`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`NE W WORLD MEDICAL, INC.,
`Petitioner,
`
`v.
`
`MICROSURGICAL TECHNOLOGY, INC.,
`Patent Owner.
`
`Case IPR2020-01573
`
`U.S. Patent No. 9,107,729
`
`DECLARATION OF MAEVE HICKEY IN SUPPORT OF
`PATENT O WNER'S MOTION FOR ADDITIONAL DISCOVERY
`
`Patent Owner Ex. 2011-0001
`
`
`
`I, Maeve Hickey, make the following declaration pursuant to 28 U.S.C. § 1746:
`
`L I am a project assistant at the law firm of Wiley Rein LLP.
`
`2. I provide this Declaration in connection with the above-identified Inter
`
`Partes Review proceeding. Unless otherwise stated, the facts stated in this
`
`Declaration are based on my personal knowledge.
`
`3. Exhibit 2002 is a true and correct copy of Erin G. Sieck et al., Outcomes
`
`of Kahook Dual blade Goniotomy with and without Phacoemulsification Cataract
`
`Extraction, 1 Ophthalmology Glaucoma, 75-81 (2018). This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`co rner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`4. Exhibit 2003 is a true and correct copy of Todd Neff, UCHealth Eye
`
`Center lands global innovation awards, UCHealth Today, January 6, 2016. This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`5. Exhibit 2004 is a true and correct copy of the Complaint for Patent
`
`Infringement (ECF No. 1) in Mic�oSu�gical Technology, Inc., et al. v. New World
`
`Medical, Inc., Case No. 1:20-cv-00754-UNA (D. Del.), filed June 4, 2020. This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`Patent Owner Ex. 2011-0002
`
`
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`6. Exhibit 2005 is a true and correct copy of a presentation by New World
`
`Medical titled "KDB Competitive: Trabectome/Goniotome {MST}, available at
`
`<https ://www.learn.newworldmedical. com/wp-content/uploads/2020/04/ MST-
`
`Trabectome-Goniotome-min.pdf� and last accessed October 30, 2020. This
`
`document has been marked with an exhibit label and page numbers on each page at
`
`the bottom right corner. However, no alterations, other than these noted markings,
`
`have been made to this document.
`
`7. Exhibit 2006 is a true and correct copy of U.S. Patent No. 10,327,947.
`
`This document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right co rner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`8. Exhibit 2007 is a true and correct copy of an October 21, 2015 press
`
`release titled "New World Medical to Launch the Kahook Dual Blade at AAO
`
`Meeting." This document has been marked with an exhibit label and page numbers
`
`on each page at the bottom right co rner. However, no alterations, other than these
`
`noted markings , have been made to this document.
`
`9. Exhibit 2008 is a true and correct copy of University of Colorado a
`
`global leader in patents fog inventions, innovations, CU Connections, June 11, 2020.
`
`Patent Owner Ex. 2011-0003
`
`
`
`This document has been marked with an exhibit label and page numbers on each
`
`page at the bottom right corner. However, no alterations, other than these noted
`
`markings, have been made to this document.
`
`10. Exhibit 2009 is a true and correct copy of Draft Proposed Patent
`
`Owner's Additional Discovery Requests.
`
`11. Exhibit 2010 is a true and correct copy of an email conversation
`
`between Lawrence Sung, counsel for Patent Owner, and Kyle Deighan, counsel for
`
`Petitioner, containing messages from October 6-7, 2020. This document has been
`
`marked with an exhibit label and page numbers on each page at the bottom right
`
`corner. However, no alterations, other than these noted markings, have been made
`
`to this document.
`
`12. I make this declaration of my own personal knowledge. if called to
`
`testify as to the truth of the matters stated herein, I could and would testify
`
`competently.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 30th day of October, 2020, in Maryland.
`
`is/ Maeve M. Hickey
`Maeve M. Hickey
`
`Patent Owner Ex. 2011-0004
`
`
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