`
`I, David Lorenz, affirn1 and declare as follow·s:
`
`1.
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`I an1 the Vice President of Operations at Kowalski Heat Treating ("Kowalski"), an ISO
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`900 1 :2008 Without Design certified company located in Cleveland, Ohio.
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`2. On January 15, 2016, I submitted a signed Certification for Rothwell, Figg, En1st &
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`Manbeck P.C. regarding a heat treatment process conducted on endodontic files by Kowalski. A
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`copy of that Cetiification is attached to this declaration as Exhibit A.
`
`3.
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`I have been informed that an objection has been lodged against the signed Certification
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`for lack of authentication.
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`4. Rothwell, Figg, Etnst & Manbeck P.C. retained Kowalski to conduct heat treatn1ent on
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`satnples of endodontic files in accordance with a procedure described in an article by Kuhn eta!.,
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`Journal of Endodontics 2000, 28(1 0), 716~ 720.
`
`5. Kowalski received endodontic files from Rothwell, Figg, Ernst & Manbeck P.C., which
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`were identified by the packaging as ProFile .04 Taper, Nickel Titaniun1 Rotary Instrutnents, Size
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`20, 25 n1n1, Part No. PIT042025. The endodontic files were atmealed by in1n1ersing then1 in a
`
`,,
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`tnolten salt bath at 752oF ( 400°C) ± 5oF for 10 n1inutes and subsequently water quenched at
`
`roon1 ten1perature.
`
`6. After heat treatment, the endodontic files were re-packaged and two packages of the
`
`files -vvere sent to Knight Mechanical Testing in Fort Wayne, Indiana.
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`correct.
`
`GOLD STANDARD
`SUBSTITUTE EXHIBIT 2051
`US ENDODONTICS v. GOLD STANDARD
`CASE IPR2015-00632
`
`
`
`Declaration of David Lorenz Page 1 2
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`8.
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`The signed Certification attached as Exhibit A was prepared in the course of the
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`regularly conducted business of Kowalski, at the time the heat treatment was conducted, based
`
`on my personal knowledge.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on February /~ 2016
`
`David Lorenz / t1 P c .P Of'Q2.;muJ
`t.J!CTp-t.t.- vR.c; I) r
`
`
`
`
`
`Exhibit A
`
`Exhibit A
`
`
`
`
`
`
`
`Kowalski Heat Treating Company
`
`A FAMILY BUSINESS FROM THE PAST AND FOR THE FUTURE
`
`Certification
`
`Prepared For:
`
`Today 's Date
`
`Friday, January 15, 2016
`
`ROTHWELL, FIGG, ERNST & MA
`607 14th Street, N
`WASHINGTON
`
`20005
`
`DC
`
`Part Number: r T042025
`
`lcert Parameter: II Process
`ICert Description: II Other
`
`KHTNumber:
`
`261556
`
`OrderDate: 1/13/2016
`
`Purchase Order Number:
`J Nolan
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`Quantity: 24
`
`Weight:
`
`1
`
`Processed per the following specifications:
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`The above stated parts were annealed by immersing them in a molten salt bath at (400 C) 752 F +- 5 F for 10
`minutes and subsequently water quenched. Process instructions were supplied by Jason Nolan.
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`Inspection Results: Process Complete
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`Required Hardness:
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`RC
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`Actual: Process Complete
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`Number of pieces inspected:
`
`Inspected by:
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`dml
`
`0
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`Approved by:~ L-
`
`Title:
`
`Date:
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`Friday, January 15, 2016
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`361 1 Detroit Avenue Cleveland, Ohio 44113
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`Phone (216) 631-4411 Fax (216) 631-8921
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`O.C. T.A. • 2000 Cerri(icatJml Form
`
`!'age 2 o/2
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