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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________________________________________________
`MEDTRONIC, INC., and
`MEDTRONIC VASCULAR, INC.,
`
` Petitioners,
`
`vs.
`
`TELEFLEX INNOVATIONS
`S.A.R.L.,
` Patent Owner.
`_______________________________________________________
`
`IPR2020-01341 (Patent 8,142,413 B2)
`IPR2020-01342 (Patent 8,142,413)
`IPR2020-01343 (Patent RE46,116 E)
`IPR2020-01344 (Patent RE46,116)
`____________________________________________________
` VIDEOCONFERENCE VIDEOTAPED
` DEPOSITION OF
` STEPHEN BRECKER, M.D.
`
`DATE: April 20, 2021
`TIME: 10:03 a.m.
`PLACE: London, England
`(via videoconference)
`JOB NO.: MW 4517226
`REPORTED BY: Dawn Workman Bounds, CSR
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`Page 2
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`A P P E A R A N C E S
` (ALL APPEARANCES VIA VIDEOCONFERENCE)
`ON BEHALF OF PETITIONERS:
` SHARON ROBERG-PEREZ, ESQ.
` RYAN DORNBERGER, ESQ.
` CYRUS A. MORTON, ESQ.
` ROBINS KAPLAN LLP
` 2800 LaSalle Plaza
` 800 LaSalle Ave
` Minneapolis, MN 55401
` 612.349.8500
` camorton@rkmc.com
` RDornberger@RobinsKaplan.com
` sroberg-perez@robinskaplan.com
`
`ON BEHALF OF PATENT OWNER:
`
` ALEX S. RINN, ESQ.
` PETER KOHLHEPP, ESQ.
` JOSEPH W. WINKELS, ESQ.
` CARLSON CASPERS VANDENBURGH & LINDQUIST, PA.
` Capella Tower, Suite 4200
` 225 South Sixth Street
` Minneapolis, MN 55402
` 612.436.9623
` arinn@@carlsoncaspers.com
` pkohlhepp@carlsoncaspers.com
` jwinkels@carlsoncaspers.com
`
`ALSO PRESENT:
` Rob Adams, Videographer
` Greg Smock, Teleflex
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`Page 3
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` I N D E X
`WITNESS: STEPHEN BRECKER, M.D. PAGE
`EXAMINATION BY MR. RINN............................ 6
`EXHIBITS PREVIOUSLY MARKED/REFERRED TO
`No. 1001: U.S. Patent Application 8,142,413
` March 27, 2012.......................... 74
`
`No. 1005: Declaration of Stephen Brecker
` July 30, 2020........................... 8
`No. 1006: Curriculum Vitae........................ 17
`No. 1007: U.S. Patent Application 7,736,355
` June 15, 2010........................... 97
`
`No. 1008: U.S. Patent Application 7,604,612
` October 20, 2009........................ 121
`No. 1025: U.S. Patent Application 2005/0015073
` January 2005............................ 123
`
`No. 1405: Final Declaration of Stephen Brecker
` July 30, 2020........................... 9
`No. 1409: U.S. Patent Application 5,439,445
` August 8, 1995.......................... 128
`
`No. 1410: Takahashi Article....................... 146
`
`No. 1435: U.S. Patent Application 2004/0010280
` January 15, 2004........................ 142
`No. 2116: Deposition Transcript of Stephen
` Brecker, August 11, 2020................ 11
`
`No. 2238: Deposition Transcript of Stephen
` Brecker, January 14, 2021............... 14
`No. 2240: Deposition Transcript of Stephen
` Brecker, January 19, 2021............... 16
`
`No. 3010: Brecker Errata Sheet, 8/11/20........... 13
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`No. 3011: Brecker Errata Sheet, 9/14/20........... 14
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` P R O C E E D I N G S
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` THE VIDEOGRAPHER: Good morning. We are
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`going on the record at 10:03 a.m. on April 20, 2021.
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`Please note that the microphones are sensitive and may
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`pick up whispering, private conversations and cellular
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`interference. Please turn off all cell phones or place
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`them away from the microphones, as they can interfere
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`with the deposition audio. Audio and video recording
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`will continue to take place unless all parties agree to
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`go off the record.
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` This is Media Unit 1 of the video-recorded
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`deposition of Stephen Brecker taken by counsel in the
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`matter of Medtronic, Inc., et al., versus Teleflex
`
`Innovations, S.A.R.L., filed in the United States Patent
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`Trial and Trademark Office.
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` This deposition is being held via
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`videoconference. My name is Rob Adams from the firm
`
`Veritext Legal Solutions and I am the videographer. The
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`court reporter is Dawn Bounds from the firm Veritext
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`Legal Solutions. I am not authorized to administer an
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`oath. I am not related to any party in this action nor
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`am I financially interested in the outcome.
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` Counsel and all present in the room and
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`everyone attending remotely will now state their
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`appearances and affiliations for the record. If there
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`Page 5
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`are any objections to proceeding, please state them at
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`the time of your appearance, beginning with the noticing
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`attorney.
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` MR. RINN: I'm Alex Rinn from Carlson
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`Caspers on behalf of the patent owner Teleflex. With me
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`today are going to be Peter Kohlhepp and Joe Winkels,
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`also from Carlson Caspers. Dr. John Graham is attending,
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`and Greg Smock from Teleflex is attending as well.
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` MS. ROBERG-PEREZ: On behalf of petitioner
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`Medtronic, Sharon Roberg-Perez, Robins Kaplan. With me
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`are my colleagues Cy Morton and Ryan Dornberger.
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` THE REPORTER: Due to the need for this
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`deposition to take place remotely because of the
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`government's order for physical distancing, the parties
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`will stipulate the court reporter may swear in the
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`witness over the videoconference and that the witness has
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`verified that he is in fact Stephen Brecker, M.D.
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` Agreed, counsel?
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` MR. RINN: Agreed.
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` MS. ROBERG-PEREZ: Agreed.
`
` STEPHEN BRECKER, M.D.,
`
`duly sworn via videoconference as stipulated by counsel
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`was examined and testified as follows:
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`Page 6
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` EXAMINATION
`
`BY MR. RINN:
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` Q. Thank you, Dr. Brecker. We've not had a chance
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`to meet before. My name is Alex Rinn from the Carlson
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`Caspers firm. It's morning for us, good afternoon for
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`you -- or still morning to you I guess as well.
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` A. Yes, it's 10:06 a.m.
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` Q. Okay, great. Where are you physically located
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`today?
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` A. I'm at St. George's Hospital in South London.
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` Q. Okay. And is there anyone with you in the room
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`today?
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` A. There is not.
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` Q. Okay. I understand you've done a number of
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`these depositions before in matters related to the IPRs
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`we'll be talking about this morning. So I think you
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`probably understand how this works. But this deposition
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`is obviously being held over Zoom, so it's especially
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`important that we try not to talk over each other.
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` I'll ask my questions. Please let me
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`finish my question, and then I will let you respond, and
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`we'll try not to speak over each other as the day
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`proceeds.
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` Does that make sense?
`
` A. It does.
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` Q. Okay. Is there any reason you can't testify
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`Page 7
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`truthfully today?
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` A. There is not.
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` Q. Okay. Now, you have submitted four different
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`declarations in connections with the 1341, 1342, 1343,
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`and 1344 IPRs related to the '413 patent and the '116
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`patent; is that correct?
`
` A. That's correct.
`
` Q. Okay. And if I refer today to U.S. Patent
`
`Number 8,142,413 as the '413 patent, will you know which
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`patent I'm referring to?
`
` A. I will.
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` Q. Okay. And similarly, if I refer to U.S. Patent
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`Number RE 46116 as the '116 patent, you'll understand
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`what I'm referring to?
`
` A. I will.
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` Q. Okay. And same with the different IPR numbers,
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`if I refer to the 1341 IPR or the 1342 IPR, 1343 IPR, or
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`the 1344 IPR, you'll understand which IPRs I'm referring
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`to?
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` A. Yes. I may not have them immediately in my
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`head which is which, but I'll know what you're referring
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`to.
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` Q. Okay. And we can always kind of orient
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`ourselves if we need to.
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` So I believe you have a binder of
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`materials with you today; is that right?
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` A. Yes. This -- I received this -- I got this
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`last night, yeah.
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` Q. Okay. Great.
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` Let's go ahead and just kind of start
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`introducing a few of these exhibits, and then we'll talk
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`about some of them.
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` So if you turn to what I believe should be
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`the third tab of your binder, it should be labeled
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`Medtronic Exhibit 1005. And is this a declaration that
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`you submitted in connection with the 1341 IPR related to
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`the '413 patent?
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` A. That's correct. Yes.
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` Q. Okay. I am just going to take one second and
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`move this over to Exhibit Share so we have it as part of
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`the official record here.
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` Dr. Brecker, are you able to access
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`Exhibit Share today?
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` A. Yes, I have that on a separate desktop computer
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`on my desk. I'm doing this deposition on a laptop.
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` Q. Okay.
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` A. I have the Exhibit Share locked in on my desk.
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` I can see some previous entries from the
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`depositions I did in January, and then there is one from
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`today dated 20 April.
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` Q. Okay. Great. Great.
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` So I should have just moved the -- your
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`declaration from the 1341 case into the marked exhibits
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`folder.
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` And do you see that that has populated?
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` A. I can see that, yes.
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` Q. Okay. Great.
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` And today you can use either the materials
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`that we put on to Exhibit Share or the materials in your
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`binder. Unless -- unless I mention otherwise, they
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`should all be the same document. So whatever is more
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`convenient for you, feel free to use that.
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` A. Thank you.
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` Q. Okay. Let's turn to the next tab in your
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`binder. It should be marked Medtronic Exhibit 1405.
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` And it is -- does this appear to be your
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`declaration from the 1342 case related to the '413 IPR?
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` A. Yes, it does.
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` Q. Okay. Then we'll go ahead and move this one
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`into Exhibit Share.
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` Okay. If you could turn to the next tab
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`in your binder.
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` Is this the declaration you submitted in
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`the 1343 case related to the '116 patent?
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` A. Yes, it is, yes.
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` Q. And it is labeled Medtronic Exhibit 1005; is
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`that correct?
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` A. It is, yes.
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` Q. Okay. All right. If we go to the next tab in
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`your binder. This one should be labeled Medtronic
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`Exhibit 1405. And is this the declaration you submitted
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`in connection with the 1344 IPR related to the '116
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`patent?
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` A. It is, yes.
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` Q. Great.
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` Okay. What did you do to prepare to
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`testify at today's deposition?
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` A. So I've done some reading on my own of the
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`declarations; not -- haven't learned them by heart, but
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`I've refreshed my memory since it's sometime since I put
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`these in. And I've had two teleconferences with Robins
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`Kaplan.
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` Q. Okay. And did you review other -- any other
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`materials aside from the four declarations we just spoke
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`about?
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` A. So I just refreshed my memory on some of the
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`prior art and looked through some of the transcripts of
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`the previous depositions.
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` Q. Okay.
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` A. There's obviously a huge amount of material in
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`this case, and this time it hasn't been possible to put
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`as much time aside with everything else that's been going
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`on. So -- but I have done reading.
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` Q. Okay. You mentioned you reviewed some of your
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`prior deposition transcripts.
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` Why don't we turn to -- I don't
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`believe it's -- it's not the next tab in your binder but
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`it should be the one after that. It should be labeled
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`Exhibit 2116.
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` Do you see that in your binder?
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` A. Yes. Yes, I do.
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` Q. Okay. So this is labeled Exhibit 2116, and the
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`first page of this exhibit is titled Videotaped
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`Deposition of Stephen J.D. Brecker, M.D.; date, August
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`11, 2020.
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` Do you see that?
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` A. I do, yes.
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` Q. Okay. And this document actually has two
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`different deposition transcripts kind of combined into
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`one exhibit. So if you page to page 118 of this exhibit,
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`I believe you'll see the start of the second transcript
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`that's actually part of this exhibit.
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` Do you see that?
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` A. Yes, I do.
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` Q. Okay. Great.
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` So this second deposition transcript that
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`is part of Exhibit 2116 is titled Videotaped Deposition
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`of Stephen J.D. Brecker, M.D., Volume 2; date, September
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`14, 2020; is that correct?
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` A. Yes, I see that.
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` Q. Okay. And if you flip through these, do these
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`appear to be the transcripts from the depositions you
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`gave on August 11, 2020, and September 14, 2020?
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` A. Yes, they appear to be. I haven't studied
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`these ones -- these documents specifically in this
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`binder; but I'm assuming they are, exactly.
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` Q. Okay. Okay. And did you testify truthfully at
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`those two depositions?
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` A. I did.
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` Q. Okay. And are these two of the transcripts
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`that you reviewed prior to today's deposition?
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` A. Well, I haven't -- obviously, I haven't read
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`through the entirety of the transcripts.
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` I can't read them much faster than I've
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`said them.
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` Q. Okay.
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` A. So it would take me as long.
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` So I've looked at certain portions that
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`I've reviewed, but not -- not in -- not in huge detail.
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`Page 13
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`I haven't been through them word for word.
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` Q. Okay. After you testified in the August 11th
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`and September 14th, 2020, depositions, did you have a
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`chance to review the transcripts after those depositions
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`and did you review those transcripts after those
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`depositions?
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` A. I think so. I think I had to review and make
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`corrections. And with the number of depositions in this
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`case, sitting here now I cannot recall specifically if I
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`did that for each and every one.
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` I know that in general after a deposition,
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`I would receive the transcript and I would make
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`corrections; but I -- and I think that those corrections
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`may be in this. I saw one of them. Whether I did it for
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`all of the declara -- or all of the depositions, I can't
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`be a hundred percent certain, but I think I would have
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`done.
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` Q. Okay. If you go to I think -- skip two tabs in
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`your binder, and I believe you should see a tab labeled
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`Exhibit 3010.
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` A. Yes.
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` Q. Okay. And does this appear to be the errata
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`sheet that you provided in connection with the August
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`11th deposition you gave?
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` A. Yeah, I -- so I've only just seen this
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`Page 14
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`document. Can I -- if this relates to the August -- and
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`this is at one of the sorts of sheets I did of these.
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`And if this is the August 11th, then -- I can't see the
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`date. Actually this says -- on the front of this, this
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`says deposition date September 14.
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` Q. I think you have to go one tab back in your
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`binder perhaps.
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` A. Okay. Yeah.
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` So, yeah, this one is August 11. The
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`3-0 -- Exhibit 3010 is the errata sheet which I completed
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`for the August 11 deposition.
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` Q. Okay. Great.
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` Okay. So if we go to the next tab then,
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`Exhibit 3011, is that the errata sheet that you provided
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`in connection with the September 14 deposition?
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` A. Yes, it is.
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` Q. Okay.
`
` Okay. Let's go back a couple more tabs in
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`your binder to Exhibit 2238.
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` A. Yes.
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` Q. Okay. This -- this document is labeled Exhibit
`
`2238, and it's titled Videotaped Deposition of
`
`Dr. Stephen Brecker; date, January 14, 2021.
`
` Does this appear to be the deposition
`
`transcript from your January 14 deposition?
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` A. Yes, it does.
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` Q. Okay. And did you testify truthfully at that
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`Page 15
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`deposition?
`
` A. I did.
`
` Q. And had you had a chance to review this
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`deposition transcript after you provided your testimony
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`and provide any corrections if necessary?
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` A. So I'm not sure if there are correction sheets
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`for this. And I -- I can't -- honestly I cannot -- I
`
`cannot recall if I did or not provide corrections.
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` Q. Okay.
`
` A. If I did, I would have thought they would be
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`here. So I just don't recall. January was an intensely
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`difficult month in the U.K. in the hospital, and I -- so
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`I just don't recall if I did or not.
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` Q. Yeah, understood. That's okay.
`
` If you did provide any corrections or
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`errata sheet, would you have sent them to the Robins
`
`Kaplan firm?
`
` A. Yes, that was the standard that I would do is
`
`just e-mail -- complete the sheets and e-mail it.
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` Q. Okay.
`
` A. But I truthfully cannot recall if I did that or
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`not for this one and potentially the next one in January.
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`It's possible I did; I just don't remember.
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` Q. Okay. I'm just making sure this has been moved
`
`into Exhibit Share. Bear with me one second.
`
` Okay. If we go to the next tab in your
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`Page 16
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`binder. This is labeled Exhibit 2240.
`
` Do you see that?
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` A. I do.
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` Q. Okay. And this document is titled Remote
`
`Videotaped Deposition of Stephen Brecker, M.D.; date,
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`January 19, 2021; is that correct?
`
` A. Correct.
`
` Q. And does this appear to be the deposition
`
`transcript from your January 19, 2021, deposition?
`
` A. It does.
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` Q. All right. And did you testified truthfully at
`
`that deposition?
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` A. I did.
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` Q. Okay. And I know you just explained how you
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`weren't sure if you've actually had a chance to review
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`and submit an errata sheet for this deposition
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`transcript; is that correct?
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` A. Yes, I can't recall.
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` Q. Okay. But if you did, any changes would have
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`been submitted to the Robins Kaplan firm; is that right?
`
` A. Yes.
`
` Q. Okay.
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`Page 17
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` MR. RINN: Okay. We're just about through
`
`this administrative task of introducing these exhibits.
`
`BY MR. RINN:
`
` Q. Let's go to your CV quickly, Exhibit 1006.
`
` A. Yes.
`
` Q. Okay. And this document is Exhibit 1006; it's
`
`titled Curriculum Vitae, Stephen Jon David Brecker; is
`
`that correct?
`
` A. That's correct.
`
` Q. And is this a copy of the CV that you provided
`
`in connection with each of the four IPRs that we're
`
`discussing today?
`
` A. Well, this would have been my original CV I
`
`submitted in the case. The only -- the only reason I'm
`
`hesitating -- the answer is yes, it's the one that was
`
`submitted. I'm just looking at the latest date of
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`publications which goes up to 2019, which makes me think
`
`that this is a 2019 version; and because there's several
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`publications since then, there is a -- there is more
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`up-to-date version of my CV. It's a continual process.
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`And there's been a change in my status and appointments.
`
`But the CV is the one I would have submitted in this case
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`to Robins Kaplan.
`
` Q. Okay. What -- what is the update to your
`
`appointments that you believe is missing from this CV?
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`Page 18
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` A. So it's simply that I've completed a six-year
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`term as chief of cardiology at the hospital and
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`university. And so next month I'm formally handing --
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`I've already done a handover on the academic university
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`side. And because of the pandemic, I stayed on as
`
`clinical lead, but that will hand over next month.
`
` It's just an end of the term of office of
`
`chief of cardiology.
`
` Q. Sure. And how will your role change once that
`
`transition is completed?
`
` A. Oh, so the chief of cardiology, as you can
`
`appreciate, is a huge administrative responsibility and
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`role. So I had taken a lot of time after my working week
`
`to do that and have academic meetings in the university,
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`and on the clinical side was involved in the pandemic
`
`planning action. So those aspects of my job will go. My
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`clinical work will increase as a result. I hadn't
`
`stopped doing clinical work. I've always been doing
`
`clinical work. But it's just a reconfiguration of hours
`
`of time in terms of administrative responsibilities.
`
` Q. Okay. Will you be doing similar kinds of
`
`clinical work going forward as you had in the past six
`
`years?
`
` A. Yes, although there will be a slightly expanded
`
`role in doing some more teaching and also expanding some
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`Page 19
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`of the structural heart interventions that we're doing,
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`for which I would be the lead but recruiting new members
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`of staff as well.
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` The university have asked me to stay on in
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`an advisory role for clinical research. So that will
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`stay. But I will no longer be the person that has to
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`sort out all the problems.
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` Q. I can imagine that will be a bit of a relief
`
`after --
`
` A. Yes.
`
` Q. -- several years.
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` A. Yeah, particularly the last -- yeah, it's
`
`been -- it's a difficult role. You know, there's 23
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`cardiologists here, so you can imagine managing them.
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`And this -- this role, so it will just -- it will just
`
`become -- I'll just be a clinician again, which I'm
`
`looking forward to.
`
` Q. Okay. We'll talk a little bit more about your
`
`particular clinical experience. But you -- I believe you
`
`said -- you mentioned that your -- you may have an
`
`expanded role in the structural heart work that you do.
`
` Can you say a little bit more about that.
`
` A. Only that we're planning to expand the
`
`portfolio procedures we do in partnership with some other
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`hospitals in South London.
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`Page 20
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` So, for example, transcatheter mitral
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`interventions, which we had some experience of, but
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`starting transcatheter mitral valve interventions;
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`significant expansion on our patent foramen ovale closure
`
`program is a big backlog of patients, so I'm leading
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`that.
`
` Q. Okay. And you had -- is it correct that you
`
`had not previously done these kinds of procedures at your
`
`current hospital?
`
` A. No, no, it's -- that's not correct. I've done
`
`these procedures before. The last year they've pretty
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`much not been done for obvious reasons, and there's a big
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`backlog. They're expanding to clear that. And in
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`addition we're expanding to some procedures we have not
`
`done before.
`
` Q. I see. Okay.
`
` A. That's the plan anyway.
`
` Q. I'm sorry. I think I spoke over you there. I
`
`apologize.
`
` A. No, I just said that's the plan.
`
` Q. I see. Okay.
`
` And what are the procedures that you're
`
`expanding to that you had not done before? Is that the
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`mitral valve replacement and the patent closure?
`
` A. No. The first one is correct. The
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`Page 21
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`transcatheter mitral valve implantation is not a
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`procedure we have done before at St. George's.
`
` We've been involved in programs with
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`partner hospitals, but not on site here. Patent foramen
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`ovale, we -- I have been doing for 20 years.
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` For various reasons the program paused
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`before the pandemic because of government regulations in
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`terms of the procedure. They stopped it nationally.
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`Then they restarted it at selected hospitals, of which we
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`were one. Then it stopped again because of the pandemic,
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`and now we're restarting.
`
` Q. Okay. Are there any other kind of procedures
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`that you've not previously done at your current hospital
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`that you'll be expanding into?
`
` A. Well, there's plenty of adjunctive techniques
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`to the procedures we do already but we haven't
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`specifically done. But I'm trying to think of other
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`procedures -- completely different procedures. I mean
`
`there's tricuspid valve interventions that we've been
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`looking into.
`
` Yeah, so...
`
` Q. Okay. When we were introducing your CV, I
`
`believe you said there were some publications that -- or
`
`the publication list may not be completely up to date.
`
` I guess maybe I'll first start asking, you
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`Page 22
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`know, how many publications do you think are missing from
`
`the -- say, from the past two or three years?
`
` A. Oh, so if this -- so I'm looking at the actual
`
`peer review publications, not the abstracts.
`
` Q. Okay.
`
` A. You'd lose count of the abstracts. They'll be
`
`a lot of abstracts of international meetings.
`
` In terms of publications in peer review
`
`journals, these go up to 2019. I would estimate that
`
`there's probably maybe another 8 to 10 publications on --
`
`if I looked at my current CV and compared it, maybe - I
`
`mean I'm guessing - but it would be that order.
`
` Q. Yep. And do you recall, maybe not -- I don't
`
`know if we need specifics, but the general nature of the
`
`research that you would have been publishing on in those
`
`8 to 10 articles you think may be missing?
`
` MS. ROBERG-PEREZ: Object to form.
`
` A. Yeah, they're in the field predominantly of
`
`transcatheter interventions and specifically
`
`transcatheter valve interventions.
`
` Q. Okay. You can't think of any other procedures
`
`or technologies that you've written a peer review journal
`
`article on in the past couple of years that do not appear
`
`in your CV, other than the transcatheter valve papers you
`
`just mentioned?
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`Page 23
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` A. I haven't written an article or paper myself on
`
`another field. It's possible -- and again I'm guessing,
`
`because I haven't got the document in front of me.
`
` It's possible I'm a named author on a
`
`multicenter paper on another area, but I'd have to pull
`
`up my current CV to answer your question.
`
` Q. Okay. That's fine.
`
` Okay. So it sounds like you have spent
`
`most of your clinical time -- I understand you've had a
`
`number of administrative duties over the past years, but
`
`most of your clinical time in the transcatheter valve
`
`field; is that correct?
`
` Sorry, let me rephrase that.
`
` Have you spent most of your time in the
`
`transcatheter valve field over the past six years?
`
` A. I would put it a little bit more broadly. Most
`
`of my clinical work in the last six years has been in the
`
`field of structural heart interventions. However, as
`
`chief of cardiology, I have to have an overview on the
`
`clinical service, clinical governance and research on all
`
`the areas. So I would have been immersed in all of the
`
`areas, particularly within the catheter lab but in the
`
`clinic as well.
`
` Q. Okay. It sounds like your clinical work
`
`anyway, not your oversight work but your clinical work,
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`has been largely in the structural heart field over the
`
`past six years, or has it been more than that?
`
` A. Certainly in the last six years. That's been
`
`my personal clinical experience. It's not a hard and
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`fast. I've been in the catheter lab with my patients who
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`have been having coronary interventions. My own personal
`
`first operator experience in the last six years has been
`
`predominantly in the field of structural heart
`
`intervention.
`
` Q. Okay. When was the last time you personally
`
`did a PCI procedure, for example?
`
` A. So I would -- I personally did one quite
`
`recently with another operator. But I mean I do them
`
`with other operators, not -- I think the question you may
`
`be asking is when did I last do a personal first operator
`
`angioplasty procedure; and that's something like 10 years
`
`ago.
`
` Q. Okay.
`
` A. Yeah, around that time is when I was
`
`transitioning into a lot of research and development in
`
`the structural heart space, and therefore I had to reduce
`
`that activity.
`
` Sorry. That was my answer.
`
` Q. Yeah -- oh, no. I'm sorry. I'm reviewing
`
`something. I apologize.
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`Page 25
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` Thank you.
`
` A. I thought you were waiting for me.
`
` Q. No, no. Sorry.
`
` Okay. So over the past roughly 10 years
`
`you've been focused in the structural heart area?
`
` Prior to that, you had performed more, I
`
`believe you called it, first operator angioplasty
`
`procedures; is that correct?
`
` A. Yes, prior to then I was absolutely immersed in
`
`coronary intervention from my appointment as a consultant
`
`cardiologist. Until that time I was absolutely -- that's
`
`what I was appointed to do. That was during the period
`
`in which there was intense expansion of coronary
`
`intervention. And I was doing upwards of -- hundreds and
`
`hundreds of procedures a year.
`
` So I was appointed as a consultant in 1996
`
`and -- under the wave of the stenting frenzy, and the
`
`expansion and rollout of primary angioplasty, and I was
`
`involved in research, clinical writing, clinical trials,
`
`coordination, pathways of care, everything. That's what
`
`I was doing for the whole of that time period.
`
` Q. Okay. So is it fair to say that your career
`
`has kind of been broken up into two clinical portions?
`
`You know, it sounds like you started in the coronary
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`intervention field from 1996 all the way up until about
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`Page 26
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`approximately 2010, 2011; and then since then you've been
`
`more focused on structural heart; is that correct?
`
` MS. ROBERG-PEREZ: Object to form;
`
`mischaracterizes the testimony.
`
` A. I wouldn't say I look upon it like that. I
`
`mean, I think a career is an evolution. So I wo

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