`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.
`Petitioners,
`
`v.
`
`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
`
`Case IPR2020-01344
`Patent RE46,116
`
`Declaration of Tara C. Norgard in Support of Patent Owner’s Unopposed
`Motion for Pro Hac Vice Admission
`
`
`
`
`
`I, Tara C. Norgard, hereby declare as follows:
`
`1.
`
`I am an attorney with the law firm of Carlson, Caspers,
`
`Vandenburgh & Lindquist P.A. (“Carlson Caspers”). This declaration is
`
`submitted on behalf of Patent Owner Teleflex in support of its Unopposed
`
`Motion for Pro Hac Vice Admission of Litigation Counsel. This declaration is
`
`made on my own personal knowledge, except as otherwise indicated.
`
`2.
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`I am a member in good standing of the Bar of the State of
`
`Minnesota (Minnesota Bar Number 0307683).
`
`3.
`
`I have never been suspended or disbarred from any court
`
`or administrative body.
`
`4.
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`No application for admission to practice before any court or
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`administrative body that I have filed or that has been filed on my behalf has
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`ever been denied.
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`5.
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`No sanctions or contempt citations have been imposed on me by
`
`any court or administrative body.
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`6.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37
`
`C.F.R.
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`
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`7.
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`I agree to be subject to USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
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`8.
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`In the past three years I have applied for, pro hac vice admission
`
`before the Patent Trial and Appeal Board in the following related matters:
`
`Medtronic, Inc., et al. v. Teleflex Innovations S.A.R.L., IPR2020-00126,
`
`IPR2020-00127, IPR2020-00128, IPR2020-00129, IPR2020-00130, IPR2020-
`
`00132, IPR2020-00134, IPR2020-00135, IPR2020-00136, IPR2020-00137, and
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`IPR2020-00138. I am also concurrently filing motions for pro hac vice
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`admission in the following related matters: Medtronic, Inc. et al. v. Teleflex
`
`Innovations S.A.R.L., IPR2020-01341, IPR2020-01342, and IPR2020-01343.
`
`9.
`
`I have been involved in many litigations involving patent
`
`infringement in multiple federal District Courts. I have practiced law for more
`
`than twenty years and I have litigated patent and other types of cases during that
`
`entire time period. I have extensive experience with patent issues related to
`
`anticipation under 35 U.S.C. §102 and obviousness under 35 U.S.C. §103, which
`
`are the legal theories on which this Inter Partes Review was instituted. In the
`
`course of my experience litigating patents, I have analyzed many pieces of prior
`
`art, prepared many prior art statements and responses, worked with validity
`
`
`
`experts, and drafted and filed briefing related to anticipation and obviousness
`
`arguments.
`
`10.
`
`I am familiar with the subject matter at issue in this proceeding. My
`
`law firm, Carlson Caspers, represents Patent Owner in a patent infringement
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`lawsuit that is pending in the United States District Court for the District of
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`Minnesota (Civil Action. No. 19-cv-1760 (PJS/TNL), filed July 2, 2019), in
`
`which I am an attorney of record for Patent Owner. This lawsuit involves the
`
`patents at issue in this and related Inter Partes Reviews, U.S. Patent Nos.
`
`8,048,032, RE45,380, RE45,760, RE45,776, and RE47,379, and involves the
`
`same parties. I have had a substantial, substantive role in all briefing and proceedings
`
`before the district court. I, along with Mr. Vandenburgh, presented oral argument in
`
`support of Patent Owner’s motion for a preliminary injunction in the district court, and
`
`have presented oral argument on discovery issues before the court. I also defended one
`
`of two depositions of Patent Owner witnesses that took place before discovery was
`
`stayed in the district court action. Through my work on this case, I have gained
`
`familiarity with the technology, issues, and subjects at issue and the patents at
`
`issue in this IPR and the related IPR proceedings.
`
`11.
`
`I have also reviewed in detail each of U.S. Patent Nos. 8,142,413,
`
`RE46,116, 8,048,032, RE45,380, RE45,760, RE45,776, RE47,379, the Petitions
`
`and corresponding exhibits and expert declarations filed by Petitioner Medtronic
`
`
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`in this and the related proceedings, the Patent Owner’s Preliminary Responses, and
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`the Board’s Decisions instituting review. Further, I have reviewed in detail the
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`prior art references cited by Medtronic’s Petitions and relied on by the Board in
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`instituting this review.
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`12. Having practiced in the area of patent law generally, and medical
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`device technology specifically, since the beginning of my career as an attorney in
`
`private practice, I have additional understanding of the technology, issues, and
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`subject matter at issue in these IPR proceedings.
`
`
`
`
`
`
`
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`I state under penalty of perjury that the foregoing is true and correct.
`
`Dated: July, 9 2021
`
`
`
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`
`
`
`
`/ Tara C. Norgard /
`Tara C. Norgard
`
`
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