`Cc:
`Date:
`Attachments:
`
`Niederluecke, Kurt; MDT-VSI
`VSI-MDT
`Friday, January 24, 2020 5:21:11 PM
`Ex V - 116 Claim Chart.pdf
`Ex U - USRE46116.pdf
`Ex T - 413 Claim Chart.pdf
`Ex S - US8142413.pdf
`Compare.pdf
`2020 01 24 Teleflex First Amended Complaint DRAFT.pdf
`
`Kurt,
`
`We plan on moving to amend the complaint to add counts for infringement of U.S. Patent Nos.
`8,142,413 and RE46,116. Attached for your reference is a copy of the proposed amended complaint
`(in clean and redline from the original complaint) and additional exhibits. The scheduling order
`states that all motions to amend the pleadings need to be served on or before February 1, so please
`let us know by the end of business on Tuesday (1/28) whether Medtronic opposes the motion.
`
`We also intend on supplementing the complaint in light of some recent corporate agreements. My
`understanding is that the agreements are going to be signed early next week and will have an
`effective date of February 3. You will see that we have drafted the amended complaint so that we
`can do this all in one step. We will forward the new agreements to you promptly once they are
`signed.
`
`Regards,
`Derek
`
`
`
`Derek Vandenburgh
`Carlson, Caspers, Vandenburgh, &
`Lindquist, P.A.
`225 S. Sixth St., Suite 4200,
`Minneapolis,MN 55402
`Direct: 612.436.9618
`Cell: 612-991-3952
`DVandenburgh@carlsoncaspers.com
`carlsoncaspers.com
`BIO | vCard | Disclaimers
`
`
`
`
`
`
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