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`** HIGHLY CONFIDENTIAL **
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TENNESSEE
`GREENEVILLE DIVISION
`Civil Action No. 2:14-CV-00196
`----------------------------~------x
`DENTSPLY INTERNATIONAL, INC. and TULSA
`DENTAL PRODUCTS LLC d/b/a TULSA DENTAL
`SPECIALTIES,
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`Plaintiffs,
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`- against
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`US ENDODONTICS, LLC,
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`Defendant.
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`-----------------------------------x
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`September 19, 2014
`9:24 a.m.
`
`Videotaped Deposition of BOBBY
`BENNETT, taken by Plaintiffs, pursuant to
`Notice, held at the offices of Kenyon &
`Kenyon LLP, One Broadway, New York, New
`York, before Todd DeSimone, a Registered
`Professional Reporter and Notary Public of
`the State of New York.
`
`GOLD STANDARD EXHffiiT 2014
`US ENDODONTICS v. GOLD STANDARD
`CASE IPR2015-01476
`
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`VERITEXT REPORTING COMPANY
`Case21:1-i!t't"-~l96-JRG-DHI Docume~6Y!rit~~'d'i2112/14 Page 2 of 74 ~8rAAbiP.00
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`Page 60
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`BENNETT
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`- HIGHLY CONFIDENTIAL
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`that we manufacture is important to our
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`business. All of them have a nice revenue
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`stream, so yeah, they are all important.
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`Q.
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`Are there any other products
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`that US Endo sells that are as profitable
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`as the EdgeFiles?
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`-Are there any other products
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`A.
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`Q.
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`that US Endo sells that are responsible
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`for as much revenue as EdgeFiles?
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`A.
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`I'm not sure.
`
`I'm not sure.
`
`I
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`it.
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`Q.
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`Do you consider the EdgeFiles
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`to be a successful product?
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`A.
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`Q.
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`Yes.
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`So have you received positive
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`feedback from Edge Endo regarding the
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`A.
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`Q.
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`No,
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`I can't say that I have.
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`So what makes you think of the
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`23 EdgeFiles as a successful product?
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`A.
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`Because of the testing that we
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`conducted on them.
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`VERITEXT REPORTING COMPANY
`www. veri text. com
`516-608-2400
`212-267-6868
`Case 2:14-cv-00196-JRG-DHI Document 156-1 Filed 12/12/14 Page 16 of 74 PageID #:
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`1
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`BENNETT
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`- HIGHLY CONFIDENTIAL
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`length EdgeFiles X3s on page 2 of Bennett
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`3 Exhibit 4, do you recall approximately how
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`Page 98
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`long those were heat-treated by US Endo?
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`A.
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`You know, I'm not confident on
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`the first few sizes. On the -- from the
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`size 30 up, on the 30 and the 40,
`that is I
`the same thing for the 25 and 29
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`heat treatment.
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`I know
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`It is
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`10 millimeter.
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`11
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`Q.
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`So all of the 25 millimeter
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`12 EdgeFile X3s and 29 millimeter EdgeFile
`13 X3s are heated for 1111 hours; is that
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`right?
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`A.
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`Q.
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`No, that's not correct.
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`Sorry, are you referring to
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`just the size 30 and 40s?
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`A.
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`Q.
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`Correct.
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`For the other sizes of the 21,
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`25 and 29 millimeter EdgeFile X3s, do you
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`recall how long those are heated?
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`A.
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`I don't, not with detail.
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`I
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`could be off on those.
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`Q.
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`What different durations does
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`US Endo use for the heat treatment step?
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`VERITEXT REPORTING COMPANY
`212-267-6868
`www.veritext.com
`516-608-2400
`Case 2:14-cv-00196-JRG-DHI Document 156-1 Filed 12/12/14 Page 32 of 74 PageID #:
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`BENNETT - HIGHLY CONFIDENTIAL
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`Page 99
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`A.
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`· - - - · - -
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`------
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`And that's where my confusion
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`is coming in at these first two.
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`I can't
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`recall specifically if they are at -
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`-
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`•
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`-
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`because i t is typically
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`based off of diameter, what I've seen
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`anyhow, and those are too close for me to
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`speculate without looking at something.
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`Q.
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`Do you have any documentation
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`that details the duration of the heat
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`treatment process that US Endo uses for
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`these particular size EdgeFile X3s that
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`are reflected in Bennett Exhibit 4 on
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`pages 2 and 3?
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`A.
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`Q.
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`I do.
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`And you would be able to look
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`at that documentation regarding the
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`duration of heat treatment to figure out
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`how long they were heated?
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`A.
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`Q.
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`Yes.
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`But right now it's your
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`understanding that it is either -- excuse
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`VERITEXT REPORTING COMPANY
`www.veritext.com
`516-608-2400
`212-267-6868
`Case 2:14-cv-00196-JRG-DHI Document 156-1 Filed 12/12/14 Page 33 of 74 PageID #:
` 5139
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