`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
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`EDWARDS LIFESCIENCES CORPORATION,
`
`
`
`Petitioner,
`
`v.
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`ENDOHEART AG,
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`Patent Owner.
`
`____________
`
`Case IPR2016-00300
`
`U.S. Patent No. 8,182,530
`
`____________
`
`DECLARATION OF RUBY J. NATNITHITHADHA
`
`
`
`
`
`Edwards Exhibit 1046, pg. 1
`Edwards vs. Endoheart
`IPR2016-00300
`
`
`
`
`
`
`
`Pursuant to 28 U.S.C. § 1746, I, Ruby J. Natnithithadha, the undersigned,
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`hereby declare as follows:
`
`1. My name is Ruby J. Natnithithadha. I am over eighteen years of age, of
`
`sound mind, and in all ways qualified and competent to make this
`
`declaration. I have personal knowledge of the facts contained in this
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`declaration and they are true and correct.
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`2. I am a Senior Attorney at the law firm of Oblon, McClelland, Maier &
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`Neustadt, LLP. and back-up counsel in the Petition filed by Edwards
`
`Lifesciences Corporation on December 9, 2015.
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`3. On February 17, 2016 Endoheart’s counsel, Edward Arons, sent an email
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`correspondence to Edwards Lifesciences Corporation’s counsel of record,
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`identifying a discrepancy related to the Mandatory Notices section of the
`
`Petition. This was the first time Edwards Lifesciences Corporation’s
`
`counsel was put on notice or aware of any issue related to the Mandatory
`
`Notices.
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`4. The discrepancy was in fact the result of a clerical error regarding the
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`relationship between the two Edwards Lifesciences entities identified in
`
`the Mandatory Notices section of the Petition.
`
`
`
`
`
`2
`
`Edwards Exhibit 1046, pg. 2
`Edwards vs. Endoheart
`IPR2016-00300
`
`
`
`
`
`5. I attest that on a teleconference with Keith Newburry, Catherine Nyarady
`
`and Todd Baker on December 8, 2015, we discussed the relationship
`
`between the real parties-in-interest in the instant proceeding.
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`6. I attest I mis-transcribed into the Petition that Edwards Lifesciences, LLC
`
`is the parent company of Edwards Lifesciences Corporation. See Petition
`
`at 20.
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`7. As supported by the attached document, Exhibit 1047, downloaded from
`
`www.sec.gov on March 3, 2016, the public records plainly identify
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`Edwards Lifesciences, LLC as a wholly owned entity of Edwards
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`Lifesciences Corporation.
`
`
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the results of these proceedings.
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`Date: March 22, 2016
`
`
`
`
`
`
`
`
`
` /Ruby J. Natnithithadha/
`
`
`Ruby J. Natnithithadha
`
`
`
`
`
`
`
`
`
`3
`
`Edwards Exhibit 1046, pg. 3
`Edwards vs. Endoheart
`IPR2016-00300
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