`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.,
`
`Petitioners,
`
`v.
`
`TELEFLEX INNOVATIONS S.À.R.L.,
`
`Patent Owner.
`
`IPR2020-00126
`IPR2020-00127
`IPR2020-00128
`IPR2020-00129
`IPR2020-00130
`IPR2020-00132
`IPR2020-00134
`IPR2020-00135
`IPR2020-00136
`IPR2020-00137
`IPR2020-00138
`
`PETITIONERS’ OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVES
`
`
`
`Pursuant to the Board’s February 16, 2021 Order Setting Oral Argument
`
`(Paper 1101), Petitioners Medtronic, Inc., and Medtronic Vascular, Inc., file the
`
`following objections to Patent Owners’ demonstratives.
`
`I.
`
`Slide 55
`
`Petitioners object to Patent Owner’s demonstrative slide 55 as improper new
`
`evidence and new argument because Patent Owner does not cite or argue those pages
`
`of the excerpted deposition transcript (Ex-1756 at 94-95) in its conception and
`
`reduction to practice briefing, and no paper—Patent Owner’s or Petitioners’—in
`
`these proceedings cites the portion of the excerpt highlighted in red, below.
`
`
`1 IPR2020-00126, -00128: Paper 110. IPR2020-00127: Paper 93. IPR2020-00129,
`
`-00132: Paper 108. IPR2020-00130: Paper 91. IPR2020-00134: Paper 105.
`
`IPR2020-00135: Paper 109. IPR2020-00136, -00138: Paper 92. IPR2020-00137:
`
`Paper 111.
`
`1
`
`
`
`Slide 55:
`
`II.
`
`Slide 66
`
`Petitioners object to Patent Owner’s demonstrative slide 66 as improper new
`
`evidence and new argument because no paper—Patent Owner’s or Petitioners’—
`
`cites those deposition excerpts (Ex-2237 at 37:11-13, 39:7-9).
`
`
`
`2
`
`
`
`Slide 66:
`
`
`
`III. Slide 97
`
`Petitioners object to Patent Owner’s demonstrative slide 97 as improper new
`
`argument because Patent Owner does not argue that Exhibit 2019 shows that
`
`“GuideLiner Narrow SST-02 Flatt Pattern engineering drawing” was created
`
`November 1, 2005, as part of its diligence case in its conception and reduction to
`
`practice briefing.
`
`3
`
`
`
`Slide 97 (red box added identifying new argument):
`
`IV. Slide 99
`
`Petitioners object to Patent Owner’s demonstrative slide 99 as improper new
`
`evidence and new argument because Patent Owner does not cite or argue Exhibit
`
`2115 as part of its diligence case in its conception and reduction to practice briefing.
`
`
`
`4
`
`
`
`Slide 99 (red box added identifying new evidence and new argument):
`
`
`
`Dated: March 5, 2021
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Reg. No. 44,954
`Robins Kaplan LLP
`2800 LaSalle Plaza
`800 LaSalle Avenue
`Minneapolis, MN 55402
`Attorney for Petitioners
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e)(4), the undersigned certifies that on March 5,
`
`2021, a copy of PETITIONERS’ OBJECTIONS TO PATENT OWNER’S
`
`DEMONSTRATIVES was served 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)
`arinn@carlsoncaspers.com
`
`Megan E. Christner, Reg. No. 78,979
`mchristner@carlsoncaspers.com
`
`Kenneth E. Levitt, Reg. No. 39,747
`levitt.kenneth@dorsey.com
`
`
`Dated: March 5, 2021
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/Cyrus A. Morton/
`Cyrus A. Morton
`Reg. No. 44,954
`Attorney for Petitioners
`
`
`
`6
`
`
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