`FOR THE DISTRICT OF MINNESOTA
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`VASCULAR SOLUTIONS LLC,
`TELEFLEX INNOVATIONS S.à r.l.,
`ARROW INTERNATIONAL, INC.,
`and TELEFLEX LLC
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`v.
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`MEDTRONIC, INC., and
`MEDTRONIC VASCULAR, INC.,
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`Plaintiffs,
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`Defendants.
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`No. 0:19-cv-01760-PJS-TNL
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`Jury Trial Demanded
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`PLAINTIFFS’ OBJECTIONS AND RESPONSES TO DEFENDANTS’
`INTERROGATORIES CONCERNING PRELMINARY INJUNCTION ISSUES
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`Plaintiffs Vascular Solutions LLC, Teleflex Innovations S.à r.l., Arrow
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`International, Inc., and Teleflex LLC (collectively “Plaintiffs”) hereby object and respond
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`to Defendants Medtronic, Inc., and Medtronic Vascular, Inc.’s (“Defendant” or
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`“Medtronic”) Interrogatories Concerning Preliminary Injunction Issues as follows:
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`INTRODUCTION
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`Plaintiffs will respond to Medtronic’s Interrogatories in accordance with the
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`federal discovery rules and laws, and the rules of this Court, including but not limited to
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`Federal Rule of Civil Procedure 26 for purposes of the preliminary injunction
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`proceedings. Plaintiffs are only required by the Federal Rules of Civil Procedure to
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`search for and produce responsive information within their personal knowledge or from
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`documents within their possession, custody, or control, that are located following a
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`1
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`Page 1
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`Medtronic Exhibit 1884
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`versions of the “Telescope” guide extension catheter since 2019), Boston Scientific (all
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`versions of the “Guidezilla” guide extension catheter since 2013), and QX Medical (all
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`versions of the “Boosting Catheter” guide extension catheter since 2017). For the time
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`period after Boston Scientific’s Guidezilla entered the U.S. market, pursuant to Federal
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`Rule of Civil Procedure 33(d), Plaintiffs respond by identifying at least the documents
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`produced as VSIQXM_E00056205, -56290, -56291, and -56292. Plaintiffs are collecting
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`and will produce and identify additional documents from which additional information
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`responsive to this Interrogatory can be derived or ascertained.
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`INTERROGATORY NO. 7:
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`For each claim in the Patents-in-Suit, identify the Date of first conception and each
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`reduction to practice, and describe the facts and circumstances relating to your contention
`of the conception and reduction to practice of the alleged invention, including, without
`limitation, where, when, how, and by whom the claim was conceived and reduced to
`practice, and identify all documents and things allegedly corroborating such conception
`and diligence in reducing the claimed invention to practice.
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`RESPONSE:
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`Plaintiffs object to this Interrogatory to the extent that it seeks information subject
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`to the attorney-client privilege, work product doctrine, or any other privilege. Plaintiffs
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`do not agree to waive any applicable privilege by its response to this Interrogatory.
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`Plaintiffs further object to this Interrogatory as overly broad, unduly burdensome,
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`irrelevant, and not proportional to the needs of the case at least to the extent it seeks
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`information regarding the conception and reduction to practice for “each claim in the
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`Patents-in-Suit,” because only a limited number of the large number of claims of the
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`Patents-in-Suit are at issue in this litigation and because not all claims asserted against
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`8
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`Page 2
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`Medtronic Exhibit 1884
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`Defendants in Plaintiffs’ Complaint are included in Plaintiffs’ motion for preliminary
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`injunction.
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`Subject to and without waiving the foregoing objections, Plaintiffs respond that
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`the inventors came up with the idea for what became the GuideLiner catheter product and
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`that led to the inventions claimed in the patents-in-suit at some point in 2004 after the
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`annual Transcatheter Cardiovascular Therapeutics conference that took place in late
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`September of that year. Pursuant to Federal Rule of Civil Procedure 33(d), Plaintiffs
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`further respond by identifying at least the following documents: pages from Gregg
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`Sutton’s laboratory notebook dated January 4, 2005 (VSIQXM_E00005937), Howard
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`Root’s notes dated February 7, 2005 (VSIQXM_E00005949), and Howard Root’s market
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`feasibility memorandum dated February 4, 2005 (VSIQXM_E00005947).
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`INTERROGATORY NO. 8:
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`Identify each claim in the Patents-in-Suit that you have alleged or will allege is
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`infringed by Telescope.
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`RESPONSE:
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`Plaintiffs object to this Interrogatory to the extent that it seeks information subject
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`to the attorney-client privilege, work product doctrine, or any other privilege. Plaintiffs
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`do not agree to waive any applicable privilege by its response to this Interrogatory.
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`Plaintiffs further object to this Interrogatory as seeking information already provided in
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`its Complaint. Plaintiffs further object to this Interrogatory as premature, particularly to
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`the extent it requires Plaintiffs to set forth their infringement positions before the deadline
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`for infringement contentions has been set by the court and to the extent it calls for a legal
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`9
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`Page 3
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`Medtronic Exhibit 1884
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`Dated: August 15, 2019
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`s/ J. Derek Vandenburgh
`J. Derek Vandenburgh (#224145)
`Tara C. Norgard (#307683)
`Joseph W. Winkels (#349707)
`Alexander S. Rinn (#385616)
`Shelleaha L. Jonas (#398417)
`CARLSON, CASPERS, VANDENBURGH &
`LINDQUIST, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, Minnesota 55402
`(612) 436-9600 Telephone
`(612) 436-9605 Facsimile
`dvandenburgh@carlsoncaspers.com
`tnorgard@carlsoncaspers.com
`jwinkels@carlsoncaspers.com
`arinn@carlsoncaspers.com
`sjonas@carlsoncaspers.com
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`Attorneys for Plaintiffs Vascular Solutions LLC,
`Teleflex Innovations S. à r.l., Arrow
`International, Inc., and Teleflex LLC
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`11
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`Page 4
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`Medtronic Exhibit 1884
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`CERTIFICATE OF SERVICE
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`I certify that I caused to be served Plaintiffs’ Objections and Responses to
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`Defendants’ Interrogatories Concerning Preliminary Injunction Issues via email, as
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`agreed to by the parties, on the following persons or entities on the date noted below:
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`Kurt J. Niederluecke
`Lora M. Friedemann
`Laura L. Myers
`Anne E. Rondoni Tavernier
`FREDRIKSON & BYRON, P.A.
`200 South Sixth Street, Suite 4000
`Minneapolis, MN 55402-1425
`Telephone: 612.492.7000
`Facsimile: 612.492.7077
`kniederluecke@fredlaw.com
`lfriedemann@fredlaw.com
`lmyers@fredlaw.com
`arondonitavernier@fredlaw.com
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`Attorneys for Defendants
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`Dated: August 15, 2019
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`s/ J. Derek Vandenburgh
`J. Derek Vandenburgh (#224145)
`Tara C. Norgard (#307683)
`Joseph W. Winkels (#349707)
`Alexander S. Rinn (#385616)
`Shelleaha L. Jonas (#398417)
`CARLSON, CASPERS, VANDENBURGH &
`LINDQUIST, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, Minnesota 55402
`(612) 436-9600 Telephone
`(612) 436-9605 Facsimile
`dvandenburgh@carlsoncaspers.com
`tnorgard@carlsoncaspers.com
`jwinkels@carlsoncaspers.com
`arinn@carlsoncaspers.com
`sjonas@carlsoncaspers.com
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`12
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`Page 5
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`Medtronic Exhibit 1884
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