UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`EDWARDS LIFESCIENCES CORPORATION, EDWARDS LIFESCIENCES
`LLC, AND EDWARDS LIFESCIENCES AG
`Petitioners
`
`v .
`
`BOSTON SCIENTIFIC SCIMED, INC.
`Patent Owner
`
`Case IPR2017-01293
`Patent 8,992,608
`
`MOTION FOR JOINDER
`PURSUANT TO 35 U.S.C. § 315(c) AND 37 C.F.R. § 42.122(b)
`
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`EDWARDS LIFESCIENCES CORPORATION, EDWARDS LIFESCIENCES
`LLC, AND EDWARDS LIFESCIENCES AG
`Petitioners
`
`v .
`
`BOSTON SCIENTIFIC SCIMED, INC.
`Patent Owner
`
`Case IPR2017-01293
`Patent 8,992,608
`
`MOTION FOR JOINDER
`PURSUANT TO 35 U.S.C. § 315(c) AND 37 C.F.R. § 42.122(b)
`
`
`
`
`
`
`
`
`
`
`
`
`TABLE OF CONTENTS
`
`Page
`
`TABLE OF AUTHORITIES .......................................................................................................... ii
`
`I.
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED ...................................1
`
`II.
`
`STATEMENT OF MATERIAL FACTS ................................................................2
`
`III.
`
`STATEMENT OF REASONS FOR RELIEF REQUESTED .................................4
`
`A.
`
`B.
`
`C.
`
`D.
`
`Joinder Is Appropriate..................................................................................5
`
`The New, Presently-Asserted Grounds Are Sufficiently
`Related to the Already-Instituted Grounds to Be Resolved
`Together .......................................................................................................7
`
`1.
`
`2.
`
`Anticipation of Claims 1–9 by Haug (Ex. 1135) .............................8
`
`Obviousness of Claims 1–4 over Seguin (Ex. 1150;
`Ex. 1153) in View of Lazarus (Ex. 1147) and
`Lawrence-Brown (Ex. 1149) ...........................................................9
`
`The Impact on the Schedule and the Costs of the Current
`Proceedings Will Be Minimal ....................................................................10
`
`Petitioners’ Proposed Procedures to Simplify Briefing and
`Discovery ...................................................................................................12
`
`IV.
`
`CONCLUSION ......................................................................................................13
`
`
`
`i
`
`
`
`
`
`Cases
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`ABB Inc. v. Roy-G-Biv Corp.,
`IPR2013-00286, Paper No. 14 (P.T.A.B. Aug. 9, 2013) ...........................................................7
`
`Ariosa Diagnostics, Inc. v. Isis Innovation Ltd.,
`IPR2013-00250, Paper No. 24 (P.T.A.B. Sept. 3, 2013) ...........................................................6
`
`Kyocera Corp. v. Softview LLC,
`IPR2013-00004, Paper No. 15 (P.T.A.B. Apr. 24, 2013) ..........................................................5
`
`Microsoft Corp. v. Proxyconn, Inc.,
`IPR2013-00109, Paper No. 15 (P.T.A.B. Feb. 24, 2013) ..........................................................6
`
`Samsung Elecs. Co. v. Va. Innovation Sci., Inc.,
`IPR2014-00557, Paper No. 10 (P.T.A.B. June 13, 2014) ...................................................... 4-6
`
`Sony Corp. v. Yissum Research Dev. Co. of the Hebrew Univ. of Jerusalem,
`IPR2013-00327, Paper No. 15 (P.T.A.B. Sept. 24, 2013) .........................................................7
`
`Target Corp. v. Destination Maternity Corp.,
`IPR2014-00508, Paper No. 28 (P.T.A.B. Feb. 12, 2015) ..........................................................5
`
`Other Authorities
`
`37 C.F.R. § 42.1(b) ..........................................................................................................................1
`
`37 C.F.R. §§ 42.22 ...........................................................................................................................6
`
`37 C.F.R. § 42.122 .......................................................................................................................1, 6
`
`Rules and Statutes
`
`35 U.S.C. § 315 ........................................................................................................................ 1, 4-6
`
`
`
`ii
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`
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`IPR of U.S. Patent No. 8,992,608
`
`I.
`
`STATEMENT OF THE PRECISE RELIEF REQUESTED
`
`Edwards Lifesciences Corporation, Edwards Lifesciences LLC, and
`
`Edwards Lifesciences AG (collectively, “Petitioners”) respectfully request joinder
`
`pursuant to 35 U.S.C. § 315(c) and 37 C.F.R. § 42.122(b) of the concurrently filed
`
`Petition for Inter Partes Review of Claims 1–9 of U.S. Patent No. 8,992,608 (the
`
`“’608 Patent”) (the “Second IPR Petition”) with their pending inter partes review,
`
`IPR2017-00060. IPR2017-00060 involves the same parties and was instituted on
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`March 29, 2017 on three grounds, all based on obviousness of claims 1–4 over
`
`combinations with the Spenser reference (Ex. 1004 in IPR2017-00060; Ex. 1104 in
`
`the Second IPR Petition). See IPR2017-00060, Paper No. 7 at 24.
`
`Joinder of the limited grounds raised in the Second IPR Petition to the
`
`instituted grounds in IPR2017-00060 is appropriate because such joinder will not
`
`unduly delay the resolution of either proceeding, and instead will help “secure the
`
`just, speedy, and inexpensive resolution” of these proceedings. See 37 C.F.R.
`
`§ 42.1(b). The Second IPR Petition seeks inter partes review of (1) claims 1–9
`
`over the grandparent application of the ’608 Patent, which published in 2005 as
`
`U.S. 2005/0283231 (Ex. 1135); and (2) claims 1–4 over Seguin (Ex. 1150; Ex.
`
`1153) in view of Lazarus (Ex. 1147) and Lawrence-Brown (Ex. 1149) based on
`
`Patent Owner’s recently-explicated interpretation of the terms “sacs,” “flaps,” and
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`“pockets” in a closely related patent in a European proceeding. Neither of these
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`1
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`IPR of U.S. Patent No. 8,992,608
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`grounds was previously considered by the Board in the petition in IPR2017-00060.
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`However, there is sufficient similarity between the issues and the evidence relied
`
`upon in these two new grounds of the Second IPR Petition and the issues and
`
`evidence relied upon in the grounds already instituted in IPR2017-00060 that
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`Patent Owner will not be prejudiced by adding these grounds; there will be
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`minimal impact on the briefing, discovery and trial schedule; and joining them will
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`lead to the most efficient resolution of these significant questions of patentability
`
`for the Board, the public, and all of the parties.
`
`II.
`
`1.
`
`STATEMENT OF MATERIAL FACTS
`
`On October 12, 2016, Petitioners filed a petition for inter partes
`
`review of the ’608 Patent. IPR2017-00060, Paper No. 1.
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`2.
`
`In that petition, which resulted in IPR2017-00060, Petitioners
`
`requested inter partes review of claims 1–4 of the ’608 Patent on eleven grounds
`
`of unpatentability:
`
`Ground 1: Anticipation by Cribier
`
`Ground 2: Obviousness over Cribier in view of Spiridigliozzi
`
`Ground 3: Obviousness over Cribier in view of Elliot
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`Ground 4: Obviousness over Cribier in view of Thornton
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`Ground 5: Obviousness over Cribier in view of Cook
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`Ground 6: Obviousness over Cribier in view of De Paulis
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`2
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`IPR of U.S. Patent No. 8,992,608
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`Ground 7: Obviousness over Spenser in view of Elliot
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`Ground 8: Obviousness over Spenser in view of Thornton
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`Ground 9: Obviousness over Spenser in view of Cook
`
`Ground 10: Obviousness over Spenser in view of De Paulis
`
`Ground 11: Anticipation by Spenser
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`3.
`
`On January 23, 2017, Patent Owner filed a Preliminary Response.
`
`IPR2017-00060, Paper No. 6.
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`4.
`
`The Board instituted IPR2017-00060 on March 29, 2017, on Grounds
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`7, 8, and 9 (obviousness of the ’608 Patent over Spenser in view of Elliot,
`
`Thornton, and Cook, respectively). IPR2017-00060, Paper No. 7 at 24.
`
`5.
`
`Subsequent to the filing of the petition in IPR2017-00060, the parties
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`were involved in a trial in the UK regarding, in part, the validity of EP 2 749 254
`
`and EP 2 926 766, which are relatives of the ’608 Patent, and include disclosures
`
`identical to those in the ’608 Patent regarding “flaps,” “pockets,” and “sacs.” See
`
`generally Edwards Lifesciences LLC v. Boston Sci. SciMed, Inc. EWHC (Pat),
`
`Claim No. HC-2015-004574. During that trial in late January 2017, Patent Owner
`
`explicitly argued for the first time that the flaps and pockets embodiments in
`
`Figures 32 to 34 of these patents are not mutally exclusive from the sacs
`
`embodiments in, e.g., Figures 14 to 16, and that a sac can read on bunched-up
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`fabric creating flaps and pockets (and vice versa)—a position that impacts the
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`3
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`IPR of U.S. Patent No. 8,992,608
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`scope of the claims. E.g., Ex. 1145 at ¶¶ 137–38 (e.g., “[I]t is difficult to draw any
`
`clear-water between a ‘pocket’ and a ‘sac.’”); Ex. 1146 at 1063–65 (explaining that
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`the “bunched up” fabric could also be read as “sacs”).
`
`6.
`
`Concurrently with this Motion for Joinder, Petitioners are filing their
`
`Second IPR Petition with two new grounds: (1) anticipation of claims 1–9 by the
`
`grandparent application of the ’608 Patent (U.S. 2005/0283231 (Ex. 1135)); and
`
`(2) obviousness of claims 1–4 over Seguin (Ex. 1150; Ex. 1153), which teaches the
`
`use of a fabric seal in the form of a sheath comprising “peripheral inflatable
`
`chambers,” in view of Lazarus (Ex. 1147) and Lawrence-Brown (Ex. 1149) based
`
`on Patent Owner’s recently-explicated interpretation of the use of “sacs,” “flaps,”
`
`and “pockets” in claims of closely-related European patents.
`
`III. STATEMENT OF REASONS FOR RELIEF REQUESTED
`
`The requested joinder will serve to “secure the just, speedy, and inexpensive
`
`resolution” of these proceedings. See Samsung Elecs. Co. v. Va. Innovation Sci.,
`
`Inc., IPR2014-00557, Paper No. 10 at 17 (P.T.A.B. June 13, 2014) (citing 37
`
`C.F.R. § 42.1(b); 77 Fed. Reg. at 48,758). The joinder provision for inter partes
`
`reviews, 35 U.S.C. § 315(c), provides:
`
`If the Director institutes an inter partes review, the
`
`Director, in his or her discretion, may join as a party to
`
`that inter partes review any person who properly files a
`
`petition under section 311 that the Director, after
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`4
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`IPR of U.S. Patent No. 8,992,608
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`receiving a preliminary response under section 313 or the
`
`expiration of the time for filing such a response,
`
`determines warrants the institution of an inter partes
`
`review under section 314.
`
`“[T]he Board will determine whether to grant joinder on a case-by-case basis,
`
`taking into account [] the particular facts of each case.” Samsung, IPR2014-00557,
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`Paper No. 10 at 16 (citing 157 CONG. REC. S1376 (daily ed. Mar. 8, 2011)
`
`(statement of Sen. Kyl)). As the Board has previously found, “liberal joinder of
`
`reviews, including those having new arguments[,]” furthers the goals of ensuring
`
`fair and just resolution of patent issues. Target Corp. v. Destination Maternity
`
`Corp., IPR2014-00508, Paper No. 28 at 10–13 (P.T.A.B. Feb. 12, 2015).
`
`In an order identified as a Representative Order, the Board instructed that a
`
`movant requesting joinder should: (1) “explain the reasons why joinder is
`
`appropriate,” (2) “identify any new ground of unpatentability being raised” in the
`
`petition, (3) “explain how the impact on the schedule and costs of the current
`
`proceedings will be minimized,” and (4) “specifically address how briefing and/or
`
`discovery may be simplified to minimize schedule impact.” Kyocera Corp. v.
`
`Softview LLC, IPR2013-00004, Paper No. 15 at 4 (P.T.A.B. Apr. 24, 2013).
`
`A.
`
`Joinder Is Appropriate
`
`The Board has authority to join a properly-filed IPR petition to an instituted
`
`IPR proceeding. See 35 U.S.C. § 315(c). The Second IPR Petition and
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`5
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`IPR of U.S. Patent No. 8,992,608
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`concurrently filed Motion for Joinder are timely filed under 35 U.S.C. § 315(c) and
`
`37 C.F.R. §§ 42.22 and 42.122(b).1 37 C.F.R. § 42.122 states that a motion for
`
`joinder is to be filed “no later than one month after the institution date of any inter
`
`partes review for which joinder is requested.” IPR2017-00060 was instituted on
`
`March 29, 2017. IPR2017-00060, Paper No. 7. The Petitioners filed the Second
`
`IPR Petition on April 18, 2017, fewer than three weeks after the institution of
`
`IPR2017-00060, and as noted, before any one-year bar based on 35 U.S.C. § 315
`
`would have applied absent joinder.
`
`That the Petitioners here are the same as in IPR2017-00060 does not bar
`
`joinder: “[T]he Board . . . has allowed joinder of additional grounds by the same
`
`party.” Samsung, IPR2014-00557, Paper No. 10 at 16 (citing Microsoft Corp. v.
`
`Proxyconn, Inc., IPR2013-00109, Paper No. 15 (P.T.A.B. Feb. 24, 2013); Ariosa
`
`
`1
`The Second IPR Petition is also independently timely under 35 U.S.C.
`
`§ 315(b), which states that “[a]n inter partes review may not be instituted if the
`
`petition requesting the proceeding is filed more than 1 year after the date on which
`
`the petitioner . . . is served with a complaint alleging infringement of the patent.”
`
`Petitioners were served with a complaint in Boston Scientific Corp. v. Edwards
`
`Lifesciences Corp., C.A. No. 16-275-SLR (D. Del.), on April 19, 2016. D.I. 6 in
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`C.A. No. 16-275-SLR.
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`6
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`IPR of U.S. Patent No. 8,992,608
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`Diagnostics, Inc. v. Isis Innovation Ltd., IPR2013-00250, Paper No. 25 (P.T.A.B.
`
`Sept. 3, 2013); ABB Inc. v. Roy-G-Biv Corp., IPR2013-00286, Paper No. 14
`
`(P.T.A.B. Aug. 9, 2013); Sony Corp. v. Yissum Research Dev. Co. of the Hebrew
`
`Univ. of Jerusalem, IPR2013-00327, Paper No. 15 (P.T.A.B. Sept. 24, 2013)).
`
`Indeed, the fact that the Second IPR Petition involves the same Petitioners (and the
`
`same Petitioners’ expert) as the already-instituted IPR will reduce the impact on
`
`the schedule and minimize the costs of the proceedings.
`
`Although, as discussed below, the grounds raised in the Second IPR Petition
`
`are new and rely on different art, they are sufficiently related to the grounds
`
`instituted in IPR2017-00060 that the grounds from both petitions can be efficiently
`
`consolidated and tried together.
`
`B.
`
`The New, Presently-Asserted Grounds Are
`Sufficiently Related to the Already-Instituted
`Grounds to Be Resolved Together
`
`There are two grounds—both new—asserted in the Second IPR Petition.
`
`However, they are sufficiently related to the already-instituted grounds that all
`
`grounds can efficiently be decided simultaneously. The grounds in the
`
`concurrently-filed Second IPR Petition are: (1) anticipation of claims 1–9 by the
`
`publication of the grandparent application of the ’608 Patent (Ex. 1135); and (2)
`
`obviousness of claims 1–4 over Seguin (Ex. 1150; Ex. 1153), which teaches the
`
`use of a sheath comprising sac-type “inflatable peripheral chambers,” in view of
`
`7
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`
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`IPR of U.S. Patent No. 8,992,608
`
`Lazarus (Ex. 1147) and Lawrence-Brown (Ex. 1149) based on Patent Owner’s
`
`recently-explicated interpretation of the use of “sacs,” “flaps,” and “pockets” in
`
`claims of closely-related European patents.
`
`1.
`
`Anticipation of Claims 1–9 by Haug (Ex. 1135)
`
`The first ground of the Second IPR Petition is the anticipation of all claims
`
`(1–9) by U.S. Patent Application No. 10/870,340, the grandparent of the ’608
`
`Patent, which published as U.S. 2005/0283231 (“Haug,” Ex. 1135) and which has
`
`a specification identical to that of the ’608 Patent. All claims of the ’608 Patent
`
`broadly claim both systems with a single commissure support element and a single
`
`valve commissure portion and systems with a plurality of commissure support
`
`elements and a plurality of valve commissure portions. The grandparent Haug
`
`application, however, provides written description support only for the latter (i.e., a
`
`plurality). Because the Haug application lacks written description support for the
`
`full scope of the claims of the ’608 Patent, there is a break in the priority chain, and
`
`the ’608 Patent cannot claim priority to the Haug application.
`
`As a result of this defect in the priority chain, Haug, which has an identical
`
`specification to the ’608 Patent, is prior art under 35 U.S.C. § 102(b) to the ’608
`
`Patent. Because Haug discloses systems with a plurality of commissure support
`
`elements and a plurality of valve commissure portions, which are within the
`
`coverage of the “comprising” claims of the ’608 Patent, Haug anticipates each and
`
`8
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`IPR of U.S. Patent No. 8,992,608
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`every claim of the ’608 Patent. Given that Haug presents an anticipation ground
`
`based on the same specification as the ’608 Patent and this ground involves the
`
`scope of, and additional claims that all depend from, independent claim 1, this
`
`ground can efficiently be addressed in short order together with those in IPR2017-
`
`00060, all of which already involve claim 1.
`
`2. Obviousness of Claims 1–4 over Seguin
`(Ex. 1150; Ex. 1153) in View of Lazarus
`(Ex. 1147) and Lawrence-Brown (Ex.
`1149)
`
`The second ground of the Second IPR petition is the obviousness of claims
`
`1–4 of the ’608 Patent over the combination of Seguin (Ex. 1150; Ex. 1153) in
`
`view of Lazarus (Ex. 1147) and Lawrence-Brown (Ex. 1149). The claims
`
`challenged in this ground are the same four claims challenged by the three already
`
`instituted grounds, and thus, these grounds can efficiently be addressed together.
`
`The asserted basis for obviousness over these references, including the
`
`primary Seguin reference, only came to light after the filing of the first petition.
`
`As discussed above, in a trial in the UK involving patents related to the ’608 Patent
`
`(that have disclosures with respect to “flaps,” “pockets,” and “sacs” that are
`
`identical to the disclosures of the ’608 Patent) in late January 2017, Petitioners
`
`became aware of Patent Owner’s position that seals comprising sac-type features
`
`similar to the “inflatable peripheral chambers” of Seguin (Ex. 1150; Ex. 1153) can
`
`9
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`IPR of U.S. Patent No. 8,992,608
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`read on a fabric seal that bunches up to create flaps and pockets, such as is claimed
`
`in the ’608 Patent.
`
`There should be no surprise or prejudice to Patent Owner in responding to
`
`these arguments or this art—as explained above, these arguments are based on
`
`Patent Owner’s own positions taken three months ago in litigation on a related
`
`patent against Petitioners. Additionally, the three references relied on in this
`
`ground are all known to Patent Owner. The Seguin application relied on as the
`
`primary reference (WO 03/003949) is cited on the face of the ’608 Patent. Ex.
`
`1101 at 7. WO 03/003949 was also recently cited in opposition proceedings
`
`against EP 2 926 766, along with the two secondary references relied on in this
`
`ground, Lazarus and the PCT equivalent of Lawrence-Brown. Ex. 1152 at 2.
`
`Thus, Patent Owner is familiar with all three references relied upon in this ground
`
`and there should be no surprise and minimal additional burden to address these
`
`references here.
`
`C. The Impact on the Schedule and the Costs of
`the Current Proceedings Will Be Minimal
`
`Given that the two petitions involve the same parties, Petitioners’ expert is
`
`the same for both petitions (and Dr. Buller’s second declaration is a supplement to
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`10
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`IPR of U.S. Patent No. 8,992,608
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`his first2), and Patent Owner was already familiar with the references in each new
`
`ground, the impact on the schedule should be minimal. Further, should the Board
`
`decide to institute on the second petition, joinder will reduce costs and will
`
`conserve the parties’ and the Board’s resources.
`
`Here, the first ground is based on the Haug application, the grandparent
`
`application to the ’608 Patent. The parties are already very familiar with the
`
`teachings of Haug, as its specification is identical to that of the ’608 Patent. Thus,
`
`the inclusion of this ground will add very little additional work for the parties or
`
`the Board, as the teachings of that common specification are already at issue in
`
`IPR2017-00060. The sole issue to be decided is a narrow one: the question of
`
`whether the ’608 Patent can claim priority to the Haug application.
`
`For the second ground, based on Seguin, as noted above, Patent Owner cited
`
`the primary reference during prosecution of the ’608 Patent (see Ex. 1101 at 7), the
`
`
`2
`As explained in the Buller declaration submitted with the Second IPR
`
`Petition, Dr. Buller has incorporated by reference the background discussion of his
`
`first declaration (which is submitted again in this IPR) and here submits a
`
`supplemental declaration regarding the newly-relied upon art and grounds so that
`
`the Board and Patent Owner may easily identify the new material that has been
`
`added.
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`11
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`IPR of U.S. Patent No. 8,992,608
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`primary and both secondary references were all at issue in recent opposition
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`proceedings against EP 2 926 766, and the argument advanced by Petitioners in
`
`this ground is based on an argument Patent Owner made just three months ago in a
`
`proceeding on a related patent. Thus, there should be no surprise and minimal
`
`additional burden on Patent Owner to respond to this ground, because Patent
`
`Owner is already familiar with the arguments and the art.
`
`D.
`
`Petitioners’ Proposed Procedures to Simplify
`Briefing and Discovery
`
`Given that the Second IPR Petition involves the same parties, Petitioners’
`
`expert is the same for both petitions, and the Second IPR Petition adds only two
`
`grounds—one of which relies almost entirely on a reference with a specification
`
`identical to that of the ’608 Patent, and the other is based on arguments Patent
`
`Owner recently made regarding a patent related to the ’608 Patent—Petitioners
`
`believe that no modifications to briefing or discovery procedures should be
`
`necessary.
`
`In the event that Petitioners’ expert would need to be deposed before an
`
`institution decision is made on the Second IPR Petition, Petitioners would agree to
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`offer Dr. Buller at that time on both his original and supplemental declarations.
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`Further, if necessary, Petitioner is willing to forfeit a reasonable portion of its reply
`
`period to the extent required to provide Patent Owner with sufficient time to
`
`address the two additional grounds of unpatentability in the Second IPR Petition.
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`12
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`IPR of U.S. Patent No. 8,992,608
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`Petitioner is also willing to accommodate any additional, reasonable logistical or
`
`scheduling requests of Patent Owner to facilitate efficient resolution of the joined
`
`proceedings.
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`IV. CONCLUSION
`
`For the foregoing reasons, Petitioners respectfully request that the grounds in
`
`Edwards’ accompanying Second IPR Petition be instituted and that the Board grant
`
`this Motion for Joinder of this proceeding with IPR2017-00060.
`
`
`
`Dated: April 18, 2017
`
`
`Respectfully Submitted,
`
`
`
`
`
`
`
`
`/s/ Gregory S. Cordrey
`Gregory S. Cordrey, Esq. (Reg. No. 44,089)
`Attorney for Petitioners
`Edwards Lifesciences Corporation,
`Edwards Lifesciences LLC, and
`Edwards Lifesciences AG
`
`
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`
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`13
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`IPR of U.S. Patent No. 8,992,608
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`
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`I hereby certify that, on April 18, 2017, I caused a true and correct copy of
`
`CERTIFICATE OF SERVICE
`
`the foregoing MOTION FOR JOINDER PURSUANT TO 35 U.S.C. § 315(c)
`
`AND 37 C.F.R. § 42.122(b) and all associated supporting materials to be served
`
`via Express Mail delivery at the correspondence address of record for the ’608
`
`Patent:
`
`SEAGER, TUFTE & WICKHEM, LLP
`100 South 5th Street, Suite 600
`Minneapolis MN 55402
`
`
`COURTESY COPY TO PATENT OWNER’S COUNSEL OF RECORD IN IPR2017-
`00060:
`
`
`jennifer.sklenar@apks.com
`
`wallace.wu@apks.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Gregory S. Cordrey
`
`Gregory S. Cordrey, Esq. (Reg. No. 44,089)
`Attorney for Petitioners
`Edwards Lifesciences Corporation,
`Edwards Lifesciences LLC, and
`Edwards Lifesciences AG
`
`
`
`14
`
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