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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.
`
`Petitioners,
`
`V.
`
`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
`
`DECLARATION OF ALEXANDER S. RINN SUBMITTED IN
`
`CONNECTION WITH PATENT OWNER’S PRELIMINARY RESPONSES
`
`Page 1
`
`Teleflex EX. 2073
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 1
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

`

`1, Alexander S. Rinn, hereby declare and state as follows:
`
`1.
`
`I am a member of the bar of the district of Minnesota.
`
`I am an
`
`attorney at Carlson, Caspers, Vandenburgh & Lindquist, P.A., which represents
`
`Patent Owner in the IPR proceedings initiated by Medtronic, Inc. and Medtronic
`
`Vascular, Inc. I make this Declaration in connection with Patent Owner’s
`
`Preliminary Responses to Petitions filed by Medtronic, Inc. and Medtronic
`
`Vascular, Inc.
`
`2.
`
`Exhibit 2043 is a true and correct copy of the October 11, 2019
`
`Declaration of Amy Welch 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).
`
`3.
`
`Exhibit 2044 is a true and correct copy of the partially redacted
`
`October 11, 2019 Declaration of Amy Welch in Support of Plaintiffs’ Motion for
`
`Preliminary Injunction filed in the case of Vascular Solutions LLC v. Medtronic,
`
`Inc. , l9-cv—01760-PJS~TNL (D. Minn).
`
`4.
`
`Exhibit 2045 is a true and correct copy of Plaintiffs’ Second
`
`Supplemental Objections and Response to Defendants’ Interrogatory No. 7
`
`Concerning Preliminary Injunction Issues served on November 6, 2019 in the case
`
`of Vascular Solutions LLC v. Medtronic, Inc, l9-cv-01760-PJS-TNL (D. Minn.)
`
`Page 2
`
`Teleflex EX. 2073
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 2
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

`

`5.
`
`Exhibit 2046 is a true and correct copy of the June 10, 2013
`
`Declaration of Howard Root in Support of Plaintiff’s Motion for Preliminary
`
`Injunction filed in the case of Vascular Solutions, Inc. v. Boston Scientific
`
`Corporation, 13-CV-01172 (JRT—SER) (D. Minn.)
`
`6.
`
`Exhibit 2048 is a true and correct copy of the partially redacted
`
`Defendants’ Opposition to Plaintiffs’ Motion for Preliminary Injunction filed in the
`
`case of Vascular Solutions LLC v. Medtronic, Inc, l9-cv—01760-PJS-TNL (D.
`
`Minn.)
`
`7.
`
`Exhibit 2049 is a true and correct copy of the Amended Pretrial
`
`Scheduling Order from the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-
`
`cv—Ol760-PJS—TNL (D. Minn).
`
`8.
`
`Exhibit 2050 is a true and correct copy of Defendants’ Second
`
`Amended Notice of Deposition of Peter Keith served on September 30, 2019 in the
`
`case of Vascular Solutions LLC v. Medtronic, Inc, 19—cv—01760—PJ S-TNL (D.
`
`Minn.)
`
`9.
`
`Exhibit 2051 is a true and correct copy of Defendants’ Amended
`
`Notice of Deposition ofAmy Welch served on October 9, 2019 in the case of
`
`Vascular Solutions LLC v. Medtronic, Inc, 19—cv—01760—PJS-TNL (D. Minn.)
`
`Page 3
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 3
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

`

`10.
`
`Exhibit 2052 is a true and correct copy of drawings submitted to the
`
`US. Patent Office on August 9, 2002 in connection with US. Patent Application
`
`10/214,712 by inventor Thomas V. Ressemann.
`
`11.
`
`Exhibit 2053 is a true and correct copy of Defendants’ Interrogatories
`
`to Plaintiffs Concerning Preliminary Injunction Issues served on July 25, 2019 in
`
`the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-cv-01760-PJS-TNL (D.
`
`Minn).
`
`12.
`
`Exhibit 2054 is a true and correct copy of Defendants’ Requests for
`
`Production of Documents Concerning Preliminary Injunction Issues served on July
`
`25, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc. , l9-cv—01760-
`
`PJS-TNL (D. Minn).
`
`13.
`
`Exhibit 2056 is a true and correct copy of the Expert Report of Peter
`
`T. Keith on Infringement, Claim Coverage, and Lack of Acceptable Noninfringing
`
`Alternatives filed publicly as Exhibit 23 to the Declaration of Courtland Merrill in
`
`Support of QXMédical LLC’s Motion for Summary Judgment in the case of
`
`QXMédical v. Vascular Solutions, LLC, 17-cv—01969-PJS-TNL (D. Minn).
`
`14.
`
`Exhibit 2057 is a true and correct copy of a PDF printout of a
`
`Teleflex webpage titled “Product Patents” available at
`
`https://Www.teleflex.com/usa/en/product-areas/interventional/patents/index.
`
`Page 4
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 4
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

`

`15.
`
`Exhibit 2059 is a true and correct copy of Plaintiffs” First
`
`Supplemental Objections and Responses to Defendants” Interrogatories
`
`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.
`
`Minn.).
`
`16.
`
`Exhibit 2060 is a true and correct copy of a printout of a September
`
`25, 2019 Teleflex press release titled “Teleflex Announces Tenth Anniversary of
`
`GuideLiner Catheter Product Line.”
`
`17.
`
`Exhibit 2068 is a true and correct copy of Defendants’ Answer,
`
`Defenses, and Counterclaims to Plaintiffs’ Complaint filed on August 23, 2019 in
`
`the case of Vascular Solutions LLC v. Medtronic, Inc. , 19-cv-01760-PJS-TNL (D.
`
`Minn.)
`
`18.
`
`Exhibit 2069 is a true and correct copy of Exhibit E to the Complaint
`
`filed on July 2, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc, 19-
`
`cv-01760-PJS-TNL (D. Minn).
`
`19.
`
`Exhibit 2070 is a true and correct copy of a document produced
`
`publicly by Medtronic as MED001682~0001 in the case of Vascular Solutions LLC
`
`v. Medtronic, Inc. , l9-cv—01760-PJS-TNL (D. Minn.)
`
`Page 5
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 5
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

`

`20.
`
`Exhibit 2071 is a true and correct copy of Exhibit A to the Complaint
`
`filed on July 2, 2019 in the case of Vascular Solutions LLC v. Medtronic, Inc, 19-
`
`cv-01760-PJS-TNL (D. Minn).
`
`21.
`
`Exhibit 2072 is a true and correct copy of the October 10, 2019
`
`Declaration of Peter Keith in Support of Plaintiffs’ Motion for Preliminary
`
`Injunction filed in the case of Vascular Solutions LLC v. Medtronic, Inc, l9-cv-
`
`01760—PJS-TNL (D. Minn.)
`
`22.
`
`As of March 9, 2020, the parties in the case of Vascular Solutions
`
`LLC v. Medtronic, Inc, 19-CV—01760-PJS~TNL (D. Minn.) have exchanged over
`
`25,000 documents as part of the discovery process.
`
`23.
`
`Exhibit 2074 is a true and correct copy of the December 2, 2019
`
`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).
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: March 9 2020
`
`
`./
`./ /,..:////,)
`// ,JfiM/‘fiwtw‘mmwM”WM“
`Alexander S. Rinn
`
`Page 6
`
`Teleflex EX. 2073
`
`Medtronic v. Teleflex
`
`IPR2020-00135
`
`
`Page 6
`
`Teleflex Ex. 2073
`Medtronic v. Teleflex
`IPR2020-00135
`
`

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