparation of your declaration?
`
` A. I honestly don't remember back that far.
`
` Q. Can you guess?
`
` MR. BARUFKA: Objection, calls for speculation.
`
`BY MR. PINKUS:
`
` Q. Can you give me an approximate amount of time?
`
` A. A couple of weeks, but I'm really unsure on
`
`that.
`
` Q. Did you prepare your declaration entirely by
`
`yourself?
`
` MR. BARUFKA: Objection attorney/client
`
`privilege.
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` MR. PINKUS: You can answer as to whether you
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`did it by yourself. I'm not asking what your attorneys
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`did.
`
` A. Um hum. I had assistance with this.
`
`BY MR. PINKUS:
`
` Q. Do you know what the opinion is you were going
`
`to give in your declaration before going into the
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`preparation of the declaration?
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` A. No, it was open subject to me. I had to review
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`the patents to formulate an opinion.
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` Q. Okay, let's talk about your background a little
`
`bit.
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`Page 12
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`Travis Rowe
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`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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`Page 13
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` A. Um hum.
`
` Q. Starting with undergraduate college, where did
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`you go to college?
`
` A. U.C. Santa Cruz, U.C. Davis.
`
` Q. You received a degree from there?
`
` A. U.C. Davis.
`
` Q. What was your degree in?
`
` A. Mechanical and material science engineering.
`
` Q. What year?
`
` A. '95, 1995.
`
` Q. Was there any specialty in the course of your
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`studies?
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` A. It's a dual degree. So the specialty is the
`
`materials and mechanical combined. At the time, it was
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`a specialty.
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` Q. Did you study anything in particular any
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`medical devices during your undergraduate studies?
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` A. Very little, actually.
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` Q. What did you do education-wise after your --
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`did you obtain any additional education, formal
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`education, beyond your undergraduate degree?
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` A. No formal degrees, no.
`
` Q. After you graduated in 1995 --
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` A. Um hum.
`
` Q. -- what did you do next?
`
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`Page 13
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`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
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`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
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` A. Began a professional career as mechanical
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`engineer mainly, a little bit of material science as
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`well, but mainly mechanical.
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` Q. For what company?
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` A. Place is called R-O-C-K-S-H-O-X. It's a
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`bicycle suspension company.
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` Q. And what was your position there?
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` A. Engineer. I don't remember the exact title.
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`But I worked as an engineer primarily in design and
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`fatigue testing.
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` Q. So what were your primary responsibilities?
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` A. I designed mechanical elements, bicycle
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`suspension, then testing of them, for endurance, life
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`diagrams, things like that.
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` Q. No medical devices involved in your work there?
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` A. No.
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` Q. And when did you leave?
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` A. I would need my resume to get the exact year.
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`I believe somewhere in '97.
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` Q. And what did you do next?
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` A. I went to a firm, clots roll screening,
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`C-H-O-L-E-S-T-E-C-H.
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` Q. Sorry, continue.
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` A. I have a desktop device which screens clots
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`roll, triglycerides, things like that.
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` Q. Nothing having to do with medical devices
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`inserted into the body?
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` A. No, that was all external, blood draw.
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` Q. And when did you leave Cholestech?
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` A. You're really testing my memory on dates.
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`Would have been around '99, possibly -- no, 99 -- 98,
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`99.
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` Q. And where did you work next?
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` A. Therasense, T-H-E-R-A-S-E-N-S-E.
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` Q. And what did you do finish Therasense?
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` A. Design medical elements, connecters, interfaces
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`for human use of like LCDs, things like that, buttons.
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` Q. What was your job title there?
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` A. Engineer. Again, I don't remember the exact
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`level, probably senior, probably something to that
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`effect at that point.
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` Q. Again, there were no medical devices inserted
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`into the human body?
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` A. No, that, again, was blood draw.
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` Q. And when did you leave Therasense?
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` A. 2001 or -- yeah, 2001.
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` Q. After Therasense, where were you employed?
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` A. Pacific Consultants.
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` Q. Pacific?
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` A. Yeah, Pacific.
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` Q. What did you do for Pacific Consultants?
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` A. Designed medical device in terms of -- whole
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`gamut of things. It was a consulting group. So
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`everything from large desktop devices to spinal implants
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`to stents, of course. They were kind of one of the
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`world leaders in FEA of stents at the time.
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`(Reporter clarification.)
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` Q. And other than stents, and spinal implants,
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`were there any other medical devices that were inserted
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`into the human body that you worked on while you were at
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`Pacific?
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` A. I'm sure there was. I can't remember what.
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`You know. Over the years, we would design something new
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`about every two months, so there was a large, large
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`array of items that we designed.
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` Q. Did you work on stent grafts while you were
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`there?
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` A. I -- a couple of dual devices, but not a stent
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`graft, mainly stents.
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` Q. And what were your job responsibilities
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`involving stents? What did you do?
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` A. Um hum. Design heart valves service as well,
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`was another big project we had. Design of the
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`mechanical frame of the implant, and then delivery
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`systems for it.
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` Q. So you designed the structural characteristics
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`of the frame itself of the stent?
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` A. Yeah.
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` Q. Okay. Did you do analysis of the stent as
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`well?
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` A. No. That was done by another group.
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` Q. So primarily design?
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` A. Yeah.
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` Q. Were there any anchors or -- for fixation of
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`the stent within the blood vessel at the devices you
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`worked on?
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` A. Yes.
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` Q. Did you work on those aspects of the stent?
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` A. Absolutely.
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` Q. What did you do with regard to the anchors for
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`fixation?
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` A. What did I do --
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` Q. What type of work did you do on the anchors?
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` A. So inherent in the design of the anchor is the
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`side and load-bearing capabilities. So all the
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`geometry. And then working with the FEA to work out the
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`appropriate loads and load-carrying capabilities.
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` Q. And did you ever study the penetration -- the
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`effects of the penetration of the anchors into the
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`vessel wall?
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` A. Not directly. As a consulting group, we would
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`provide designs and then typically the company we were
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`consulting do would do the testing.
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` Q. Did you ever study any effects of fluid flow or
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`blood flowing through the stent graft on the stent and
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`the anchors?
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` A. Mainly stents and heart valves absolutely,
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`because it's absolutely inherent. Blood flow causes all
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`the forces that act on the valve, or --
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` Q. What about for stents?
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` A. For stents, it's always a concern for
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`migration. But in terms of load-carrying capabilities,
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`migrational loads, there's others, but mainly
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`migrational.
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` Q. Not penetration?
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` A. Not for a stent, no.
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` Q. When you say "load-carrying," are you talking
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`about how much it can -- anchors can with stand -- how
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`much load anchors can withstand before they deform or
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`break?
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` A. Inherent in anchor design, yes, you want to
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`make sure that it's not going to break, but then also
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`carrying the load into the structure in a proper manner.
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`There's many factors.
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` Q. And did you -- strike that.
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` What did you do -- when did you leave Pacific?
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` A. 2003.
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` Q. And what did you do after that?
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` A. Started employment at Medtronic.
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` Q. And what was the full name of the entity at
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`Medtronic that you worked for?
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` A. Medtronic, Inc.
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` Q. And what was your role when you started at
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`Medtronic?
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` A. Engineer, again, mechanical engineer, so R&D
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`engineering would be the proper title.
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` Q. And what were the -- what were your job
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`responsibilities?
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` A. So in terms of engineering, my job
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`responsibilities, primarily at that time was stent
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`design.
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` Q. What aspects of the stent?
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` A. All.
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` Q. Stent or stent graft?
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` A. Stent. Yeah.
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` Q. What product was that?
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` A. That's the complete SE.
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` Q. Did that product have any anchors --
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` MR. BARUFKA: Objection, relevance.
`
`///
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`BY MR. PINKUS:
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` Q. -- for engagement with the vessel wall?
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` A. So again, as the rules, when there's objection,
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`do I answer?
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` MR. PINKUS: The only time you can't answer is
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`if he instructs you specifically not to answer, you can
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`answer.
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` A. So then the question was?
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`BY MR. PINKUS:
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` Q. Were there any anchors on that stent that you
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`were working on?
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` A. No anchors on complete SE.
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` Q. Did you transition to another position within
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`Medtronic?
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` A. Yes.
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` Q. What was the title of that position?
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` A. Again, R&D Engineer.
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` Q. And was that a different product you were
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`working on?
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` A. So I guess it's within a different group, so
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`the different groups have different products, but the
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`Complete SE was my primary project before changing, yes.
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` Q. What group were you in when you worked at
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`Complete SE?
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` A. Peripheral group.
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` Q. Then what group did you move to?
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` A. Endovascular.
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` Q. What product did you work on when you were in
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`endovascular?
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` A. Primarily called LowProEbo, L-O-W, Pro is short
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`for Profile, and Ebo, E-B-O.
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` Q. What type of device that?
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` A. That's a stent graft for abdominal aortic
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`aneuryisms.
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` Q. Did you work on any other product at Medtronic?
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` A. Absolutely.
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` Q. Can you name them, please?
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` A. Carotid stents went by a number of different
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`names, but a carotid stent. Of course there's all kinds
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`of overlap with existing products and things and
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`supporting legacy products so really there's too many to
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`list. But -- then some of our pipeline, I don't know if
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`we're free to divulge our pipelines.
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` Q. Did you work on any other stent grafts?
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` A. Yes.
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` Q. Can you name them?
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` MR. BARUFKA: Objection, relevance.
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` A. By name, we have -- I don't know if our
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`internal trade names are going to make any sense.
`
`///
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`BY MR. PINKUS:
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` Q. Let's start with commercial products?
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` A. No commercial products. Our bicycles were too
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`long.
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` Q. Did any of those stents have anchors that
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`engaged with the vessel wall?
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` A. Yes.
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` Q. Could you name them, please?
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` MR. BARUFKA: Objection, relevance.
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` A. LowProEbo.
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`BY MR. PINKUS:
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` Q. That's the only one?
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` A. Yeah.
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` Q. Are you still in that same position at
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`Medtronic now?
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` A. Yeah.
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` Q. I'm sorry, did you say -- were there any
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`devices, while you were working at Medtronic, that had
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`anchors that engaged with the vessel wall that you
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`worked on?
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` A. Yes.
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` Q. Which one was that again?
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` A. The LowProEbo.
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` Q. When you were studying -- when you worked on
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`that product with the anchors, what was your -- what
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`were your job responsibilities?
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` A. I was a stent designer for that program.
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` Q. And what aspects of the stent did you work on?
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` A. All.
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` Q. All? You worked on the anchors?
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` A. Yes.
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` Q. And what capacity, what were you working on in
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`particular?
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` A. The entire design.
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` Q. I mean of the anchor, what in particular of the
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`anchors were you working on the design for?
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` MR. BARUFKA: Objection, form.
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` A. Yeah, so when I say "all," the entire design;
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`so every aspect of the design I was responsible for.
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`BY MR. PINKUS:
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` Q. And did you study the force applied by the
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`stent itself on the anchors?
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` A. Yes.
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` MR. BARUFKA: Objection, relevance.
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` A. Yes.
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`BY MR. PINKUS:
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` Q. So the stent applies an outward radial force
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`correct?
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` MR. BARUFKA: Objection, relevance.
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` MR. PINKUS: Let me rephrase that.
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`BY MR. PINKUS:
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` Q. Was that stent a self-expanding stent or
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`balloon-expandable stent?
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` A. Yes. Self-expanding.
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`(Reporter clarification.)
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`BY MR. PINKUS:
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` Q. So a self-expanding stent such as you were
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`working on, that experts an downward radial force when
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`it expands, correct?
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` A. Yes, a self-expanding stent exerts an outward
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`force.
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`BY MR. PINKUS:
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` Q. So when it expands, it contacts the vessel
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`wall --
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` MR. BARUFKA: Objection, relevance.
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`BY MR. PINKUS:
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` Q. -- it pushes the anchors into the vessel wall,
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`correct?
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` A. It can, depending -- it can, depending on the
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`design.
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` Q. When might it not?
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` A. All factors of sizing and material properties,
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`geometry. It's very complex small structure.
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` Q. So let's focus on geometry.
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` A. Um hum.
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` Q. So what might -- what in the geometry might
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`allow for an anchor to penetrate the vessel wall upon
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`expansion of the stent?
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` A. So clearly, and most important, function if
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`something's going to puncture it's going to be the
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`sharpness.
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` Q. Anything else?
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` A. It's two factors that cause anything to
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`puncture, going to be the sharpness and the amount of
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`force that it's driven with.
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` Q. And when you're talking about force are you
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`talking about the radial force?
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` A. For a stent, one of the items that causes force
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`on an anchor is the radial force.
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` Q. Is there any other items that cause force on
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`the anchor?
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` A. In terms of the stent alone, it's primarily the
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`stent's radial force but you also have all the
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`interaction with the human body I'm assuming.
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` Q. What do you mean by interaction with the human
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`body?
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` A. Interaction with the vessel, interaction with
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`anything that's dynamic within that vessel.
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` Q. Such as the pulsation of the vessel?
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` A. Pulsation of the vessel caused by blood flow.
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` Q. So did you study the effects of the blood flow
`
`on the anchors?
`
` A. Yes.
`
` Q. In what aspect? What respect?
`
` A. It's critical for understanding the durability
`
`of the device.
`
` Q. Did you examine the forces that the blood flow
`
`provide on the anchors?
`
` A. Yes.
`
` Q. And in what respect did you study that?
`
` MR. BARUFKA: Objection, form.
`
` A. So it's important to understand the blood flow
`
`forces on the stent graft so that the forces of the
`
`stent graft or a known design for appropriate levels.
`
`BY MR. PINKUS:
`
` Q. This is primarily again for stresses, failures,
`
`breakage, things like that?
`
` A. Stresses, failures, regulatory submission.
`
` Q. Did you look at all at the penetration -- the
`
`depth of penetration of those anchors from the fluid
`
`flow forces?
`
` A. We looked at depth of penetration, but through
`
`surrogate forces.
`
` Q. What do you mean by surrogate forces?
`
` A. It's difficult on a test bench to get someone
`
`Alderson Reporting Company
`1-800-FOR-DEPO
`
` XXXXXXXXXXXXXXXXXXXXXXXX
`
`Page 26
`
`IPR2014-00100 Pat. Owner Ex. 2023
`Medtronic v. Marital Deduction Trust
`
`
`
`Travis Rowe
`
`SUBJECT TO PROTECTIVE ORDER
`San Francisco, CA
`
`June 26, 2014
`
`Page 27
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`to sign up for implantation. So we test in all kinds of
`
`surrogate ways. So we approximate those forces.
`
` Q. Could you explain one type of test or the type
`
`of test you would have done to approximate those forces.
`
` A. Typically we would present the anchors to
`
`bovine tissue. Bovine tissue is readily available. And
`
`the normal forces would be applied and calculated.
`
` Q. How would you approximate the fluid flow
`
`forces?
`
` A. There's all -- a bevy of equations. It's a
`
`pressure flow, so it's easy to calculate.
`
` Q. Then you examined the depth of the penetration
`
`of those barbs from the fluid flow forces?
`
` A. Yes, yes.
`
` Q. And you were able to distinguish the fluid flow
`
`forces from the forces acting on the anchors from the
`
`stent itself?
`
` A. So again, those fluid flow forces are simulated
`
`because we can't, again, implant in humans until after
`
`trials are approved, things like that. So those
`
`simulated forces -- I'm sorry, repeat the question?
`
` Q. So you're able to distinguish the fluid flow
`
`forces from the forces acting on the anchors from the
`
`stent itself?
`
` A. So, being that they're simulated, the forces
`
`Alderson Reporting Company
`1-800-FOR-DEPO
`
` XXXXXXXXXXXXXXXXXXXXXXXX
`
`Page
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