IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`
`C.A. No. 12-cv-01791 GMS
`
`
`LIFEPORT SCIENCES LLC,
`
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`v.
`
`
`
`
`ENDOLOGIX, INC.,
`
`
`
`
`
`
`
`
`PLAINTIFF’S DISCLOSURE OF INITIAL CLAIM CHARTS
`UNDER DEFAULT STANDARD FOR DISCOVERY 4(c)
`
`Under Paragraph 4(c) of the Default Standard for Discovery, Including Discovery of
`
`Electronically Stored Information (“ESI”) (“Default Standard”), Plaintiff LifePort Sciences LLC
`
`(“LifePort”) hereby serves its initial claim charts on Defendant Endologix, Inc. relating the
`
`accused products to the asserted claims.
`
`Pursuant to Paragraph 4(c) of the Default Standard, the claim charts are “initial claim
`
`charts” only, and Plaintiff “shall be permitted to supplement.” Default Standard, footnote 3.
`
`Supplementation will also be necessary because the production of the “core technical
`
`documents” by Defendant pursuant to Paragraph 4(b) of the Default Standard was made only on
`
`August 11, 2014. This production includes over 80,000 documents comprising over 580,000
`
`pages, and Plaintiff has not yet had an adequate opportunity to fully review them. Moreover,
`
`discovery has just begun and Defendant may be obligated to produce a large number of
`
`additional technical documents in response to Plaintiff’s document requests. Accordingly, the
`
`initial claim charts are based on information presently known to Plaintiff.
`
`001
`
`

`
`Plaintiff reserves its right to serve supplemental claim charts asserting additional grounds
`
`for infringement by the accused products in view of Defendant’s supplemental productions of
`
`technical documents.
`
`Attached hereto are the following initial claim charts:
`
` Ex. A, U.S. Patent No. 6,302,906, Claim Chart For Endologix AFX
`
` Ex. B, U.S. Patent No. 6,302,906 Claim Chart For Endologix IntuiTrak
`
` Ex. C, U.S. Patent No. 8,192,482 Claim Chart For Endologix AFX
`
` Ex. D, U.S. Patent No. 8,192,482 Claim Chart For Endologix IntuiTrak
`
` Ex. E, U.S. Patent No. 6,117,167 Claim Chart For Endologix AFX
`
` Ex. F, U.S. Patent No. 6,117,167 Claim Chart For Endologix Intuitrak
`
` Ex. G, U.S. Patent No. 5,676,696 Claim Chart For Endologix AFX
`
` Ex. H, U.S. Patent No. 5,676,696 Claim Chart For Endologix IntuiTrak
`
` Ex. I, U.S. Patent No. 5,993,481 Claim Chart For Endologix AFX
`
` Ex. J, U.S. Patent No. 5,993,481 Claim Chart For Endologix IntuiTrak
`
` Ex. K, U.S. Patent No. 5,489,295 Claim Chart For Endologix AFX
`
` Ex. L, U.S. Patent No. 5,489,295 Claim Chart For Endologix IntuiTrak
`
`Plaintiff also incorporates by reference all infringement contentions in its Complaint,
`
`including amendments, and its identification of accused products pursuant to Paragraph 4(a) of
`
`the Default Standard. In addition, while each claim chart is intended to be complete and stand on
`
`its own, to the extent that other claim charts provide additional explanation or context, that
`
`material is deemed to be incorporated.
`
`Page 2 of 5
`
`002
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`

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`These infringement charts have been prepared without the benefit of a claim construction
`
`order from the Court. By providing the attached claim charts, Plaintiff does not intend to proffer
`
`or imply particular claim constructions. Instead, in accordance with the Court’s Scheduling
`
`Order, Plaintiff will disclose its claim constructions for any disputed terms in accordance with
`
`the Scheduling Order. Similarly, Plaintiff does not admit or imply that any claim preambles are,
`
`or are not, limiting on the scope of the claims. Further, Plaintiff does not admit or concede that
`
`every fact, detail or citation in its charts is necessary in order to prove infringement.
`
`Some of the infringement charts relate certain claim limitations to products or product
`
`configurations that are available in multiple sizes. For the sake of clarity and simplicity, only
`
`one size of a particular product or product configuration is generally cited in the claim charts.
`
`However, such contentions apply equally to all sizes of like products and product configurations.
`
`Plaintiff reserves the right to rely upon or cite to additional evidence respecting various product
`
`sizes to prove its infringement case.
`
`For the convenience of the parties, Plaintiff is concurrently producing many of the
`
`documents cited or mentioned in the attached infringement charts. Such documents are also
`
`publicly available.
`
`Plaintiff contends that each element of each asserted claim of the patents-in-suit is
`
`literally present in the accused instrumentalities. In the alternative, Plaintiff contends that any
`
`limitation not found to be literally present in an accused instrumentality is present under the
`
`doctrine of equivalents in that it is assembled or operates to perform substantially the same
`
`function, in substantially the same way, to create substantially the same result. Plaintiff
`
`expressly reserves the right to modify or amend these claim charts to include more detailed
`
`doctrine of equivalents contentions after further technical discovery from Defendant and/or third
`
`Page 3 of 5
`
`003
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`

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`parties, or if the Court’s claim construction order arguably limits or precludes any of the literal
`
`infringement theories currently set forth in Plaintiff’s claim charts.
`
`To the extent that a Defendant’s agent or vendor performs a step, or a portion of a step, in
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`a claimed method as described in the attached claim charts, Plaintiff contends that the agent or
`
`vendor does so under the control or direction of Defendant, and that the agent’s or vendor’s
`
`actions are attributable to Defendant for the purposes of determining Defendant’s liability for
`
`infringement of the Patents in Suit. Alternatively, Plaintiff contends that Defendant induces third
`
`parties to perform certain steps in its infringing operations.
`
`DATED:
`
`Sep. 10, 2014
`
`Respectfully submitted,
`
`
`
`DECHERT LLP
`
`
`
`
`
`/s/ Derek J. Brader
`Joseph J. Farnan, III (Bar No. 3945)
`Brian E. Farnan (Bar No. 4089)
`919 North Market Street, 12th Floor
`Wilmington, Delaware 19801
`(302) 777-0300
`(302) 777-0301 (Fax)
`bfarnan@farnanlaw.com
`
`Philip C. Ducker (pro hac vice)
`Dechert LLP
`2440 W. El Camino Real Suite 700
`Mountain View, CA 94040-1499
`Tel. (650) 813-4800
`Fax (650) 813-4848
`
`Derek J. Brader (pro hac vice)
`Dechert LLP
`Cira Centre
`2929 Arch Street
`Philadelphia, PA 19104-2808
`Tel. (215) 994-4000
`Fax (215) 994-2222
`
`OF COUNSEL:
`Martin J. Black—LEAD ATTORNEY
`Kevin M. Flannery
`
`Page 4 of 5
`
`004
`
`

`
`Dechert LLP
`Cira Centre
`2929 Arch Street
`Philadelphia, PA 19104-2808
`Tel. (215) 994-4000
`martin.black@dechert.com
`kevin.flannery@dechert.com
`
`Counsel for Plaintiff LifePort Sciences LLC
`
`
`
`Page 5 of 5
`
`005
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`

`
`EXHIBIT C - U.S. PATENT NO. 8,192,482 (GOICOECHEA)
`
`CLAIM CHART FOR ENDOLOGIX AFX
`
`1.
`
`1a
`
`1b
`
`Claim 1
`
`1. A stent
`comprising:
`
`a plurality of
`hoops aligned
`along a common
`axis, each of said
`hoops being non-
`helical and oriented
`in a plane
`substantially
`perpendicular to the
`longitudinal axis of
`the stent, and
`
`Claim 1
`“The AFX Endovascular AAA Delivery System is indicated for
`endovascular treatment in patients with AAA using a surgical
`vascular access technique or a bilateral percutaneous technique.”
`(Endologix AFX Endovascular AAA System, Instructions for Use,
`Life-Endologix_000087, at 4 [hereinafter IFU].) The AFX “stent
`graft is composed of a cobalt chromium alloy self-expanding stent
`cage . . . .” (Id.) The “unibody bifurcated stent graft” as well as each
`“extension accessory” stent graft satisfies the elements of this claim.
`The hoops are non-helical, and are aligned along a common axis,
`as shown below.
`
`Common,
`Longitudinal Axis
`
`Hoop orientation
`(perpendicular)
`
`Hoops
`
`(IFU 24 (red annotations added); see also ENDO00031533;
`ENDO00033055; ENDO00031859; ENDO00043117;
`ENDO00220441; ENDO00356321; ENDO00580816.)
`Each of the accessory stents has a similar configuration of hoops,
`as shown below.
`
`Page 1 of 22
`
`006
`
`

`
`Claim 1
`
`(IFU 24.)
`
`(AFX Stent Graft Selection Guide, Life-Endologix_000163, at 1; see
`also ENDO00031533; ENDO00033055; ENDO00031859;
`ENDO00043117; ENDO00220441; ENDO00356321;
`ENDO00580816.)
`Each hoop includes elongate elements joined to form apices that
`point longitudinally, as shown below:
`
`1c
`
`each of said
`hoops including a
`plurality of
`elongate elements
`joined to one
`another and
`forming apices that
`point in a direction
`along the
`longitudinal axis of
`
`Page 2 of 22
`
`007
`
`

`
`the stent, and
`
`Claim 1
`
`Apex
`
`Apex
`Elongate Elements
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration, as shown
`above.
`Endologix marks the AFX system with U.S. Patent No. 6,331,190,
`indicating that it is made under that patent. (See IFU 1.) The ’190
`Patent discloses and claims just this structure.
`
`1d
`
`wherein at least
`one elongate
`element in each
`hoop is a
`continuation of an
`elongate element of
`an adjacent hoop;
`and
`
`’190 Patent Figs. 2, 10.
`
`Page 3 of 22
`
`008
`
`

`
`Claim 1
`
`
`’190 Patent. Figs. 3190 Patent. Figs. 3–6.
`
`
`Claim 1 of the ’190 Patent recites an “endoluminal prosthesis,Claim 1 of the ’190 Patent recites an “endoluminal prosthesis,Claim 1 of the ’190 Patent recites an “endoluminal prosthesis,
`
`
`comprising: a tubular wire support comprising at least first andcomprising: a tubular wire support comprising at least first andcomprising: a tubular wire support comprising at least first and
`
`
`second axiallysecond axially adjacent tubular segments joined by a connectoradjacent tubular segments joined by a connector
`
`
`extending therebetween, wherein the firstextending therebetween, wherein the first and second tubularand second tubular
`
`
`segments and the connector are formed from a single length ofsegments and the connector are formed from a single length ofsegments and the connector are formed from a single length of
`
`
`wire, and wherein each tubular segment comprises a series of, and wherein each tubular segment comprises a series of, and wherein each tubular segment comprises a series of
`
`
`proximal and distal bends, such that each proximal bend in the firstproximal and distal bends, such that each proximal bend in the firstproximal and distal bends, such that each proximal bend in the first
`
`
`tubular segment aligns with a distal bend intubular segment aligns with a distal bend in the second tubularthe second tubular
`
`
`segment to form a joint . . . .” ’190 Patent col. 15 ll. 2segment to form a joint . . . .” ’190 Patent col. 15 ll. 2segment to form a joint . . . .” ’190 Patent col. 15 ll. 2–11 (emphasis
`
`added).added).
`
`
`Each of the accessory stent grafts has a similar configuration, asEach of the accessory stent grafts has a similar configuration, asEach of the accessory stent grafts has a similar configuration, as
`
`shown above.shown above.
`
`
`See alsoSee also ENDO00031533; ENDO00033055; ENDO00031859;ENDO00031533; ENDO00033055; ENDO00031859;
`
`
`ENDO00043117; ENDO002ENDO00043117; ENDO00220441; ENDO00356321;20441; ENDO00356321;
`
`ENDO00580816.ENDO00580816.
`
`
`Endologix marks the AFX system with U.S. Patent No. 6,331,190,Endologix marks the AFX system with U.S. Patent No. 6,331,190,Endologix marks the AFX system with U.S. Patent No. 6,331,190,
`
`
`indicating that it is made under that patent. (indicating that it is made under that patent. (See IFU 1.)IFU 1.) The ’190
`
`
`Patent discloses and claims an “eye” at each joint between adjacentPatent discloses and claims an “eye” at each joint between adjacentPatent discloses and claims an “eye” at each joint between adjacent
`
`
`hoops, which is the same as or equivalent to the securing meanshoops, which is the same as or equivalent to the securing meanshoops, which is the same as or equivalent to the securing means
`
`
`disclosed in the 482 Patent.disclosed in the 482 Patent. See ’190 Patent col. 15 l. 12 (“wherein’190 Patent col. 15 l. 12 (“wherein
`
`Page 4 of 22
`
`1e
`
`means for
`securing an apex of
`one hoop to an
`abutting a
`juxtaposed apex of
`
`009
`
`

`
`a neighboring hoop.
`
`Claim 1
`each joint includes an eye.”).
`Each of the accessory stent grafts has a similar configuration as
`shown above.
`
`2.
`
`Claim 2
`
`2. A stent as
`recited in claim 1
`comprising at least
`one stent segment
`in combination
`with one or more
`additional stent
`segments.
`
`Claim 2
`Each stent comprises at least one segment and at least one additional
`segment, as shown below.
`
`Segment
`
`Additional
`Segments
`
`(IFU 24 (red annotations added).)
`
`Page 5 of 22
`
`010
`
`

`
`Claim 2
`
`Additional
`Segments
`
`Segment
`
`Additional
`Segments
`
`Segment
`
`(IFU 24 (red annotations added).)
`Segments and additional segments are similar in the Vela proximal
`extension.
`
`3.
`
`Claim 3
`
`3. A stent as
`recited in claim 2
`wherein said one or
`more additional
`segments are
`axially aligned with
`one another.
`
`Claim 3
`Each of the stents includes axially aligned additional segments.
`For the bifurcated stent grafts, the additional segments’ axes can be,
`and sometimes are, aligned. As shown below, the additional segments are
`not aligned, but the flexible stent graft can be, and sometimes is,
`repositioned so that they are aligned.
`
`Page 6 of 22
`
`011
`
`

`
`Claim 3
`
`(IFU 24 (red annotations added).)
`For the extension stent grafts, the additional segments are coaxial, as
`shown below with the axes drawn in red.
`
`(IFU 24 (red annotations added).)
`The Vela proximal extension is similarly coaxial.
`
`Page 7 of 22
`
`012
`
`

`
`Claim 4
`The stepped iliac limb extension includes two axially aligned additional
`segments, as explained above respecting claim 3. Those segments are
`connected to one another by a tubular fabric element, as shown below.
`
`Tubular fabric
`element
`
`(IFU 24 (red annotations added); see also ENDO00356321.)
`
`Claim 5
`As explained above in row 1e, the identified stent grafts use “means for
`securing” to connect apices of adjacent hoops. See 1e. The “connecting
`means” of this claim are the same as the “means for securing” of claim 1,
`and the same eyes, discussed above in 1e, are used between the stent
`segments and additional segments.
`
`4.
`
`Claim 4
`
`4. A stent as
`recited in claim 3
`wherein said
`axially aligned
`segments are
`connected to one
`another by a tubular
`fabric element.
`
`5.
`
`Claim 5
`
`5. A stent as
`recited in claim 2
`wherein said one or
`more additional
`segments are
`secured to one
`another by
`connecting means
`connecting at least
`some of the apices
`of hoops at mating
`ends of said stent
`and said additional
`segments.
`
`Page 8 of 22
`
`013
`
`

`
`6.
`
`Claim 6
`
`6. A stent as
`recited in claim 2
`wherein adjacent
`hoops are of the
`same diameter.
`
`Claim 6
`Each stent identified above in 1a include hoops of the same diameter,
`as shown below.
`
`Same diameter
`
`Same diameter
`
`(IFU 24 (red annotations added).)
`
`Same diameter
`
`Same diameter
`
`(IFU 24 (red annotations added).)
`The Vela proximal extension includes similar structures.
`
`Page 9 of 22
`
`014
`
`

`
`7.
`
`Claim 7
`
`7. A stent as
`recited in claim 2
`wherein adjacent
`hoops are of a
`different diameter.
`
`Claim 7
`The bifurcated, tapered, flared, and stepped stents use adjacent hoops of
`different diameters, as shown below.
`
`Different
`diameters
`
`(IFU 24 (red annotations added).)
`
`Different diameters
`
`Page 10 of 22
`
`015
`
`

`
`8.
`
`Claim 8
`
`8. A stent as
`recited in claim 2
`wherein a first
`additional segment
`is axially parallel
`to, but non-
`common co-axial
`with, said stent
`segment.
`
`9.
`
`Claim 9
`
`9. A stent as
`recited in claim 8
`further comprising
`a second additional
`segment axially
`parallel to said stent
`segment, but non-
`co-axial with either
`said stent segment
`or said first
`additional stent
`
`Claim 7
`(IFU 24 (red annotations added).)
`
`Claim 8
`Each additional segment of the bifurcated stent graft can be, and
`sometimes is, axially parallel to, but non-coaxial with, the stent segment.
`
`Segment axis
`
`First additional
`segment axis
`
`(IFU 24 (red annotations added).)
`
`Claim 9
`Each additional segment of the bifurcated stent graft can be, and
`sometimes is, axially parallel to, but non-coaxial with, the stent segment
`and with the other additional segment.
`
`Page 11 of 22
`
`016
`
`

`
`segment.
`
`Claim 9
`
`Segment axis
`
`First additional
`segment axis
`
`Second additional
`segment axis
`
`(IFU 24 (red annotations added).)
`
`Claim 12
`See discussion of claim 2 above.
`
`The hoops that form the additional stent segment are aligned along a
`common, longitudinal axis, and each hoop is substantially perpendicular to
`that axis, as shown below.
`
`10.
`
`Claim 12
`
`12. A stent as
`recited in claim 2
`wherein at least one
`of said additional
`stent segments
`comprises:
`a plurality of
`hoops aligned
`along a common
`axis, each of said
`hoops oriented in a
`plane substantially
`perpendicular to the
`longitudinal axis of
`the additional stent
`segment,
`
`Page 12 of 22
`
`017
`
`

`
`Claim 12
`
`Hoops
`
`Longitudinal
`Axis
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration of hoops, as
`shown below.
`
`(IFU 24.)
`
`Page 13 of 22
`
`018
`
`

`
`Claim 12
`
`and each of said
`hoops including a
`plurality of
`elongate elements
`joined to one
`another and
`forming apices that
`point in a direction
`along the
`longitudinal axis of
`the additional stent
`segment; and
`
`means for
`securing an apex of
`one hoop to a
`juxtaposed apex of
`a neighboring hoop.
`
`(AFX Stent Graft Selection Guide, Life-Endologix_000163, at 1; see also
`ENDO00031533; ENDO00033055; ENDO00031859; ENDO00043117;
`ENDO00220441; ENDO00356321; ENDO00580816.)
`Each hoop includes elongate elements joined to form apices that point
`longitudinally, as shown below:
`
`Vertex
`Elongate
`Elements
`
`Vertex
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration, as shown
`above.
`Abutting vertices are connected by “means for securing,” as shown
`below. Means for securing are discussed above in 1e.
`
`Page 14 of 22
`
`019
`
`

`
`Claim 12
`
`Means for
`securing
`
`(IFU 24 (red annotations added); see also ENDO00031533;
`ENDO00033055; ENDO00031859; ENDO00043117; ENDO00220441;
`ENDO00356321; ENDO00580816.)
`Each of the accessory stents has a similar configuration, as shown above.
`
`Claim 13
`“The main body and each iliac leg are constructed from a single wire.”
`(IFU 4; see also ENDO00031533; ENDO00033055; ENDO00031859;
`ENDO00043117; ENDO00220441; ENDO00356321; ENDO00580816.)
`
`Claim 21
`Each longitudinal end is substantially perpendicular square to the
`longitudinal axis as shown below.
`
`Page 15 of 22
`
`11.
`
`Claim 13
`
`13. An
`endoluminal stent
`as claimed in claim
`1 wherein said
`hoops are formed
`of a single
`continuous wire.
`
`12.
`
`Claim 21
`
`21. An
`endoluminal stent
`as claimed in claim
`1 wherein each
`
`020
`
`

`
`Claim 21
`
`Longitudinal Axis
`
`Longitudinal end
`
`longitudinal end of
`the stent is
`substantially
`perpendicular
`square to the
`longitudinal axis of
`the stent.
`
`Longitudinal end
`
`Longitudinal end
`
`13.
`
`Claim 22
`
`22. An
`endoluminal stent
`as claimed in claim
`1 wherein said stent
`is at least partially
`covered in fabric.
`
`14.
`
`Claim 30
`
`30a
`
`30. A stent
`comprising
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration, as shown
`above.
`
`Claim 22
`“The stent graft is composed of a cobalt chromium alloy self-expanding
`stent cage with a thin-walled, low porosity ePTFE graft cover that is
`attached proximally and distally to the stent cage with polypropylene
`suture.” (IFU 4.)
`
`Claim 30
`“The AFX Endovascular AAA Delivery System is indicated for
`endovascular treatment in patients with AAA using a surgical
`vascular access technique or a bilateral percutaneous technique.”
`(Endologix AFX Endovascular AAA System, Instructions for Use
`4 [hereinafter IFU].) The AFX “stent graft is composed of a cobalt
`chromium alloy self-expanding stent cage . . . .” (Id.) The
`
`Page 16 of 22
`
`021
`
`

`
`Claim 30
`“unibody bifurcated stent graft” as well as each “extension
`accessory” stent graft satisfies the elements of this claim.
`The “unibody bifurcated stent graft” as well as each “extension
`accessory” stent graft is a tubular member. The hoops that form
`the stent are non-helical, and are aligned along the longitudinal
`axis, as shown below.
`
`Longitudinal Axis
`
`30b
`
`a tubular member
`having a plurality of
`hoops aligned
`adjacent one another
`along the
`longitudinal axis of
`said tubular member,
`
`Hoops
`
`(IFU 24 (red annotations added); see also ENDO00031533;
`ENDO00033055; ENDO00031859; ENDO00043117;
`ENDO00220441; ENDO00356321; ENDO00580816.)
`Each of the accessory stents has a similar configuration of
`hoops, as shown below.
`
`Page 17 of 22
`
`022
`
`

`
`Claim 30
`
`(IFU 24.)
`
`(AFX Stent Graft Selection Guide, Life-Endologix_000163, at 1;
`see also ENDO00031533; ENDO00033055; ENDO00031859;
`ENDO00043117; ENDO00220441; ENDO00356321;
`ENDO00580816.)
`Each hoop includes elongate elements joined to form apices that
`point longitudinally, as shown below:
`
`30c
`
`each of said hoops
`comprising a
`plurality of elongate
`elements, with pairs
`of said elongate
`elements meeting
`one another and
`forming vertices
`axially pointing in a
`direction along the
`
`Page 18 of 22
`
`023
`
`

`
`longitudinal axis of
`the stent,
`
`Claim 30
`
`Vertex
`
`Vertex
`Elongate Elements
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration, as
`shown above.
`Abutting vertices are connected, as shown below.
`
`Connection
`
`30d
`
`wherein at least
`some of said vertices
`axially abut and are
`individually
`connected to
`oppositely pointed
`vertices of elongate
`elements of an
`adjacent hoop,
`
`(IFU 24 (red annotations added); see also ENDO00031533;
`
`Page 19 of 22
`
`024
`
`

`
`Claim 30
`ENDO00033055; ENDO00031859; ENDO00043117;
`ENDO00220441; ENDO00356321; ENDO00580816.)
`Each of the accessory stents has a similar configuration, as shown
`above.
`
`30e
`
`wherein the
`vertices of each hoop
`pointed in the axial
`direction lie in a
`common plane
`perpendicular to the
`longitudinal axis of
`the tubular member,
`and
`
`Longitudinal Axis
`
`Common planes
`(perpendicular)
`
`(IFU 24 (red annotations added).)
`Each of the accessory stents has a similar configuration of
`hoops, as shown above.
`Endologix marks the AFX system with U.S. Patent No.
`6,331,190, indicating that it is made under that patent. (See IFU
`1.) The ’190 Patent discloses and claims just this structure.
`
`30f
`
`wherein at least
`one elongate element
`in each hoop is a
`continuation of an
`elongate element of
`an adjacent hoop.
`
`Page 20 of 22
`
`025
`
`

`
`Claim 30
`
`
`
`’190 Patent Figs. 2, 10.’190 Patent Figs. 2, 10.
`
`’190 Patent. Figs. 3’190 Patent. Figs. 3–6.
`
`
`Claim 1 of the ’190 Patent recites an “endoluminal prosthesis,Claim 1 of the ’190 Patent recites an “endoluminal prosthesis,
`
`
`comprising: a tubulcomprising: a tubular wire support comprising at least first andar wire support comprising at least first and
`
`
`second axiallysecond axially adjacent tubular segments joined by a connectoradjacent tubular segments joined by a connector
`
`
`extending therebetween, wherein the first and second tubularextending therebetween, wherein the first and second tubularextending therebetween, wherein the first and second tubular
`
`Page 21 of 22
`
`026
`
`

`
`Claim 30
`segments and the connector are formed from a single length of
`wire, and wherein each tubular segment comprises a series of
`proximal and distal bends, such that each proximal bend in the first
`tubular segment aligns with a distal bend in the second tubular
`segment to form a joint . . . .” ’190 Patent col. 15 ll. 2–11
`(emphasis added).
`Each of the accessory stent grafts has a similar configuration, as
`shown above.
`See also ENDO00031533; ENDO00033055; ENDO00031859;
`ENDO00043117; ENDO00220441; ENDO00356321;
`ENDO00580816.
`
`15278480
`
`Page 22 of 22
`
`027