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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.
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`Petitioners,
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`V.
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`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
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`DECLARATION OF ALEXANDER S. RINN SUBMITTED IN
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`CONNECTION WITH PATENT OWNER’S PRELIMINARY RESPONSES
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`Page 1
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`Teleflex EX. 2073
`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 1
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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`1, Alexander S. Rinn, hereby declare and state as follows:
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`1.
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`I am a member of the bar of the district of Minnesota.
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`I am an
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`attorney at Carlson, Caspers, Vandenburgh & Lindquist, P.A., which represents
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`Patent Owner in the IPR proceedings initiated by Medtronic, Inc. and Medtronic
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`Vascular, Inc. I make this Declaration in connection with Patent Owner’s
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`Preliminary Responses to Petitions filed by Medtronic, Inc. and Medtronic
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`Vascular, Inc.
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`2.
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`Exhibit 2043 is a true and correct copy of the October 11, 2019
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`Declaration of Amy Welch in Support of Plaintiffs’ Motion for Preliminary
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`Injunction filed under seal in the case of Vascular Solutions LLC v. Medtronic,
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`Inc, 19—cv-01760-PJS-TNL (D. Minn).
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`3.
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`Exhibit 2044 is a true and correct copy of the partially redacted
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`October 11, 2019 Declaration of Amy Welch in Support of Plaintiffs’ Motion for
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`Preliminary Injunction filed in the case of Vascular Solutions LLC v. Medtronic,
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`Inc. , l9-cv—01760-PJS~TNL (D. Minn).
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`4.
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`Exhibit 2045 is a true and correct copy of Plaintiffs’ Second
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`Supplemental Objections and Response to Defendants’ Interrogatory No. 7
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`Concerning Preliminary Injunction Issues served on November 6, 2019 in the case
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`of Vascular Solutions LLC v. Medtronic, Inc, l9-cv-01760-PJS-TNL (D. Minn.)
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`Page 2
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`Teleflex EX. 2073
`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 2
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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`5.
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`Exhibit 2046 is a true and correct copy of the June 10, 2013
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`Declaration of Howard Root in Support of Plaintiff’s Motion for Preliminary
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`Injunction filed in the case of Vascular Solutions, Inc. v. Boston Scientific
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`Corporation, 13-CV-01172 (JRT—SER) (D. Minn.)
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`6.
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`Exhibit 2048 is a true and correct copy of the partially redacted
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`Defendants’ Opposition to Plaintiffs’ Motion for Preliminary Injunction filed in the
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`case of Vascular Solutions LLC v. Medtronic, Inc, l9-cv—01760-PJS-TNL (D.
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`Minn.)
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`7.
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`Exhibit 2049 is a true and correct copy of the Amended Pretrial
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`Scheduling Order from the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-
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`cv—Ol760-PJS—TNL (D. Minn).
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`8.
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`Exhibit 2050 is a true and correct copy of Defendants’ Second
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`Amended Notice of Deposition of Peter Keith served on September 30, 2019 in the
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`case of Vascular Solutions LLC v. Medtronic, Inc, 19—cv—01760—PJ S-TNL (D.
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`Minn.)
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`9.
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`Exhibit 2051 is a true and correct copy of Defendants’ Amended
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`Notice of Deposition ofAmy Welch served on October 9, 2019 in the case of
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`Vascular Solutions LLC v. Medtronic, Inc, 19—cv—01760—PJS-TNL (D. Minn.)
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`Page 3
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 3
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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`10.
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`Exhibit 2052 is a true and correct copy of drawings submitted to the
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`US. Patent Office on August 9, 2002 in connection with US. Patent Application
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`10/214,712 by inventor Thomas V. Ressemann.
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`11.
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`Exhibit 2053 is a true and correct copy of Defendants’ Interrogatories
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`to Plaintiffs Concerning Preliminary Injunction Issues served on July 25, 2019 in
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`the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-cv-01760-PJS-TNL (D.
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`Minn).
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`12.
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`Exhibit 2054 is a true and correct copy of Defendants’ Requests for
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`Production of Documents Concerning Preliminary Injunction Issues served on July
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`25, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc. , l9-cv—01760-
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`PJS-TNL (D. Minn).
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`13.
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`Exhibit 2056 is a true and correct copy of the Expert Report of Peter
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`T. Keith on Infringement, Claim Coverage, and Lack of Acceptable Noninfringing
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`Alternatives filed publicly as Exhibit 23 to the Declaration of Courtland Merrill in
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`Support of QXMédical LLC’s Motion for Summary Judgment in the case of
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`QXMédical v. Vascular Solutions, LLC, 17-cv—01969-PJS-TNL (D. Minn).
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`14.
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`Exhibit 2057 is a true and correct copy of a PDF printout of a
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`Teleflex webpage titled “Product Patents” available at
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`https://Www.teleflex.com/usa/en/product-areas/interventional/patents/index.
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`Page 4
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 4
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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`15.
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`Exhibit 2059 is a true and correct copy of Plaintiffs” First
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`Supplemental Objections and Responses to Defendants” Interrogatories
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`Concerning Preliminary Injunction Issues served on September 20, 2019 in the
`
`case of Vascular Solutions LLC v. Medtronic, Inc, 19-cv—01760-PJS-TNL (D.
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`Minn.).
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`16.
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`Exhibit 2060 is a true and correct copy of a printout of a September
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`25, 2019 Teleflex press release titled “Teleflex Announces Tenth Anniversary of
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`GuideLiner Catheter Product Line.”
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`17.
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`Exhibit 2068 is a true and correct copy of Defendants’ Answer,
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`Defenses, and Counterclaims to Plaintiffs’ Complaint filed on August 23, 2019 in
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`the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-cv-01760-PJS-TNL (D.
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`Minn.)
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`18.
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`Exhibit 2069 is a true and correct copy of Exhibit E to the Complaint
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`filed on July 2, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc, 19-
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`cv-01760-PJS-TNL (D. Minn).
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`19.
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`Exhibit 2070 is a true and correct copy of a document produced
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`publicly by Medtronic as MED001682~0001 in the case of Vascular Solutions LLC
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`v. Medtronic, Inc. , l9-cv—01760-PJS-TNL (D. Minn.)
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`Page 5
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 5
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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`20.
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`Exhibit 2071 is a true and correct copy of Exhibit A to the Complaint
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`filed on July 2, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc, 19-
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`cv-01760-PJS-TNL (D. Minn).
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`21.
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`Exhibit 2072 is a true and correct copy of the October 10, 2019
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`Declaration of Peter Keith in Support of Plaintiffs’ Motion for Preliminary
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`Injunction filed in the case of Vascular Solutions LLC v. Medtronic, Inc, l9-cv-
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`01760—PJS-TNL (D. Minn.)
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`22.
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`As of March 9, 2020, the parties in the case of Vascular Solutions
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`LLC v. Medtronic, Inc, 19-CV—01760-PJS~TNL (D. Minn.) have exchanged over
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`25,000 documents as part of the discovery process.
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`23.
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`Exhibit 2074 is a true and correct copy of the December 2, 2019
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`Declaration of Howard Root in Support of Plaintiffs’ Motion for Preliminary
`
`Injunction filed under seal in the case of Vascular Solutions LLC v. Medtronic,
`
`Inc, 19-cv—01760-PJS-TNL (D. Minn).
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: March 9 2020
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`
`./
`./ /,..:////,)
`// ,JfiM/‘fiwtw‘mmwM”WM“
`Alexander S. Rinn
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`Page 6
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`Teleflex EX. 2073
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`Medtronic v. Teleflex
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`IPR2020-00131
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`Page 6
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`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00131
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