`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_________________
`
`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.,
`Petitioner,
`
`v.
`
`TELEFLEX INNOVATIONS S.À.R.L.,
`Patent Owner.
`
`_________________
`
`Case No. IPR2020-00128
`Case No. IPR2020-00129
`Case No. IPR2020-00130
`U.S. Patent No. RE45,380
`_________________
`
`PETITIONER’S SUR-REPLY
`TO PATENT OWNER’S MOTION TO AMEND
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`
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`
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`Case Nos. IPR2020-00128, -00129, -00130
`U.S. Patent No. RE45,380
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`TABLE OF CONTENTS
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`Page
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`I.
`
`II.
`
`Introduction ...................................................................................................... 1
`
`Proposed Claims 43 and 44 are Unpatentable. ................................................ 2
`
`A.
`
`Substitute claims 43 and 44 are unpatentable over Itou in view of
`Ressemann or Kataishi. ......................................................................... 2
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`1.
`
`2.
`
`3.
`
`4.
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`Stents and Stent Catheters ........................................................... 2
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`Complex Side Opening ............................................................... 5
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`Size Limitations .......................................................................... 6
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`Coaxial Lumen ............................................................................ 6
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`5. Motivation to Combine Itou and Ressemann ............................. 7
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`6. Motivation to Combine Itou and Kataishi .................................. 9
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`B.
`
`Substitute claims 43 and 44 are unpatentable over Kontos in view
`of Ressemann and Takahashi. .............................................................10
`
`1.
`
`Stents and Stent Catheters .........................................................10
`
`2. Motivation to Combine Kontos and Ressemann ......................11
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`III.
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`Proposed Claim 44 is Indefinite. ...................................................................14
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`IV. Conclusion .....................................................................................................15
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`
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`i
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`Case Nos. IPR2020-00128, -00129, -00130
`U.S. Patent No. RE45,380
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
`
`In re Etter,
`756 F.2d 852 (Fed. Cir. 1985) (en banc) .............................................................. 8
`
`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) ........................................................................................ 2, 14
`
`Univ. of Maryland Biotechnology Institute v. Presens Precision
`Sensing GmbH,
`711 F. App’x 1007 (Fed. Cir. 2017) ................................................................. 1, 8
`
`
`
`
`ii
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`Case Nos. IPR2020-00128, -00129, -00130
`U.S. Patent No. RE45,380
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`I.
`
`INTRODUCTION
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`Patent Owner’s (“PO”) claimed inventions are not new—they are merely
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`commercialization of the prior art. The proposed amended claims add no new
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`material limitations that were not present in the art and are therefore invalid for the
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`same reasons the original claims are invalid. Before the alleged invention, Kontos
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`described a “guide catheter extension,” or “support catheter . . . distally extended
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`from a guide catheter for delivering a PTCA catheter to a restriction in the artery.”
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`Itou, a suction catheter, and Ressemann, an embolic protection device, are both
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`designed to treat coronary artery disease and would be considered together in
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`designing catheters and treating patients. Ressemann and Kataishi disclose the
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`claimed structure of the amended complex side opening and the art attributes known
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`benefits to this structure. Further, the art describes that similarly shaped openings
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`provide these same benefits when used for both the proximal and distal opening of
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`various catheters. Nonetheless, PO argues the claims are not obvious because a
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`POSITA (1) would not be motivated to make the combinations where the art uses
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`different ways to treat coronary arteries and (2) would not have an expectation of
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`success because modifications would need to be made to incorporate the art together.
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`A POSITA is not an automaton restricted to combining two specific physical
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`embodiments of the prior art. Univ. of Maryland Biotechnology Institute v. Presens
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`Precision Sensing GmbH, 711 F. App’x 1007, 1010 (Fed. Cir. 2017). Instead, a
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`1
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`POSITA has the ordinary creativity of a skilled artisan using the common knowledge
`
`and common sense present in the art. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398,
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`421 (2007). PO narrowly focuses on combining specific embodiments and argues
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`because they are not readily combinable without making some modifications, the
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`invention is not obvious. PO ignores that these modifications were well-understood
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`routine engineering concepts within the capability of a POSITA, who had motivation
`
`to make them. Taking well-defined structures with known benefits, like the shape of
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`various catheter openings, and applying those structures to other catheters to achieve
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`predictable results is not inventive. Thus, the proposed amended claims are invalid.
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`II.
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`PROPOSED CLAIMS 43 AND 44 ARE UNPATENTABLE.
`
`A.
`
`Substitute claims 43 and 44 are unpatentable over Itou in view of
`Ressemann or Kataishi.
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`PO argues that the Itou grounds do not invalidate substitute claims 43 and 44
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`for at least five reasons, including (1) Itou does not disclose stents, (2) Ressemann
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`and Kataishi do not disclose the claimed “concave track,” (3) Itou does not disclose
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`the claimed diameter sizes with a 6 Fr guide catheter, (4) Itou does not disclose the
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`claimed “coaxial lumen,” and (5) a POSITA would not be motivated to combine Itou
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`and Ressemann, and/or Itou and Kataishi. Each of these issues is discussed below.
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`1.
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`Stents and Stent Catheters
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`Itou discloses that all four types of interventional cardiology devices are
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`insertable, including stents. First, Itou itself teaches that guidewire (6) is insertable
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`2
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`through catheter (2). Ex. 1007, Fig. 5; 4:64-65; see also Ex. 1806 ¶ 45. PO’s expert
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`could have, but did not, offer an opinion on whether a guidewire fit through Itou’s
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`structure. Ex. 1805, 139:3-13. Second, the inner diameter of Itou’s tubular portion
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`24 is 1.5mm, or 0.059 inches, Ex. 1007, Table 1, 1:59-65, see also Ex. 1902 ¶¶ 73-
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`74. Even if the “effective opening” of Itou is only 0.046 inches, as PO incorrectly
`
`asserts, angioplasty balloons and numerous commercial stents (necessarily deployed
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`using stent catheters) were available before the alleged invention date and were
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`insertable through an opening of at least 0.046 inches. Ex. 1806 ¶¶ 47-52; Ex. 1015b,
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`189; Ex. 1802, 7; Ex. 1803, 4:54-58; Ex. 1804, Table 1 & 2. Indeed, the crossing
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`profiles for 13 commercially available stents ranged from 0.84mm (0.033 inches) to
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`1.17mm (0.046 inches).1 Ex. 1804, Table 2. Other art of record shows not only that
`
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`1 PO points to a single example of a commercially available stent requiring a
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`crossing profile of 0.056 inches. See MTA Reply, 3 (citing Ex. 1802, 25). Otherwise,
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`cited stents are merely described as being “compatible” with 5 Fr guide catheters,
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`see Ex. 1806 ¶¶ 48-51 (citing Ex. 1048; Ex. 1049), which were often the smallest
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`commercially available guide catheters in the early 2000s. Regardless, as
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`Petitioner’s expert testified, and as the record evidence shows, even assuming Itou’s
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`effective opening is only 0.046 inches, a POSITA would readily understand that
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`many stents were compatible with the commonly sized 5 Fr guide catheters, but
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`some stents were compatible with even smaller catheters. See Ex. 1041 at 14 (“Small
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`size (< 5 F) guide catheters do not allow for the use of some stents.”) & 22 (“Stent
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`profiles are now very small (profile size of 0.035 and 0.033 inch).”); Ex. 1802, 5-7,
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`15, 21, & 31 (disclosing stents with crossing profiles less than 1mm or 0.039 inches).
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`It is axiomatic that a POSITA would use a suction catheter like Itou to deliver
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`a stent. Itou teaches placing the catheter in exactly the right place to deliver a stent,
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`where its distal tubular opening is adjacent “foreign matter” in the coronary artery.
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`Ex. 1007, Fig. 6; 1:66-2:5; 5:29-42. Moreover, inventor Root admitted to starting
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`with the tubular portion of an aspiration catheter while developing GuideLiner
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`because it had the same benefits “whether you’re using it for aspiration or you’re
`
`using it for guide extension.” Ex. 1762, 46:4-47:1. And his admission is consistent
`
`with a POSITA’s understanding (and the art’s teaching) to use a suction catheter to
`
`both suction a thrombus and deliver a therapeutic device, where appropriate. Ex.
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`2240, 15:13-16:16 (explaining that “[y]ou’re balancing [the risk of residual material
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`in the suction catheter] against the risk of the catheter exchange, prolonging the
`
`
`commercially available stents as large as 0.042 inches would “go into that opening
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`without a problem.” Ex. 2239, 180:5-22; 181:2-21, 182:3-22.
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`4
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`
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`procedure, that itself, as I said, can produce thrombus and introducing air”); Ex-
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`1019, 3:4-6, 35-38; 12:16-26.
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`2.
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`Complex Side Opening
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`It is undisputed that Ressemann’s evacuation sheath includes a support collar
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`with a concave track. (Ex. 1008, 24:54–56, Fig. 16J; Ex. 1902, ¶¶ 95-98.) PO’s own
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`expert, Mr. Keith, testified that if Ressemann’s collar is affixed on top of Itou’s push
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`wire, and the structure of the collar was maintained through the manufacturing
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`process, then that collar would have the claimed concave track. Ex. 1922, 58:6-
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`59:14, 61:8-12. What PO really disputes is the motivation to make the
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`Itou/Ressemann combination and a POSITA’s expectation of success, discussed
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`below, and not whether the opening itself discloses the claimed features.
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`Similarly, PO’s expert testified that a POSITA could cut the shape of
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`Kataishi’s opening into Itou’s collar, and if they did, that shape would also have the
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`claimed concave track. Id., 65:12-23, 66:6-20, 68:9-20. PO’s argument that Kataishi
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`does not disclose a concave track because of Kataishi’s guidewire lumen is
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`irrelevant—Itou’s primary embodiment does not have a guidewire lumen. A
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`POSITA, motivated to use Kataishi’s opening, is perfectly capable of using the
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`concave track of Kataishi’s opening without including the guidewire lumen.
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`Whether a POSITA would do so is a different question discussed below, but there is
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`no genuine dispute that the structure is nonetheless disclosed in the prior art.
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`3.
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`Size Limitations
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`PO alleges, without substantive argument, that Itou does not disclose the 6 Fr
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`guide catheter and the claimed size limitations. (MTA Reply, 4). PO cites to a
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`demonstrative drawing as proof but does not explain how the drawing has any
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`relevance to its argument. Id. PO appears to assume that the drawing is an exact
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`cross sectional replica of the modified Itou/Ressemann combination and thus cannot
`
`fit the claimed sizes. This is incorrect. Itou explicitly discloses that the inner diameter
`
`of tubular portion 24 is 1.5mm, or 0.059 inches. Ex. 1007, Table 1, 1:59-65, see also
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`Ex. 1902, ¶¶ 73-74. Further, Itou discloses that guiding catheter 1 can be 6 French.
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`Ex. 1007, 5:65-67, 6:47-50; Ex. 1902, ¶¶ 19 & 49.
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`4.
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`Coaxial Lumen
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`Similar to the size limitations, PO alleges that Itou does not satisfy the
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`“coaxial” limitation, without explaining anything about its argument. (MTA Reply,
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`4). Petitioner’s expert, Dr. Brecker, testified consistently about a POSITA’s
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`understanding of coaxial, which means the “axis of the lumen of the guide extension
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`catheter is aligned in the same direction as the axis of the lumen of the guide catheter.
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`Ex. 1806, ¶¶ 25-26 (citing inventor’s testimony that coaxial means a “tube within a
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`tube”); see also, Ex. 2238, 28:15-25; 29:1-31:7; 31:21-32:5; 32:10-24; 43:9-44:19;
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`63:10-64:23. Contrary to PO’s allegation, Dr. Brecker did not agree to PO’s
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`proposed construction. Instead, he testified that two structures, side by side, would
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`6
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`not be coaxial to each other, but would be coaxial to the lumen of a guide catheter.
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`Ex. 2238, 44:1-19.
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`5. Motivation to Combine Itou and Ressemann
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`PO argues that a POSITA would not be motivated to combine Itou and
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`Ressemann for essentially two reasons. First, because a POSITA would not
`
`recognize Ressemann’s collar, part of an embolic protection device, as an
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`improvement to Itou as a suction catheter. And second, because if Ressemann’s
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`collar was incorporated into Itou, some modifications would be necessary to make
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`them work and these modifications would either destroy the purpose of the
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`references or would amount to hindsight. Both arguments are incorrect.
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`First, a POSITA would undoubtedly look to Itou and Ressemann when
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`designing a catheter. Ex. 1806, ¶¶ 67-69; see also Ex. 1805, 20:7-21:2, 70:13-72:1.
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`More specifically, Ressemann explains that collar 2141 “serves to reinforce the
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`proximal opening of the evacuation lumen 2140.” Ex. 1008, 24:49-55. Taking the
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`defined structure of Ressemann’s collar and incorporating it into Itou would provide
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`the same predictable benefits, including offering a larger area of entry for therapeutic
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`devices. Ex. 1902, ¶¶ 50-84; Ex. 1807, ¶¶ 121-25. The entire structure, including the
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`tab structure PO claims is hidden, would be used because (1) it is already a known
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`structure, (2) it provides a longer and larger surface area for entry of devices, and (3)
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`the tab portion 2141b would provide a flexibility transition and a better connection
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`point to Itou’s pushrod. Ex. 1902, ¶¶ 99-100; Ex. 1807, ¶¶ 121-29.
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`Second, taking the known structure of Ressemann’s collar and incorporating
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`it into Itou would be a matter of routine engineering and would not destroy any
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`purpose of the references. Here, PO misapplies the law of obviousness and ignores
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`routine changes a POSITA would make. “A person of ordinary skill is ‘not an
`
`automaton,’ limited to physically combining references.” Univ. of Maryland
`
`Biotechnology Institute v. Presens Precision Sensing GmbH, 711 F. App’x 1007,
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`1010 (Fed. Cir. 2017) (citations omitted); see also In re Etter, 756 F.2d 852, 859
`
`(Fed. Cir. 1985) (en banc) (“Etter’s assertions that Azure cannot be incorporated in
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`Ambrosio are basically irrelevant, the criterion being not whether the references
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`could be physically combined but whether the claimed inventions are rendered
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`obvious by the teachings of the prior art as a whole.”). Instead, a POSITA uses the
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`common knowledge and creativity in the art to make the combination.
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`The process of combining Ressemann’s collar into Itou amounts to nothing
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`more than routine engineering. For example, a POSITA could place the collar on top
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`of the pushrod, could taper Itou’s pushwire as it meets the proximal opening, and
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`could apply a polymer coating to Ressemann’s collar to prevent catching of devices.
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`Ex. 1807, ¶ 131. In fact, a POSITA would want to make these changes to create a
`
`better device. Ex. 2241, 27:10-29:7. While PO argues these changes amount to
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`“hindsight,” its own expert admitted that these concepts were previously used in the
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`art at the time of the invention and would be within the knowledge of a POSITA.
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`Ex. 1922, 29:17-22 (adhesives were well known), 29:23-30:16 (polymer coatings
`
`were known), 31:13-32:6 (tapering was known and “some sort of methodology to
`
`try and get rid of that obstruction does make sense”). Other ways existed to affix the
`
`collar, including following Itou’s disclosure of coating the surfaces with resin and
`
`welding the collar to the distal end of the pushwire. See Ex. 1007, 4:32-36.
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`6. Motivation to Combine Itou and Kataishi
`
`PO’s main argument for Kataishi is that a POSITA would not look towards
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`Kataishi’s distal opening to use in a proximal opening of Itou. This motivation comes
`
`directly from the art itself, namely Ressemann, which teaches that an angled shape
`
`for both the proximal and distal ends of a catheter provides similar benefits:
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`The proximal and distal ends 140a, 140b of the evacuation lumen 140
`
`are preferably angled to allow for smoother passage of the evacuation
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`sheath assembly 100 through a guide catheter, and into a blood vessel,
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`and to facilitate smoother passage of other therapeutic devices through
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`the evacuation lumen 140 of the evacuation head 132. The larger area
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`of the angled open ends also allows for larger deformable particulate
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`matter to pass through the lumen more smoothly.
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`Ex. 1008 6:52-60 (emphasis added). Kataishi and other art shows that Kataishi’s
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`shape has improved crossability in the vasculature, Ex. 1055, 300-02, and a POSITA
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`would recognize this benefit applies to the proximal opening as well. Ex. 1807,
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`¶ 198. This is just common sense—when the extension catheter is pulled back out
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`through the guide, the proximal opening must navigate around similar curves.
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`Further, Kataishi discloses predictable benefits in a proximal opening, i.e. the shape
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`improves suction of thrombi with a larger area of entry—a POSITA would
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`recognize, based in part on Ressemann’s disclosure, this benefit applies to loading
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`therapeutic devices into a proximal opening. Ex. 1902 ¶¶ 113-29.
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`B.
`
`Substitute claims 43 and 44 are unpatentable over Kontos in view
`of Ressemann and Takahashi.
`
`PO argues that the Kontos grounds do not invalidate substitute claims 43 and
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`44 for similar reasons as the Itou grounds, including (1) the grounds do not disclose
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`stents and (2) a POSITA would not be motivated to combine the references. Each of
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`these issues is discussed below.
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`1.
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`Stents and Stent Catheters
`
`PO argues that even though Ressemann discloses passing stents, combining
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`Ressemann’s collar with Kontos might create a catch point and thus the claims are
`
`not invalid. (MTA Reply, 12). The arguments do not logically flow together and
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`ignore routine modifications a POSITA would make to prevent catch points.
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`First, PO does not dispute that in the 2005-2006 timeframe, stent and stent
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`catheters were sized to travel through Kontos’s body 12. Ex. 1806 ¶¶155-58; Ex.
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`1015a, 31-32; Ex. 1802, 6-7, 15, 21, 25; Ex. 2116, 335:18-336:1. PO incorrectly
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`argues that Ressemann requires a reverse bevel to pass stents, and thus, without a
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`reverse bevel in the Kontos/Ressemann combination, it cannot pass stents. But PO’s
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`expert admitted that Ressemann’s primary embodiment does not use a reverse bevel.
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`Ex. 1801, 107:1-108:4; see also Ex. 2241, 48:11-49:1. Nor does the expert’s own
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`patent—with verbatim disclosures from Ressemann about passing devices through
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`a side opening—use a reverse bevel. Ex. 1800, 149:3-10. And in combining Kontos
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`with Ressemann, a POSITA would use routine engineering to encase the collar in a
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`polymer coating to eliminate any catch points. Ex. 1807, ¶¶ 90-92, 188-190. PO’s
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`expert agreed that polymer coatings were known in the art, Ex. 1922, 29:23-30:16,
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`and PO’s arguments are unpersuasive.
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`2. Motivation to Combine Kontos and Ressemann
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`PO’s arguments on motivation to combine essentially are that (1) a POSITA
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`would not be motivated to remove Kontos’s funnel because it would conflict “with
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`Kontos’s stated purposes of acting as a temporary stent . . . and of functioning as a
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`‘support catheter,’”(MTA Reply, 17-18), and (2) significant modifications would
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`need to be made to maximize the inner lumen diameter as proposed by Petitioner.
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`PO defines the purpose of Kontos too narrowly, as Kontos has other functions
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`besides acting as a temporary stent, including to deliver a PTCA catheter. Further,
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`Petitioner’s proposed modification only increases the outer diameter of Kontos’s
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`extension catheter by 0.008 inches. Compare Ex. 1807, ¶ 73, with id. ¶ 194. Second,
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`the proposed modifications to Kontos are not significant redesigns of the reference,
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`as PO alleges, but instead are routine engineering concepts applied to manufacture
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`a working device. PO’s assumption that the proposed changes to Kontos are
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`hindsight bias and not routine engineering are not supported by the facts or the law.
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`The motivation to combine comes directly from the prior art. Takahashi
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`discloses that using a 5 Fr “guiding catheter” inside of a 6 Fr “guiding catheter”
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`increases backup support. Ex. 1010, 5. Specifically, the reference discloses that
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`extending a 5 Fr guide catheter just 10mm beyond the 6 Fr guide catheter increases
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`the maximum backup support by almost double compared with a 6 Fr guide catheter
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`by itself. Id., 7, Fig. 4. PO does not dispute that Takahashi provides motivation to
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`achieve a 1 French differential to increase backup support. Ex. 1801, 117:14-118:5.
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`Instead, PO only alleges that because Kontos already fit within a 6 Fr guide catheter
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`and provided some backup support, a POSITA would not be motivated to modify
`
`the reference to provide more backup support. (MTA Reply, 24).
`
`As disclosed in Ressemann, a POSITA would understand that Ressemann’s
`
`collar would provide better benefits over Kontos’s funnel in allowing more types of
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`interventional cardiology devices to pass through. Ex. 1902, ¶¶ 190-204; Ex. 1905,
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`¶¶ 96-97. A POSITA would also understand that removing the funnel would provide
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`the additional benefit to allow for a larger inner diameter without needing a larger
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`outer diameter. Ex. 1902, ¶¶ 194-96. This allows for larger devices or more device
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`12
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`clearance through the same size outer diameter guide catheter, a sought after benefit
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`to better treat patients. Id.
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`PO argues that modifying Kontos in this manner would include too many
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`changes, like making the distal tip flush with the rest of the catheter, removing the
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`protruding marker bands and recessing them into the body of the catheter, tapering
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`the guidewire, and reinforcing the catheter with braiding. (MTA Reply, 15.) PO
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`again ignores that each of these steps is well within the ordinary routine engineering
`
`of a POSITA. These arguments are inconsequential and distract from the key
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`question—whether a POSITA would be motivated to take the defined structure of
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`Ressemann’s collar with the known benefits of aiding delivery of interventional
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`cardiology devices and incorporate that structure into Kontos’s “guide catheter
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`extension” with an expectation of success. Where this motivation comes directly
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`from the art and the combination is nothing more than routine engineering, the
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`proposed amended claims are invalid as obvious.
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`Petitioner’s experts testified that recessing Kontos’s marker bands could (and
`
`would) easily be accomplished to maximize the inner lumen of the catheter. Ex.
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`1902, ¶¶ 154; Ex. 2116, 343:5-136, 346:12-25, 353:24-354:17, & 364:3-365:11
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`(testifying why a POSITA would want to remove protruding marker bands);
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`Ex. 2137, 464:19-467:2 (testifying that Kontos itself discloses “numerous other
`
`methods of disposing marker band 30” onto tube 16). Tapering was a well-
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`understood concept and a POSITA would taper the guidewire to incorporate
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`Ressemann’s collar. (Ex. 1902, ¶¶ 154; Ex. 1807, ¶¶ 177.) Contrary to PO’s
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`argument, this tapered guidewire would not be too flimsy to work. See Ex. 1922,
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`31:13-32:6 (PO’s expert testifying that tapering was known to a POSITA). 2 Other
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`changes, like reinforcing the catheter with braiding, are nothing more than using
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`familiar and known elements in predictable ways to achieve known benefits. Ex.
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`1902, ¶¶ 41, 164-72; see also KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007)
`
`(“The combination of familiar elements according to known methods is likely to be
`
`obvious when it does no more than yield predictable results.”).
`
`III. PROPOSED CLAIM 44 IS INDEFINITE.
`
`Proposed claim 44 remains indefinite, as it recites a “substantially rigid
`
`portion . . . connected to . . . the flexible tip portion” even though there is an
`
`intervening “reinforced portion.” (App., 3-5.) PO’s argument that this somehow
`
`permits indirect connection is without merit. Indeed, when it wanted to, PO knew
`
`how to use claim language permitting an indirect connection, (App., 2 (reciting that
`
`two portions are “operably connected”)), but chose not to do so here.
`
`
`2 Dr. Jones is not inconsistent on tapering. He testified he would taper Kontos over
`
`a long distance, as opposed to the abrupt tapering in Itou. Ex. 2241, 133:6-134:3.
`
`14
`
`
`
`Case Nos. IPR2020-00128, -00129, -00130
`U.S. Patent No. RE45,380
`
`IV. CONCLUSION
`
`For the foregoing reasons, Teleflex’s motion to amend should be denied.
`
`
`
`
`
`Date: February 23, 2021
`800 LaSalle Ave, Suite 2800
`Minneapolis, MN 55402
`612.349.8500
`
`
`
`
`
`RESPECTFULLY SUBMITTED,
`
`ROBINS KAPLAN LLP
`
`/ Cyrus A. Morton /
`Cyrus A. Morton
`
`Attorney for Petitioner
`Medtronic, Inc.
`
`15
`
`
`
`Case Nos. IPR2020-00128, -00129, -00130
`U.S. Patent No. RE45,380
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this February 23, 2021, a copy of Petitioner’s
`
`Opposition to Patent Owner’s Corrected Motion to Amend was served in its
`
`entirety by electronic mail on Patent Owner’s counsel at the following addresses
`
`indicated in Patent Owner’s Mandatory Notices:
`
`J. Derek Vandenburgh, Reg. No. 32,179
`dvandenburgh@carlsoncaspers.com
`
`Dennis C. Bremer, Reg. No. 40,528
`dbremer@carlsoncaspers.com
`
`Joseph W. Winkels
`jwinkels@carlsoncaspers.com
`
`Peter M. Kohlhepp
`pkohlhepp@carlsoncaspers.com
`
`Tara C. Norgard (pro hac vice pending)
`tnorgard@carlsoncaspers.com
`
`Alexander S. Rinn (pro hac vice pending)
`pkohlhepp@carlsoncaspers.com
`
`Megan E. Christner, Reg. No. 78,979
`mchristner@carlsoncaspers.com
`
`Kenneth E. Levitt, Reg. No. 39,747
`levitt.kenneth@dorsey.com
`
`Dated: February 23, 2021
`
`
`
`
`
`Respectfully submitted,
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Reg. No. 44,954
`
`
`
`
`
`
`16
`
`
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