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`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.
`Petitioners,
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`v.
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`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
`
`
`
`
`Case IPR2020-00132
`Patent RE 45,760E
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`PATENT OWNER’S OBJECTIONS TO PETITIONER’S REPLY
`EVIDENCE
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`1
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner hereby submits its notice
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`of objections to certain evidence that Petitioner submitted in connection with
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`IPR2020-00126, -0127, -0128, -0129, -0130, -0132, -0134, -0135, -0136, -0137,
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`and -0138, including evidence submitted in connection with Petitioner’s briefing
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`relating to conception and reduction to practice.
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`Patent Owner notes that certain exhibits were cited in one or more of the
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`above-referenced IPR proceedings but do not appear to have been filed (either at
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`all or only in some of the IPRs); Patent Owner reserves the right to file
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`supplemental and/or additional objections and/or move to strike those exhibits.1
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`Given the apparent omission of certain exhibits from certain IPRs, for the sake of
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`consistency and clarity, Patent Owner submits the below single set of objections.
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`In addition, the depositions of Patent Owner’s experts Mr. Keith and Dr.
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`Graham in the eleven instituted IPRs each occurred over two days. It appears that
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`Petitioner only filed certain days of deposition transcripts in certain IPRs and not in
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`others. As noted below, Patent Owner objects to this practice on the basis of
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`incompleteness (see FRE 106). In addition, the parties’ practice in these IPRs has
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`been to file deposition transcripts in each of the eleven instituted IPRs, and
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`Petitioner had represented it intended to do so.
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`1 By way of example, it appears that Petitioner cited but did not file Ex-1839, Ex-
`1840, and Ex-1841.
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`1
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`Exhibit Number
`1108/1308/1708
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`1114/1314/1714
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`1115
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`
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`Objections
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the June 20, 2018 deposition of
`Greg Sutton.
`
`FRE 802: This document is hearsay.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the June 27, 2013 deposition of
`Howard Root.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the June 15, 2018 deposition of
`Howard Root.
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`FRE 802: This document is hearsay.
`
`2
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`1116
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`1122
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`1123
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`1800
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`1801
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`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 106: Patent Owner objects to the filing of only Day 2
`of the transcript, when in fairness Day 1 of the transcript
`ought to be considered at the same time.
`
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the November 24, 2020 deposition
`of Peter Keith.
`FRE 106: Patent Owner objects to the filing of only Day 2
`of the transcript, when in fairness Day 1 of the transcript
`ought to be considered at the same time.
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`3
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`1802
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`1803
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`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the November 19, 2020 deposition
`of John J. Graham.
`FRE 106: Patent Owner reserves the right to introduce all
`or any portion of the cited reference that in fairness ought
`to be considered at the same time.
`
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`
`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`4
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`1804
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`1805
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`1806
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`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the November 23, 2020 deposition
`of Peter Keith.
`Patent Owner objects to Exhibit 1806 to the extent Dr.
`Brecker has not disclosed materials considered other than
`those referenced in his declaration. See 37 C.F.R. §§
`42.65(a) and (b). Patent Owner additionally objects to
`Exhibit 1806 to the extent it improperly raises new
`arguments in support of Petitioner’s Reply. 37 C.F.R. §
`42.23(b).
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`FRE 702, 703, 37 C.F.R. §§ 42.65:
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`¶¶ 10-13, 16, 19-25, 31-34, 38-39, 40, 44-56, 59-61, 66-
`77, 81-90, 93-97, 100-104, 107-115, 118-123, 125, 129-
`136, 141, 143-150, 152-158, 160-167, 169-173, 176-179,
`181-182, 185-186, 189-191, 194-199, and 204 are not
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`5
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`based on sufficient facts and data and do not reliably
`apply facts and data using scientific principles.
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`FRE 401, 402, 403:
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`§§ III, IV.C, and ¶¶ 4-5, 28, 152, 173, 197-200, and 201-
`219 are not relevant; to the extent they are relevant, their
`probative value is outweighed by the danger of causing
`unfair prejudice and confusing the issues.
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`FRE 702, 703, 704:
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`¶¶ 7-8, 26, 34, 57, 62, 78, 98, 105, 116, 123, 126, 137,
`141, 167, 180-181, 187, 192, 194, 200, and 204 state
`improper legal conclusions.
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`FRE 602:
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`¶¶ 15-16, 19, 30, 134, 141, 145, 160, 162, 166, 170, 171,
`191, and 217 are not based on personal knowledge.
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`Patent Owner additionally objects to Exhibit 1806 under
`FRE 802 (hearsay) to the extent that Patent Owner does
`not have the opportunity to cross-examine Dr. Brecker
`regarding his declaration.
`Patent Owner objects to Exhibit 1807 to the extent
`Michael Jones has not disclosed materials considered
`other than those referenced in his declaration. See 37
`C.F.R. §§ 42.65(a) and (b). Patent Owner additionally
`objects to Exhibit 1807 to the extent it improperly raises
`new arguments in support of Petitioner’s Reply. 37
`C.F.R. § 42.23(b).
`
`FRE 702, 703, 37 C.F.R. §§ 42.65:
`
`¶¶ 35-42, 44-46, 49-81, 95-96, 102-03, 105-110, 112-120,
`121-133, 135-139, 141-146, 152, 154-158, 161-163, 169-
`195, 197-199, and 201-206 are not based on sufficient
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`6
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`1807
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`facts and data and do not reliably apply facts and data
`using scientific principles.
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`FRE 401, 402, 403:
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`§§ IV-VIII and ¶¶ 50, 82-92, 174, 188-190 and 208-216
`are not relevant; to the extent they are relevant, their
`probative value is outweighed by the danger of causing
`unfair prejudice and confusing the issues.
`
`Patent Owner additionally objects to Exhibit 1807 under
`FRE 802 (hearsay) to the extent that Patent Owner does
`not have the opportunity to cross-examine Michael Jones
`regarding his declaration.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
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`7
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`1808
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`1809
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`1810
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`1811
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`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 106: Patent Owner objects to the filing of only Day 1
`of the transcript, when in fairness Day 2 of the transcript
`ought to be considered at the same time.
`
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the November 18, 2020 deposition
`of John J. Graham.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
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`8
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`1812
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`1813
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`1814
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`1815
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`1816
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`1817
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`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
`FRE 106: Patent Owner reserves the right to introduce all
`or any portion of the cited transcript that in fairness ought
`to be considered at the same time.
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`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the December 7, 2020 deposition
`of Craig A. Thompson.
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`9
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`1818
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`1819
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`1820
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`FRE 106: Patent Owner reserves the right to introduce all
`or any portion of the cited reference that in fairness ought
`to be considered at the same time.
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`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the December 7, 2020 deposition
`of Craig A. Thompson.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections under 37 C.F.R.
`§ 42.64(a) made during the December 7, 2020 deposition
`of Lorenzo Azzalini.
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`10
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`1821
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`1822
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`1823
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`1824
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`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403. Patent Owner
`reasserts and reserves all of its objections made during the
`October 30, 2019 deposition of Amy L. Welch.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`11
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403.
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`Patent Owner objects to Exhibit 1830 to the extent Dr.
`Zalesky has not disclosed materials considered other than
`those referenced in his declaration. See 37 C.F.R. §§
`42.65(a) and (b).
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`FRE 702, 703, 37 C.F.R. §§ 42.65:
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`¶¶ 17 and 25 are not based on sufficient facts and data and
`do not reliably apply facts and data using scientific
`principles.
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`FRE 401, 402, 403:
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` §
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` V is not relevant; to the extent it is relevant, its probative
`value is outweighed by the danger of causing unfair
`prejudice and confusing the issues.
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`Patent Owner additionally objects to Exhibit 1830 under
`FRE 802 (hearsay) to the extent that Patent Owner does
`not have the opportunity to cross-examine Dr. Zalesky
`regarding his declaration.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
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`12
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`1825
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`1830
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`1836
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`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
`
`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: This document is not relevant. To the
`extent this document is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time,
`or needlessly presenting cumulative evidence, and
`therefore the document is inadmissible under Rule 403.
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`FRE 802: This document is hearsay.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
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`13
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`1837
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`1838
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`1842
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`1843
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`1844
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`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
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`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403.
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`FRE 901, 902: This document has not been authenticated.
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`35 U.S.C. § 311: This document does not qualify as a
`printed publication.
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`FRE 401, 402, 403: Portions of this document are not
`relevant. To the extent this document is relevant, the
`probative value of certain portions is outweighed by the
`danger of causing unfair prejudice, confusing the issues,
`causing undue delay, wasting time, or needlessly
`presenting cumulative evidence, and therefore those
`portions are inadmissible under Rule 403.
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`14
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`Dated: December 30, 2020.
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`Respectfully submitted,
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`
`/J. Derek Vandenburgh /
`J. Derek Vandenburgh (Lead Counsel)
`Registration No. 32,179
`Carlson, Caspers, Vandenburgh
` & Lindquist, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, MN 55402
`Telephone: (612) 436-9600
`Facsimile: (612) 436-9650
`Email:
`DVandenburgh@carlsoncaspers.com
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`Lead Counsel for Patent Owner
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`15
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`CERTIFICATION OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e) and the agreement of the parties, the
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`
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`undersigned certifies that on December 30, 2020, a true and correct copy of the
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`foregoing Patent Owner’s Objections to Petitioner’s Reply Evidence was served
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`via electronic mail upon the following:
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`Cyrus A. Morton (Reg. No. 44,954)
`Sharon Roberg-Perez (Reg. No. 69,600)
`Christopher A. Pinahs (Reg. No. 76,375)
`William E. Manske
`Emily J. Tremblay
`Robins Kaplan LLP
`800 LaSalle Avenue, Suite 2800
`Minneapolis, MN 55401
`Phone: 349-8500
`Fax: 612-339-4181
`Email: Cmorton@robinskaplan.com
`Email: Sroberg-perez@robinskaplan.com
`Email: Cpinahs@robinskaplan.com
`Email: WManske@robinskaplan.com
`Email: ETremblay@robinskaplan.com
`
`
`
`
`
`
`
`
`
`/J. Derek Vandenburgh/
`J. Derek Vandenburgh (Lead Counsel for Patent Owner)
`
`
`
`
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