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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` * * *
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` * * *
`
` NEW WORLD MEDICAL, INC.,
`
` Petitioner,
`
` v.
`
` MICROSURGICAL TECHNOLOGY, INC.,
`
` Patent Owner.
`
` * * *
`
` IPR2020-01573, IPR2020-01711, IPR2021-00017,
`
` IPR2021-00065, IPR2021-00066
`
` * * *
`
` Telephonic Hearing Held on Thursday, July 15,
`
` 2021, before the Honorable:
`
` RYAN H. FLAX, DEVON ZASTROW NEWMAN,
`
`ROBERT A. POLLACK, Administrative Patent Judges.
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` * * *
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
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`Petitioner - New World Medical
`Ex. 1026, p. 1 of 12
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
`
`

`

`1 APPEARANCES:
`2 On behalf of the Petitioner:
`3 Calfee, Halter & Griswold, LLP
`4 By: Todd R. Tucker
` Kyle T. Deighan
`5 Attorneys at Law
` 1405 East 6th Street
`6 The Calfee Building
` Cleveland, Ohio 44114
`7 216-622-8231
` ttucker@calfee.com
`8 kdeighan@calfee.com
`9 On behalf of the Patent Owner:
`10 Wiley Rein, LLP
`11 By: Lawrence M. Sung
` Teresa M. Summers
`12 Attorneys at Law
` 1776 K Street, NW
`13 Washington, D.C. 20006
` 202-719-4181
`14 lsung@wileyrein.com
` tsummers@wileyrein.com
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`15
`16
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`Page 2
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`Page 4
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`1 explain what it wants and why it needs it, and I
`2 will give patent owner an opportunity to respond
`3 also. So if you could identify yourselves as far
`4 as who we are speaking with and for which party,
`5 please start there.
`6 MR. DEIGHAN: Thank you, your Honor.
`7 This is Kyle Deighan representing petitioner. And
`8 also on the line is my colleague, Todd Tucker, for
`9 petitioner.
`10 MR. TUCKER: Hello, your Honor. I
`11 think it's going to be him doing the argument.
`12 JUDGE FLAX: Okay. And who else do
`13 we have?
`14 MR. SUNG: Good morning, your Honor.
`15 For patent owner, this is Lawrence Sung, and with
`16 me is Teresa Summers.
`17 JUDGE FLAX: Is Ms. Summers on record
`18 in the case? I don't recall seeing her name.
`19 MR. SUNG: Yes, she is, your Honor.
`20 And just as a point of clarification -- I
`21 apologize, as a point of clarification, with one
`22 of the IPRs, the patent owner in that case is the
`23 Regents of the University of California.
`24 JUDGE FLAX: Oh, okay. Thank you for
`25 updating that. Okay. So let's move ahead to what
`
`Page 3
`1 JUDGE FLAX: We are here concerning
`2 IPR 2020-01573, 2020-01711, 2021-00017,
`3 2021-00065, 2021-00066, if I am correct. Does
`4 anyone have anything else that they wanted to add
`5 to that list, is that correct?
`6 MR. SUNG: That's correct, your
`7 Honor.
`8 MR. DEIGHAN: Nothing from patent
`9 owner, your Honor.
`10 JUDGE FLAX: To help the court
`11 reporter when you speak, could you please identify
`12 yourself? And this is Judge Flax again.
`13 Each of these IPRs concerns New World
`14 Medical, Inc., as the petitioner versus
`15 Microsurgical Technology, Inc., as the patent
`16 owner. We are also joined by Judge Zastrow
`17 Newman. The panels on each of these cases are not
`18 identical, but we have judges from each panel.
`19 So on July 12th, we received an
`20 e-mail from petitioner's counsel concerning their
`21 desire to depose witness Dr. Manual Quintana, the
`22 patent owner's witness, who according to the
`23 e-mail is not in the United States but is in
`24 Spain.
`25 So what I will do is let petitioner
`
`Page 5
`
`1 petitioner has to say. Mr. Deighan, please go
`2 ahead.
`3 MR. DEIGHAN: Thank you, your Honors.
`4 So as a matter of routine discovery, petitioner is
`5 entitled to depose Dr. Quintana. And under 37 CFR
`6 42.53, a deposition should take place within the
`7 United States. Patent owner has indicated that
`8 Dr. Quintana will not be made available for
`9 deposition in the United States.
`10 Petitioner believes that it's crucial
`11 that we have an opportunity to depose Dr. Quintana
`12 in person and consistent with the rules in the US.
`13 I won't go too far into the weeds on this. But
`14 just to provide a little bit of background,
`15 Dr. Quintana is the author of one of petitioner's
`16 prior art references, which was written by
`17 Dr. Quintana in English in 1985.
`18 Patent owner has submitted a
`19 declaration from Dr. Quintana in these proceedings
`20 that from our perspective we believe contradicts
`21 the clear words of the prior art reference, and so
`22 the words are crucial here. To complicate
`23 matters, patent owner has indicated that
`24 Dr. Quintana does not speak English, and so we
`25 will require an interpreter or translator for a
`
`www.veritext.com
`
`Veritext Legal Solutions
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`2 (Pages 2 - 5)
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`888-391-3376
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`Petitioner - New World Medical
`Ex. 1026, p. 2 of 12
`
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
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`

`

`Page 6
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`Page 8
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`1 deposition.
`2 And so given the technical nature of
`3 the article and the importance of the words and,
`4 you know, the language barrier issues, we believe
`5 pretty strongly that this deposition should be
`6 held in person and that it would be extremely
`7 prejudicial to petitioner to do this using some
`8 sort of remote means. And, again, the rule
`9 dictates that the deposition, you know, should be
`10 within the United States.
`11 As I mentioned, patent owner has
`12 indicated that Dr. Quintana will not be made
`13 available in the US. They have provided no
`14 justification, except for simply that Dr. Quintana
`15 refuses to travel to the US.
`16 It's our understanding that there are
`17 no COVID-related travel restrictions to travel
`18 between the US and Spain. In fact, patent owner
`19 during the parties' meet and confer last week did
`20 not even mention COVID or any other health
`21 concerns as being justification for why he would
`22 not appear in the US.
`23 And it should have been entirely
`24 foreseeable to patent owner that Dr. Quintana
`25 would need to be made available for deposition,
`
`1 Dr. Quintana is an 85-year-old
`2 retired ophthalmologist who resides in Barcelona,
`3 Spain. He is a Spanish citizen. And while he
`4 does speak English, English is not his primary
`5 language.
`6 And as Exhibit 2020 in each of the
`7 five related IPRs shows, on May 17th of 2021,
`8 Dr. Quintana executed a sworn affidavit. Not a
`9 declaration, but a sworn affidavit in Barcelona,
`10 Spain, that was duly notarized and apostille under
`11 Spanish law.
`12 Now, Exhibit 2020 consists of eight
`13 paragraphs across three double-spaced pages total,
`14 five paragraphs of which are short, simple,
`15 declarative statements concerning the 1985 article
`16 that he solely authored, which is Exhibit 1004 in
`17 each of the five related IPRs.
`18 Dr. Quintana is an independent
`19 third-party fact witness. He is not being offered
`20 as an expert witness. His testimony is not on
`21 behalf of either party, but merely seeks to
`22 clarify what his article meant to report.
`23 Patent owner does not represent or
`24 speak for Dr. Quintana. And to patent owner's
`25 knowledge, neither party has sought to compel his
`
`Page 7
`1 and that would need to take place in the US when
`2 they submitted his declaration in these
`3 proceedings. And, you know, in our view just not
`4 wanting to travel to the US is not enough.
`5 And so we asked for this conference
`6 call with your Honors to seek guidance on how to
`7 proceed. You know, we think that Dr. Quintana
`8 should be ordered to be made available for
`9 deposition in the US.
`10 And if not, you know, we would seek
`11 an opportunity to move to strike his testimony.
`12 And so, again, we are kind of seeking guidance
`13 from your Honors on what the parties' next steps
`14 would be; whether it's a motion from our side,
`15 petitioner's side, to compel his deposition in the
`16 US or some other means.
`17 So, again, just seeking guidance from
`18 your Honor -- your Honors on the next steps.
`19 Thank you, your Honors.
`20 JUDGE FLAX: Okay, thank you. Moving
`21 on, Mr. Sung, what do you have to say?
`22 MR. SUNG: Yes, good morning, your
`23 Honors. This is Lawrence Sung for patent owners
`24 Microsurgical Technology and the Regents of the
`25 University of California.
`
`Page 9
`1 testimony. During the July 9th, 2021, meet and
`2 confer, patent owner's counsel explained that the
`3 patent owner does not have the ability to make
`4 Dr. Quintana available for deposition in the
`5 United States.
`6 Patent owner's counsel also indicated
`7 at that time that attempting to force Dr. Quintana
`8 to travel internationally while COVID-19 is still
`9 a concern, especially at his advanced age, was not
`10 commensurate with the scope of his limited and
`11 narrow testimony in Exhibit 2020.
`12 It's unclear what prejudice, if any,
`13 petitioner in this case would suffer if the board
`14 were to decide itself the appropriate way to
`15 accord Dr. Quintana's sworn statements. Just
`16 because petitioner doesn't like what Dr. Quintana
`17 said doesn't make his testimony adverse or
`18 unreliable.
`19 But in the spirit of compromise,
`20 patent owner's counsel raised the possibility of
`21 cross-exam by written interrogatories, for
`22 example, as a more suitable alternative to pursue,
`23 given the language translation issues.
`24 Petitioner's counsel hasn't provided
`25 any insight into what information they intend to
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`3 (Pages 6 - 9)
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`888-391-3376
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`Petitioner - New World Medical
`Ex. 1026, p. 3 of 12
`
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
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`

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`Page 10
`1 seek from Dr. Quintana on cross-examination that
`2 would be properly restricted to the limited
`3 testimony in the sworn affidavit. And that's all
`4 from patent owner's side, your Honors. Thank you.
`5 JUDGE NEWMAN: Counsel, this is Judge
`6 Newman. Have you explored the opportunity of a
`7 video deposition?
`8 MR. TUCKER: Your Honor, this is Todd
`9 Tucker for the petitioner. In a couple of other
`10 cases, I have been doing a series of depositions
`11 on Zoom involving translators in Macao, and it's
`12 been incredibly difficult.
`13 Given the nature with which
`14 Dr. Quintana is contradicting what he wrote in
`15 1985, I think that it will be very, very difficult
`16 when you are entirely focused on what words mean
`17 to be having a translator, a potential check
`18 translator, and all the parties on video. This is
`19 not going to be an efficient or fair deposition if
`20 it's done in that manner due to the multiple
`21 people that are going to need to be talking in
`22 this deposition.
`23 It's also -- I think there needs to
`24 be some exploration of, you know, English as
`25 second language and you need translator if you
`
`Page 11
`1 were able to write this article in 1985 to explain
`2 to the world what you were doing, which makes a
`3 little bit of this suspect. And I think it will
`4 be a difficult deposition -- extremely difficult
`5 deposition with the potential -- normally, you
`6 have two translators, the base translator and then
`7 the check translator and then multiple attorneys
`8 and the witness.
`9 It just seems like this would be
`10 very, very prejudicial and that we won't be able
`11 to test the sworn statement properly, do a proper
`12 cross-examination, your Honor. Thank you.
`13 MR. SUNG: Judge Newman, this is
`14 Lawrence Sung for patent owner. Let me just say
`15 that, of course, while we are aware that a
`16 possible mechanism would be video deposition,
`17 patent owner has taken no position on whether that
`18 would be appropriate here. And just as a
`19 remainder, we can't speak for Dr. Quintana in
`20 terms of his willingness to participate in a video
`21 deposition, either.
`22 Just as note, what I wanted to raise
`23 in response to what Mr. Tucker has mentioned,
`24 clearly the petitioner has had no problems relying
`25 on the 1985 article written in English until this
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`Page 12
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`1 very moment, and so I am not sure that the
`2 protests by petitioner regarding the deposition
`3 based on the language issues really applies in
`4 this particular case. Thank you.
`5 MR. TUCKER: If I may, your Honors, I
`6 think that's -- that's really a circular
`7 statement. This entire deposition will be what
`8 words in English mean, what they meant to
`9 Dr. Quintana when he wrote them and what they mean
`10 now that he has changed the definitions and
`11 changed the contents of his article some 30-odd
`12 years after he wrote it.
`13 So this is a deposition entirely
`14 focused on what words mean. So it is imperative
`15 that things are translated properly, that people
`16 are not speaking over each other, that we have a
`17 clear record, that we are able to overcome the
`18 communication barriers to determine exactly where
`19 he -- where the potential deponent, where this
`20 witness who is contradicting what he wrote, what's
`21 his basis for all that. And that's why this
`22 deposition needs to be in person, your Honors.
`23 JUDGE POLLACK: Counsel, this is
`24 Judge Pollack. It sounds to me as though
`25 Dr. Quintana is a third-party in a foreign
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`Page 13
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`1 country, and it might be pretty difficult to
`2 compel him to come here. So have the parties
`3 discussed taking his deposition in Spain?
`4 MR. TUCKER: Your Honor, this is
`5 Mr. Tucker again. We are willing to go to Spain
`6 if need be. We think the rule is that they need
`7 to provide him in the US. I know they are saying
`8 he is a third party.
`9 But they submitted the evidence, they
`10 need to make him available under 3742. And I am
`11 sorry, I got the rule wrong there, but under the
`12 rule. So, you know, I think if no deposition
`13 occurs, we are going to seek permission to file a
`14 motion to strike because we are not getting to
`15 test the deposition.
`16 We are willing to go to Spain,
`17 however. There are no -- again, as Mr. Deighan
`18 said, there's no travel restrictions. And
`19 Mr. Deighan and I are fully vaccinated, so we are
`20 willing to go as well. You know, if there is no
`21 deposition, however, you know, then I think we
`22 would be asking the board to strike the statement.
`23 MR. SUNG: And Judge Pollack, this is
`24 Lawrence Sung for patent owner.
`25 JUDGE FLAX: Mr. Sung, this is Judge
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`Veritext Legal Solutions
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`4 (Pages 10 - 13)
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`888-391-3376
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`Petitioner - New World Medical
`Ex. 1026, p. 4 of 12
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`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
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`

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`Page 14
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`Page 16
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`1 Flax.
`2 MR. SUNG: I'm sorry, Judge Flax.
`3 JUDGE FLAX: This is Judge Flax.
`4 Would you be willing to assist petitioner in
`5 getting Dr. Quintana to a deposition if they
`6 travel to Spain?
`7 MR. SUNG: The understanding would be
`8 that we would make the effort to reach out to
`9 Dr. Quintana to see if that were possible, but it
`10 is our understanding that he would not be willing
`11 to voluntarily submit to deposition.
`12 And, Judge Flax, if I could just
`13 answer Judge Pollack's question very briefly. We
`14 did want to say, again, just to reiterate that we
`15 do not control Dr. Quintana, and we don't really
`16 have an ability to compel him for additional
`17 deposition or additional testimony in other
`18 measures, either.
`19 What we are trying to do is to see if
`20 we can seek some type of cooperation with him
`21 about that. And so, again, because we don't speak
`22 for him, I could not tell you on the phone today
`23 what may or may not be possible from Dr. Quintana.
`24 The other point that I did want to
`25 make because Mr. Tucker has raised it is the
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`Page 15
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`1 Quintana article is a seven-page short article.
`2 Dr. Quintana's sworn affidavit similarly brief, as
`3 I mentioned. And it's only Mr. Tucker who is
`4 asserting today that the sworn statements of
`5 Dr. Quintana are in any way different or
`6 contradictory.
`7 I think that the board is in as good
`8 a position as anyone to look at the statements and
`9 make its own determination based on what's there,
`10 and as I mentioned as well, to determine whether
`11 there should be weight accorded to the sworn
`12 statement, the sworn affidavit.
`13 Again, it's been duly notarized and
`14 apostilled, and I hear petitioner today to concede
`15 that Dr. Quintana, the person who signed the sworn
`16 statement, is the same Dr. Quintana who authored
`17 the article. Thank you.
`18 MR. TUCKER: Your Honors, if I could
`19 just briefly respond, I think patent owner is
`20 missing the point that they have submitted this
`21 statement. And this statement, we are --
`22 petitioner is entitled to test that statement.
`23 And, you know, so a written
`24 interrogatory is not going to work. This is
`25 essentially direct testimony, and we are entitled
`
`1 to either have an opportunity to test it or it
`2 should be withdrawn.
`3 I think it's also a little
`4 questionable for patent owner to say they have no
`5 control over the witness when they were able to
`6 probably secure a sworn statement that we will
`7 find out if they helped draft it or not, but --
`8 and we are also -- since they do not represent
`9 him, I think another area that's extremely
`10 important is they have had communications with
`11 him.
`12 And we are entitled to find out about
`13 those communications because they -- since patent
`14 owner's counsel does not represent Dr. Quintana,
`15 there is clearly no privilege. So that is another
`16 area that needs to be explored, your Honor, to
`17 truly see what is the value of this after the
`18 fact, you know, 35 years later statement, your
`19 Honor. Thank you.
`20 JUDGE FLAX: I think what we will do
`21 right now is put you, counsel and the court
`22 reporter, on hold for a moment while the judges
`23 convene, unless you have something you want to add
`24 before we do that?
`25 MR. SUNG: Nothing from patent owner.
`
`Page 17
`1 MR. TUCKER: Kyle, anything else from
`2 petitioner?
`3 MR. DEIGHAN: Nothing else from
`4 petitioner.
`5 JUDGE FLAX: Okay. Please just hold
`6 on for a moment. Thank you.
`7 (Recess taken.)
`8 JUDGE FLAX: Okay, everybody. We are
`9 back. So having considered what everybody has
`10 said today, in the interest of fairness, we think
`11 that the parties need to work together to try to
`12 secure Dr. Quintana for a deposition in Spain.
`13 Based on what everybody has said, it
`14 appears that the patent owner is not controlling
`15 Dr. Quintana, has at least some relationship with
`16 him so that they could communicate with him, be in
`17 contact with him, and try to schedule something
`18 for a convenient time for petitioner's counsel to
`19 go to Spain and take a brief deposition of the
`20 doctor.
`21 What we want you to do is make these
`22 efforts together and report back to the board by
`23 e-mail by next Friday. Does everybody understand
`24 that?
`25 MR. TUCKER: For petitioner, this is
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`5 (Pages 14 - 17)
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`888-391-3376
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`Petitioner - New World Medical
`Ex. 1026, p. 5 of 12
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`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
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`

`

`Page 20
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`1 STATE OF OHIO )
`2 COUNTY OF MONTGOMERY ) SS: CERTIFICATE
`3 I, Monica K. Schrader, a Notary Public
`4 within and for the State of Ohio, duly
`5 commissioned and qualified,
`6 DO HEREBY CERTIFY that the above-named
`7 proceeding was reduced to writing by me
`8 stenographically in the presence of the parties
`9 and thereafter reduced to typewriting.
`10 I FURTHER CERTIFY that I am not a relative
`11 or Attorney of either party nor in any manner
`12 interested in the event of this action.
`13 IN WITNESS WHEREOF, I have hereunto set my
`14 hand and seal of office at Dayton, Ohio, on this
`15 15th day of July, 2021.
`16
`17
`18
`19
`20 <%22267,Signature%>
` MONICA K. SCHRADER
`21 NOTARY PUBLIC, STATE OF OHIO
` My commission expires 4-18-2025
`
`22
`23
`24
`25
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`Page 18
`1 Mr. Tucker. We understand, and we appreciate the
`2 board's assistance here.
`3 JUDGE FLAX: Mr. Sung, do you
`4 understand that?
`5 MR. SUNG: We do, your Honor. Thank
`6 you so much.
`7 JUDGE FLAX: And so as I just said,
`8 we want the parties to work together on this and
`9 to try to get Dr. Quintana available at some time.
`10 But we also would like for the petitioner to try
`11 to make everything as convenient for the witness
`12 as possible.
`13 So taking these things into
`14 consideration, please go ahead and then report
`15 back to us by e-mail by next Friday. And let's
`16 see, just to say it out loud, the date of next
`17 Friday is July 23rd, 2021. With that being
`18 understood, is there --
`19 MR. TUCKER: This is Mr. Tucker for
`20 petitioner --
`21 JUDGE FLAX: -- anything that the
`22 parties want to add before we conclude our
`23 conference call?
`24 MR. TUCKER: This is Mr. Tucker for
`25 petitioner. I think we have everything that we
`
`Page 19
`
`1 want to say. Mr. Deighan; is that correct?
`2 MR. DEIGHAN: Yes. Thank you, your
`3 Honors.
`4 MR. TUCKER: Thank you.
`5 JUDGE FLAX: Mr. Sung?
`6 MR. SUNG: And for patent owner,
`7 nothing further. Thank you, your Honors.
`8 JUDGE FLAX: Okay. If you have other
`9 questions, feel free to e-mail the board. And who
`10 was it that secured the court reporter for this?
`11 MR. TUCKER: That was petitioners.
`12 JUDGE FLAX: If you would get the
`13 transcript of the call as quickly as possible and
`14 submit it, we would appreciate that.
`15 MR. DEIGHAN: This is Kyle Deighan.
`16 We absolutely will, thank you.
`17 JUDGE FLAX: Okay. Well, thank the
`18 parties very much. If there is nothing further,
`19 then we will conclude. And not hearing anything,
`20 we will call this finished. And everyone have a
`21 wonderful day.
`22 (Thereupon, the hearing was concluded
`23 at 10:28 a.m.)
`24
`25
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`6 (Pages 18 - 20)
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`888-391-3376
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`Petitioner - New World Medical
`Ex. 1026, p. 6 of 12
`
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
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`

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`1004 8:16
`10:28 19:23
`12th 3:19
`1405 2:5
`15 1:14
`15th 20:15
`1776 2:12
`17th 8:7
`19 9:8
`1985 5:17 8:15
`10:15 11:1,25
`2
`20006 2:13
`202-719-4181 2:13
`2020 8:6,12 9:11
`2020-01573 3:2
`2020-01711 3:2
`2021 1:15 8:7 9:1
`18:17 20:15
`2021-00017 3:2
`2021-00065 3:3
`2021-00066 3:3
`216-622-8231 2:7
`22267 20:20
`23rd 18:17
`3
`30 12:11
`35 16:18
`37 5:5
`3742 13:10
`4
`4-18-2025 20:21
`42.53 5:6
`44114 2:6
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`6
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`8
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`9
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`6th 2:5
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`85 8:1
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`9th 9:1
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`a
`a.m. 19:23
`ability 9:3 14:16
`able 11:1,10 12:17
`16:5
`absolutely 19:16
`accord 9:15
`accorded 15:11
`action 20:12
`add 3:4 16:23
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`additional 14:16
`14:17
`administrative
`1:17
`advanced 9:9
`adverse 9:17
`affidavit 8:8,9
`10:3 15:2,12
`age 9:9
`ahead 4:25 5:2
`18:14
`alternative 9:22
`answer 14:13
`apologize 4:21
`apostille 8:10
`apostilled 15:14
`appeal 1:3
`appear 6:22
`appearances 2:1
`appears 17:14
`applies 12:3
`appreciate 18:1
`19:14
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`appropriate 9:14
`11:18
`area 16:9,16
`argument 4:11
`art 5:16,21
`article 6:3 8:15,22
`11:1,25 12:11
`15:1,1,17
`asked 7:5
`asking 13:22
`asserting 15:4
`assist 14:4
`assistance 18:2
`attempting 9:7
`attorney 20:11
`attorneys 2:5,12
`11:7
`author 5:15
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`communication
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`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Petitioner - New World Medical
`Ex. 1026, p. 7 of 12
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
`
`

`

`[communications - flax]
`
`communications
`16:10,13
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`13:2 14:16
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`www.veritext.com
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`17:18
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`e 3:20,23 17:23
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`Veritext Legal Solutions
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`Page 2
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`entitled 5:5 15:22
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`fact 6:18 8:19
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`4:12,17,24 7:20
`13:25 14:1,2,3,3
`14:12 16:20 17:5
`17:8 18:3,7,21
`
`888-391-3376
`
`Petitioner - New World Medical
`Ex. 1026, p. 8 of 12
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
`
`

`

`[flax - monica]
`
`19:5,8,12,17
`focused 10:16
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`foreign 12:25
`foreseeable 6:24
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`getting 13:14 14:5
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`identical 3:18
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`involving 10:11
`ipr 3:2
`ipr2020-01573
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`ipr2020-01711
`1:11
`ipr2021-00017
`1:11
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`ipr2021-00065
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`ipr2021-00066
`1:12
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`joined 3:16
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`k 2:12 20:3,20
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`language 6:4 8:5
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`m 2:11,11
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`3:15 7:24
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`moment 12:1
`16:22 17:6
`monica 20:3,20
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Petitioner - New World Medical
`Ex. 1026, p. 9 of 12
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
`
`

`

`[montgomery - raise]
`
`montgomery 20:2
`morning 4:14 7:22
`motion 7:14 13:14
`move 4:25 7:11
`moving 7:20
`multiple 10:20
`11:7
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`n
`name 4:18
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`occurs 13:13
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`ophthalmologist
`8:2
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`9:2,6,20 10:4
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`p
`page 15:1
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`19:6
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`3:14,25 4:7,9 5:1
`5:4,10 6:7 9:13,16
`10:9 11:24 12:2
`14:4 15:14,22
`17:2,4,25 18:10,20
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`petitioner's 3:20
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`petitioners 19:11
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`qualified 20:5
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`r
`
`r 2:4
`raise 11:22
`
`www.veritext.com
`
`888-391-3376
`
`Veritext Legal Solutions
`
`Petitioner - New World Medical
`Ex. 1026, p. 10 of 12
`New World Medical, Inc. v. MicroSurgical Tech., Inc., IPR2020-01573
`
`

`

`[raised - transcript]
`
`raised 9:20 14:25
`reach 14:8
`really 12:3,6 14:15
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`received 3:19
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`record 4:17 12:17
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