throbber
RONALD J. SOLAR, Ph.D.
`
` U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
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` B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
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`E D W A R D S L I F E S C I E N C E S )
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`C O R P O R A T I O N , )
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` P e t i t i o n e r , ) C a s e N o . I P R 2 0 1 7 - 0 0 4 4 4
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` v s . ) P a t e n t 6 , 9 1 5 , 5 6 0
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`B O S T O N S C I E N T I F I C )
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`S C I M E D I N C . , )
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` P a t e n t O w n e r . )
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`_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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` D E P O S I T I O N O F R O N A L D J . S O L A R , P h . D .
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` L o s A n g e l e s , C a l i f o r n i a
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` M o n d a y , N o v e m b e r 2 7 , 2 0 1 7
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`R e p o r t e d b y :
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`J A N I C E S C H U T Z M A N
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`C S R N o . 9 5 0 9
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`J O B N o . 2 7 5 8 4 0 8
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`P A G E S 1 - 8 7
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`EDWARDS LIFESCIENCES EX. 1126
`Edwards Lifesciences v. Boston Scientific Scimed
`IPR2017-00444
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`RONALD J. SOLAR, Ph.D.
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`EDWARDS LIFESCIENCES )
`
`CORPORATION, )
`
` Petitioner, ) Case No. IPR2017-00444
`
` vs. ) Patent 6,915,560
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`BOSTON SCIENTIFIC )
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`SCIMED INC., )
`
` Patent Owner. )
`
`----------------------
`
` Deposition of RONALD J. SOLAR, Ph.D.,
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`taken at 777 South Figueroa Street, Los Angeles,
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`California, commencing at 9:06 a.m. and ending at
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`11:41 a.m., Monday, November 27, 2017, before Janice
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`Schutzman, CSR No. 9509.
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`PAGES 1 - 87
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`RONALD J. SOLAR, Ph.D.
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`A P P E A R A N C E S O F C O U N S E L :
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` F O R T H E P E T I T I O N E R :
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` K N O B B E M A R T E N S
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` B Y : C R A I G S . S U M M E R S , E S Q .
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` C H E R Y L T . B U R G E S S , E S Q .
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` 2 0 4 0 M a i n S t r e e t
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` 1 4 t h F l o o r
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` I r v i n e , C a l i f o r n i a 9 2 6 1 4
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` 9 4 9 . 7 6 0 . 0 4 0 4
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` c r a i g . s u m m e r s @ k n o b b e . c o m
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` c h e r y l . b u r g e s s @ k n o b b e . c o m
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` F O R T H E P A T E N T O W N E R :
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` A R N O L D & P O R T E R K A Y E S C H O L E R
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` B Y : W A L L A C E W U , E S Q .
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` 7 7 7 S o u t h F i g u e r o a S t r e e t
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` 4 4 t h F l o o r
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` L o s A n g e l e s , C a l i f o r n i a 9 0 0 1 7 - 5 8 4 4
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` 2 1 3 . 2 4 3 . 4 1 0 4
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` w a l l a c e . w u @ a p k s . c o m
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`RONALD J. SOLAR, Ph.D.
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` INDEX
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`WITNESS EXAMINATION
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`RONALD J. SOLAR, Ph.D.
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` By Mr. Summers 6
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`RONALD J. SOLAR, Ph.D.
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` I D E N T I F I E D E X H I B I T S
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`E x h i b i t 2 0 1 6
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`E x h i b i t 2 0 2 1
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`E x h i b i t 2 0 2 2
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`RONALD J. SOLAR, Ph.D.
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`Los Angeles, California; Monday, November 27, 2017
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` 9:06 a.m.
`
` -- o0o --
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` RONALD J. SOLAR, Ph.D.,
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`the witness, having been administered an oath by the
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`Court Reporter, testified as follows:
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` EXAMINATION
`
`BY MR. SUMMERS:
`
` Q. Good morning.
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` A. Good morning.
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` Q. Please state your full name.
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` A. Ronald J. Solar.
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` Q. Have you been deposed before?
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` A. Yes, I have.
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` Q. How many times?
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` A. Many times.
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` Q. Do you have an idea?
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` A. Actually, in my declaration, I have a list
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`of some of the testimony that I provided, and there
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`are lists of where I was deposed or testified at
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`trial.
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` MR. SUMMERS: This -- show the witness his
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`declaration, which is Exhibit 2016.
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`RONALD J. SOLAR, Ph.D.
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` (Exhibit 2016 was identified.)
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` MR. WU: Thank you.
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` THE WITNESS: Thank you.
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`BY MR. SUMMERS:
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` Q. Dr. Solar, we've just handed you
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`Exhibit 2016.
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` Is this your declaration in this IPR
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`proceeding?
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` A. I'll just quickly thumb through it, but it
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`certainly looks like it is.
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` Q. Is it true that you've been retained to
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`give expert testimony in this IPR proceeding?
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` A. Yes.
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` Q. And you've been retained by Boston
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`Scientific?
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` A. Yes.
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` Q. The patent owner in this case?
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` A. Yes.
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` Q. And is Exhibit 2016 a true and correct copy
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`of the declaration?
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` A. Well, I believe the copy is. I mean, I
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`know the declaration is true --
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` Q. Okay.
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` A. -- but I'm assuming this is just a copy of
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`that, so --
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`RONALD J. SOLAR, Ph.D.
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` Q. Yes.
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` A. -- my answer would be yes.
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` Q. I'll represent to you that it is.
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` A. Okay.
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` Q. So Appendix B, is that a list of your
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`cases?
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` A. Yes, it is.
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` Q. It says these are IP cases; is that right?
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` A. That's correct.
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` Q. And you testified as an expert in other
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`kinds of cases?
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` A. Yes, I have.
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` Q. So this is just a listing of your
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`intellectual property cases in Appendix B; correct?
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` A. That's correct.
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` Q. Did you give a deposition in each of the
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`cases that are listed in Appendix B?
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` A. Only where it's noted in column testimony.
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`So if there's a D in that column, in those cases, I
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`recall giving deposition testimony.
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` Q. Looks like there's about eight or nine
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`cases where you gave a deposition in an IP case.
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` A. Looks like nine or ten. One, I'm not -- I
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`can't recall if I actually was deposed or not.
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` Q. You've also given trial testimony in some
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`RONALD J. SOLAR, Ph.D.
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`of these cases?
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` A. Yes.
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` Q. It appears there's maybe four cases where
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`you've given trial testimony?
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` A. Yes, that's correct.
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` Q. So the last -- was the last time you gave
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`trial testimony in the Medtronic case in 1999/2000?
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` A. For an IP case, yes.
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` Q. And your last deposition in an IP case was
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`in 2008/2009?
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` A. Yes.
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` Q. If you had to tell me how many times you've
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`been deposed in all kinds of cases, how many
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`depositions would you say that is?
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` A. Probably an equal number of non-IP cases.
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`Just trying to recall off the top of my head.
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` Q. Is it fair to say you're fairly familiar
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`with the deposition process and how we're not
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`supposed to talk over each other and we're supposed
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`to wait till each of us has finished asking a
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`question and so forth?
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` Do you understand the deposition basics?
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` A. Yes, I do.
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` Q. Okay. Do I need to go over them with you
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`today?
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` A. I don't believe that's necessary.
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` Q. Okay. How did you come to start consulting
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`or serving as an expert for the patent owner in this
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`IPR proceeding?
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` A. I received a call from a search firm that,
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`I guess, looks for expert witnesses and asked me if
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`I would be interested, if it was a matter that was
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`something that I had expertise in, and from that
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`discussion, it's led to the engagement.
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` Q. What is the name of that search firm?
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` A. Teknicon.
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` Q. When did Teknicon contact you regarding
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`this case?
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` A. I believe it was somewhere in the latter
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`part of 2016.
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` Q. At the time when you were contacted, was
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`Petitioner's IPR petition in this case already
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`filed?
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` A. I'm not sure. It may have been.
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` Q. The IPR petition was filed in December of
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`2016.
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` Do you recall whether it was December of
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`2016 when you were contacted?
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` A. I really don't recall. There was another
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`case they contact me on unrelated to this, and so I
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`don't remember which one was which, which came
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`first.
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` Q. Are you also serving as an expert witness
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`for Boston Scientific in the parallel District Court
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`proceedings that are pending here in California?
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` A. Yes.
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` Q. And are you also serving as --
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` A. It's not in California. I think it's in
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`Delaware.
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` Q. Well, Boston Scientific has filed two cases
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`against Edwards Lifesciences; one is pending in
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`Delaware, the other is pending in California.
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` Were you aware that there was a California
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`case as well?
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` A. Related to this matter, I believe it is,
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`yes.
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` Q. And are you serving as an expert witness
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`for Boston Scientific in that California federal
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`court litigation?
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` A. Yes.
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` Q. Are you also serving as an expert witness
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`for Boston Scientific in the Delaware District Court
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`litigation?
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` A. Yes.
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` Q. What did you do to prepare for your
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`RONALD J. SOLAR, Ph.D.
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`deposition today?
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` A. Reviewed a number of documents and --
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`primarily my deposi- -- my declaration.
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` Q. Did you have a meeting with anyone to
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`prepare for your deposition?
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` A. Yes. I met with counsel.
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` Q. And is that Mr. Wu?
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` A. That's correct.
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` Q. When was that?
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` A. Yesterday.
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` Q. Did you have any other meetings with Mr. Wu
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`besides the meeting yesterday to prepare for your
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`deposition?
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` A. To prepare for this? No.
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` Q. Was anyone else present at the meeting
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`yesterday with Mr. Wu and yourself?
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` A. No.
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` Q. How long did you meet with Mr. Wu to
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`prepare?
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` A. With lunch, it was approximately about four
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`hours.
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` Q. You're aware that the Yasumi patent is the
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`principal reference relied upon by Edwards, the
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`petitioner, in this IPR proceeding; correct?
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` A. Yes.
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` Q. How many hours do you think you spent
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`reviewing and studying the Yasumi reference?
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` A. Quite a number of hours. I don't recall
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`exactly but it was many, many hours.
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` Q. More than 10?
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` A. Yes, I believe so.
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` Q. More than 20?
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` A. I don't know if I spent 20 hours
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`specifically on that reference but it may have been
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`in relation to that reference.
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` Q. About how many hours have you spent in
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`connection with this IPR proceeding as a whole?
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` A. I don't recall exactly, but it was a
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`significant number. It may have been around 50 or
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`more.
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` Q. Let's go over your educational background
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`for a bit.
`
` A. Okay.
`
` Q. Your declaration states that you obtained a
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`bachelor of science degree in metallurgy and
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`material science from Penn State in 1972?
`
` A. Yes.
`
` Q. What is metallurgy and material science?
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`Are those two separate areas of study, or are they
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`one area of study?
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` A. They can be separate. In this case, it was
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`combined because it included study not only of
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`metals, which is metallurgy, and also study of other
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`materials, ceramics, polymers.
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` Q. So what is, you know, metallurgy and
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`material science? What does that entail?
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` A. It's the study of the material themselves,
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`how they behave, how you transform them, what
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`they -- what you use the materials for, how you
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`process them, properties. Anything related to the
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`material, you know, that's the science there.
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` Q. Okay. And your declaration also states
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`that you received a Ph.D. also from -- well, strike
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`that.
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` Your declaration states that you received a
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`Ph.D. in material science and biomaterials from the
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`University of Pennsylvania in 1977; is that correct?
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` A. Yes.
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` Q. And what is the study of material science
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`and biomaterials?
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` A. Well, it's a specific application of
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`material science. So it's a little advanced
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`material science than from undergraduate work, but
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`the application with biomaterials was the
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`application of materials to medical and dental
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`RONALD J. SOLAR, Ph.D.
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`applications. So not only did it include metals,
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`polymers, ceramics as it's applied in medicine, but
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`also studied the properties of biological tissue.
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` Q. So biomaterials would include materials,
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`for example, that would be placed inside the human
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`body?
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` A. Yes.
`
` Q. Please turn to page 10 of your declaration.
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` Are you on page 10?
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` A. Which -- of my page number or the --
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` Q. Yeah, sorry. Your --
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` A. -- document number?
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` Q. Yeah. Let's do this today. When I refer
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`to page number, I'm going to refer to the page
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`number that is in your declaration in the center at
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`the bottom --
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` A. Okay.
`
` Q. -- and not the other number that's in the
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`lower right corner unless I indicate otherwise.
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` Is that okay with you?
`
` A. That's fine, yes.
`
` Q. So we're at page 10 of your declaration.
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`There's a heading Roman numeral V.
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` Do you see that?
`
` A. Yes.
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` Q. Does that heading state or say "State of
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`the Art Before September 22nd, 1999"?
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` A. Yes.
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` Q. What is the purpose of this section in your
`
`declaration?
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` A. Primarily just to provide a little bit of
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`background.
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` Q. Background regarding what?
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` A. The state of the art of stents.
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` Q. Anything else?
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` A. Let's see. What else?
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` Also includes the, you know, generally, the
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`procedure where stents are used. Talks about a
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`little bit of the history of balloon expandable
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`stenting, background.
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` The patent owner had sold a number of
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`different types of balloon expandable stents. Some
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`background relating to the importance of having the
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`stent tightly fitted onto the balloon, why that's
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`important.
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` A little bit of very quick background in
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`one sentence describing the -- one paragraph
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`describing the summary of the '560 patent, what it
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`relates to and then, also in the background, discuss
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`the problem of uneven stent crimping.
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` Q. In paragraph 28 of your declaration, you
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`identify two patents, the '838 patent and the '992
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`patent.
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` Do you see that?
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` A. Yes.
`
` Q. Those are your patents?
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` A. That's correct.
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` Q. Those patents are part of the state of the
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`art before September 22nd, 1999?
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` A. Yes, they were.
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` Q. If you look at page 11 of your declaration,
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`do you see the illustration at the top of the page?
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` A. Yes.
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` Q. What is that illustration?
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` A. That's just an illustration of a
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`percutaneous heart valve with a stent-like frame,
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`which is pretty much a common way of implanting the
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`stent valves.
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` Q. Do you know whose heart valve is
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`illustrated there?
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` A. I'm not sure. It looks like it may be an
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`Edwards valve.
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` Q. When was that?
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` A. I'll have to look closer. Some of them
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`look so similar.
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`RONALD J. SOLAR, Ph.D.
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` Q. When did Edwards first introduce a heart
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`valve of the type shown in the illustration at the
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`top of page 11?
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` A. Introduced commercially or experimentally
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`or first talked about? Could you be more specific
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`of what your question is?
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` Q. What's your earliest information regarding
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`when the heart valve like the type shown at the top
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`of page 11 was known to the public or part of the
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`state of the art?
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` A. I'm not sure if I included that specific
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`information in here. I think I've included that in
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`my declaration, but my recollection was around early
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`2000, 2001, 2002 or so, as I recall.
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` Q. The heart valve that's illustrated at the
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`top of page 11 of your declaration is a
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`transcatheter heart valve, isn't it?
`
` A. Yes.
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` Q. And that wasn't part of the state of the
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`art before September 22nd, 1999, was it?
`
` A. I don't believe so, no.
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` Q. So why is this illustration of an Edwards
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`transcatheter heart valve included in this section
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`of your declaration?
`
` A. There were a number of different types of
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`RONALD J. SOLAR, Ph.D.
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`stent prosthesis, stent grafts, and I figured this
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`would be more relative to this proceeding.
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` Q. Is the Edwards transcatheter heart valve
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`relevant to this IPR proceeding?
`
` A. Yes, it is.
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` Q. How?
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` A. It's the valve that Edwards -- it's the
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`valve with which Edwards sells the crimper in this
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`proceeding is related to.
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` Q. This section of your declaration talks
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`about stents and so forth.
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` Why didn't you include a picture of a
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`garden variety stent --
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` A. I have a --
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` Q. -- in this section?
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` A. I have a picture later on in my declaration
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`of some stent struts and -- you know, for
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`illustrative purposes.
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` Q. Do you describe the Edwards transcatheter
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`heart valve anywhere in this Section 5 of your
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`declaration regarding state of the art before
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`September 22nd, 1999?
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` A. I don't believe I did.
`
` Q. Where?
`
` A. I said I do not -- I'm sorry -- do not
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`RONALD J. SOLAR, Ph.D.
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`believe I did.
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` Q. Thank you.
`
` Please refer to paragraph 28 of your
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`declaration. We talked about this earlier.
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` This paragraph identifies two patents that
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`are your patents; correct?
`
` A. Yes.
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` Q. Both these patents relate to crimpers?
`
` A. That's correct.
`
` Q. Crimpers for stents?
`
` A. Stents, stent grafts, stent prostheses.
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` Q. And one is called the '838 patent, and the
`
`other is called the '992 patent; is that right?
`
` A. Yes.
`
` Q. Do these two patents share a common
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`specification?
`
` A. Yes.
`
` Q. Does your patent app- -- do your patents
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`describe one kind of crimping device or more than
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`one kind of crimping device?
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` A. It -- as I recall -- it's been a while --
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`it was a -- there were various embodiments, but very
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`generally, as I recall, it was related to using a
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`hydraulic method to provide uniform radial
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`compression to the stent to compress the stent.
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`RONALD J. SOLAR, Ph.D.
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` Q. And what I'm trying to get at or find out
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`is, you have two patents, but do those patents
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`relate to the same device, one patent covering a
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`method of using the device and the other patent
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`covering the device itself?
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` A. That's correct.
`
` Q. So even though you have two patents, it's
`
`really one type of crimper; correct?
`
` A. Correct. One was a divisional of the
`
`other.
`
` Q. Okay. We're going to give you both of the
`
`patents.
`
` The '838 patent is Exhibit 2021, and the
`
`'992 patent is Exhibit 2022.
`
` (Exhibit 2021 was identified.)
`
` (Exhibit 2022 was identified.)
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`BY MR. SUMMERS:
`
` Q. I think you might have said it's been a
`
`while since you looked at these, so if you want to
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`take a look, please do.
`
` But my question to you is, how does the
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`stent crimper that's described in your patents work?
`
` A. Let me take a quick look. I have to
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`refresh myself. You know, I recall generally what
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`I've described. It had a chamber. You had a --
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`RONALD J. SOLAR, Ph.D.
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`kind of a -- I would say a bladder sheath. The
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`stent would go inside there. You would pressurize
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`the chamber to have uniform hydraulic pressure
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`surrounding, you know, the stent in -- within the
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`sheath, and that would compress the stent onto -- in
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`this case, it's compressing onto a balloon catheter,
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`for example.
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` But if you'd like, I could take a quick
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`look and give you more information here.
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` Q. I think that's sufficient.
`
` A. Okay.
`
` Q. Thank you.
`
` Does the stent crimper described in your
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`patents use any movable blades or movable dies?
`
` A. No.
`
` Q. Have you or has anyone else ever made a
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`crimper of the type described in your patents?
`
` A. There have been attempts that I'm aware of
`
`companies using hydraulic types of an apparatus, not
`
`specifically mine that I'm aware of. There were
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`other patents around this time looking at similar
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`concepts generally using hydraulic because it was at
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`the time identified of a great need to have uniform
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`crimping stents and people were looking at a number
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`of different ways.
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`RONALD J. SOLAR, Ph.D.
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` So there were others that I recall that use
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`hydraulics like I -- the approach I took.
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` Q. Let's try to break that down a little bit.
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` A. Okay.
`
` Q. Because I'm unclear whether anyone has
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`tried to make the crimper described in your patents,
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`specifically the crimper described in your patents,
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`or were others generally working in this field of
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`hydraulic crimping.
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` So just as a preface, that's where I'm
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`trying to -- I want to try to break that down.
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` So you said others were working in this
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`area of hydraulic crimping; is that right?
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` A. I do recall that at least one company I
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`remember, Advanced Cardiovascular Systems, either
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`had a kind of device like this -- I know they had at
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`least two patents that I recall that issued on this
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`concept. Again, it's been many years.
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` I actually made the device on a prototype
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`basis, and it worked.
`
` Q. You said Advanced Cardiovascular Systems
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`had two patents?
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` A. I think it was two patents. It may have
`
`been more. They had a number of patents in the area
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`of stent crimping in this relevant time frame.
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` Q. Were you named as an inventor on any of
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`those patents?
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` A. Not on those patents, no.
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` Q. Was Advanced Cardiovascular Systems trying
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`to make a crimper according to its patents or your
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`patents?
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` A. I don't believe they were trying to do it
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`according to my patents that I recall.
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` Q. Okay. You mentioned you made a prototype
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`of your invention --
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` A. Yes.
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` Q. -- your crimper?
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` Yes?
`
` A. Yes.
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` Q. Are you aware of anyone besides yourself
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`that has made a crimper either as a prototype or any
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`other stage corresponding to your patent -- your
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`patents?
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` A. Not that I'm aware of.
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` Q. But you yourself made a prototype according
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`to your patents?
`
` A. Yes.
`
` Q. When did you do that?
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` A. It was sometime in this time frame right --
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`I don't recall if it was around the time I filed the
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`RONALD J. SOLAR, Ph.D.
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`patent, during the prosecution of the patent, but it
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`was in that general time frame.
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` Q. Why did you make the prototype?
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` A. Because there was a need. I was -- had a
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`company called Medgination that our company's
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`objectives were to design products to basically try
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`to sell to other companies as opposed to
`
`commercialize them ourselves and so made a prototype
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`to -- this is one of the products we were trying to
`
`develop because of the great need of crimping a
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`stent evenly and uniformly.
`
` Q. Did the prototype that you made actually
`
`work to crimp a stent or other stent-like device?
`
` A. It worked very well.
`
` Q. How many prototypes did you make?
`
` A. I believe it was two.
`
` Q. Two prototypes?
`
` A. Two prototypes, right, because it was a
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`reusable system.
`
` Q. Did you make those yourself, or did you
`
`have someone make them for you?
`
` A. I had a colleague working with me.
`
` Q. Did the two prototype crimpers of the type
`
`described in your patent ever make it beyond the
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`prototype stage?
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` A. No. I had other priorities at that time
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`that I focused on.
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` Q. What priorities were those?
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` A. Those were primarily in the area of balloon
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`catheters for doing angioplasty as well as stent
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`delivery.
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` Q. How many stents did you crimp in your
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`prototype crimpers?
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` A. I don't recall.
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` Q. How long did you use the prototype to crimp
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`stents?
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` A. There were a number of months. Part of
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`the -- one of the things I was looking at is trying
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`to obtain as many different types of stents at that
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`time to see if there was anything in the stent
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`structure that would be adverse to this type of a
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`crimping device. So I don't recall how many stents
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`I actually tested, different types. It was whatever
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`I could get hold of at the time.
`
` Q. At the time you were developing your stent
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`crimper and filing your patent application, were you
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`aware of other stent crimpers that could crimp a
`
`stent uniformly?
`
` A. There were various types of prior art that
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`I recall coming across.
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`RONALD J. SOLAR, Ph.D.
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` Q. What?
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` A. I probably listed some in here.
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` Q. When you say "in here," you're saying in --
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` A. Oh, I'm sorry.
`
` Q. -- your patents?
`
` A. Yeah. I should -- let me be clear, in the
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`patent specification.
`
` Q. Did you or anyone else ever try to sell a
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`stent crimper of the type described in your patents?
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` A. Well, I did -- well, I attempted to, tried
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`to sell the idea. But then, as I said, I had other
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`priorities that took my time.
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` And I also mentioned that there were others
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`that had similar concepts of hydraulic that I had --
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`either came across either in my prior art search or
`
`through discussions. Like I said, it's been a
`
`number of years.
`
` Q. When you say you've tried to sell the idea,
`
`do you mean you tried to sell the concept of your
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`crimper or that you tried to actually sell physical
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`crimpers that would be made according to your
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`patent?
`
` A. The concept and the idea, the intellectual
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`property.
`
` Q. So the patent itself and not the physical
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`crimper?
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` A. That's correct.
`
` Q. So my question to you was, did you ever --
`
`or anyone else try to sell the actual physical
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`crimper that would be made according to your
`
`patents?
`
` A. I'm not aware of that happening.
`
` Q. Have you granted any licenses to anyone
`
`under your crimper patents?
`
` A. The patents were sold as part of a merger
`
`of the company with another company.
`
` Q. Were other patents also sold as a part of
`
`that merger?
`
` A. Yes.
`
` Q. How many other patents were sold?
`
` A. I don't know. There were a number of
`
`patents.
`
` Q. But getting back to my question about
`
`whether or not you licensed your patents to anyone,
`
`have you?
`
` Have you licensed your crimper patents to
`
`anyone?
`
` A. No.
`
` Q. Has anyone ever approached you and asked to
`
`take a license under your patents at the time you
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`owned them?
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` A. I don't recall if they did or did not.
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` Q. Did you ever offer to license your patents
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`to anyone?
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` A. I don't recall specifically, but I probably
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`did because that's the business that I was doing at
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`the time. And the company that acquired -- or we
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`merged with, actually, you know, this was presented
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`to them as part of the technology that we were
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`bringing to the merger.
`
` Q. Which company was that?
`
` A. The company was called X Technologies.
`
` Q. Can you spell that, please?
`
` A. Capital X, Technologies.
`
` Q. Just like it sounds?
`
` A. Exactly.
`
` Q. Did X Technologies do anything to try to
`
`make or commercialize the stent crimper described in
`
`your patents?
`
` A. Not specifically. There were plans to and
`
`discussions to do this, but again, priorities
`
`shifted more toward the balloon catheters that we
`
`had designed and the stent delivery systems.
`
` Q. Did the stent crimper described in your
`
`patents apply a uniform crimping force?
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`RONALD J. SOLAR, Ph.D.
`
` A. Yes, it did.
`
` Q. Did the stent crimper described in your
`
`patents solve or fail to solve the need for uniform
`
`crimper -- stent crimping?
`
` A. It was hard to say. I think it -- the
`
`short answer is we just didn't do enough work with
`
`it to really validate that that would be the case.
`
`In the work that we did, it appeared that it looked
`
`promising at the time.
`
` Q. Would you say that the stent crimper
`
`described in your patents worked for its intended
`
`purpose?
`
` A. At the time, it appeared to. But like I
`
`said, it was at a prototype level, and it would have
`
`required a lot more work.
`
` Q. What do you consider to be your area or
`
`areas of expertise?
`
` A. Kind of expansive. A lot -- I would say
`
`more focused on catheter-based technologies for
`
`cardiovascular and peripheral vascular applications.
`
`Also now doing work in the area of acute stroke.
`
`And most of the expertise are related to less
`
`invasive technologies using catheters to either
`
`deliver or provide therapies, and that also includes
`
`stents as part of the technologies.
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`RONALD J. SOLAR, Ph.D.
`
` Q. So stents would be one area of expertise
`
`for you?
`
` A. Yes.
`
` Q. How about stent crimping?
`
` A. I would say stent crimping also, yes,
`
`because it's part of the procedure of -- or I should
`
`say it's actually part of the design to provide a
`
`good stent and delivery system.
`
` Q. What about devices for crimping stents? Is
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`that an area of your expertise?
`
` A. Only to the extent of the attempts I've
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`made with my ow

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