Free Redacted Document - District Court of Delaware - Delaware

··=·· · · t ·· · ·u ·» ` Case 1 :04=·cv-01258-SLR Document 401 Filed 06/08/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS )
LLC, Plaimifg § CIVIL ACTION NO. 04~1258—SLR
V. § REDXCTEIJ PUBLIC VERSION
THE TRIZETTO GROUYQ TNCM g UNDER SEAL VERSION FILED: June 1, 2006
DcfEmd,mt_ ) REDACTED PUBLIC VERSION FILED: June 8, 2006
DECLARATION OF MICHAEL A. BARLOW IN SUPPORT OF
PLAINTIFF MCKESSON INFORMATION SOLUTIONS LLC’S
MEMORANDUM IN SUPPORT OF ITS MOTION FOR
SUMMARY JUDGMENT RE: ANTICIPATION AND OBVIOUSNESS
I, Michael A. Barlow, pursuant to 28 U.S.C. § 1746, declare as
follows:
1. I am an attorney ofthe Bar ofthe State of Delaware and ofthe
firm of Skadden, Arps, Slate, Meeher & Flom LLP, attorneys for plaintiff
Mcliesson Infomation Solutions LLC inthe above~captioned action. I submit this
declaration in support of the Plaintiffs Memorandum in Support of its Motion for
Summaiy Judgment Re: Anticipation and Obviousness, and to transmit to the Court
tmc and correct copies ofthe following documents attached as exhibits hereto:
I l

Case 1 :04-cv-01258-SLR Document 401 Filed 06/08/2006 Page 2 of 3
Description Exhibit No.
TriZetto‘s Fourth Supplemental Response To Plaintiffs Interrogatozy No. 6 1
dated September 13,2005
Expert Report of Randall Davis dated October 24, 2005 2
Expert Report of Larry Kerschberg dated October 24, 2005 3
Expert Report of Philip Hawley dated October 24, 2005 4
Excerpts from the deposition of Randall Davis taken on November 30, 5
2005
Excerpts from the deposition of Philip Hawley taken on November 30, 6
2005
Excerpts from the deposition of Larry Kerschberg taken on November 21, 7
2005
Davis, Randall ”Expert Sjzstems Where Are We? Arid Where Do We Go S
From Here?” The AI Magazine Spring 1982 pp. 3-22
Rebuttal Expert Report of Mark Musen dated November 24, 2005 9
Expert Report of David Wilson dated November 14, 2005 10
Moore North America, Inc., v. Poser Business Forms, Inc., C.A, No. 97- 1 1
712—SLR, 2001 WL 253117 (D. Del. Mar. 8, 2001)
Praxoir, Inc. v. ATML Inc., C.A. No. 03-1158—SLR, 2005 WL 3159054 (D. 12
Del. Nov. 28, 2005)
Excerpts from McKesson Information Solutions LLC's First Set Of 13
Interrogatories, dated December 22, 2004
Excerpts from the deposition of George Goldberg taken on September 13, 14
2005
Excerpts from the deposition of Eric King taken on October 4, 2005 15
Inte} Corp. v. Broadcom Corp., C.A. N0. 00-796-SLR, 2003 U,S. Dist. 16
Lexis 2372 (D. Del. Feb. 13, 2003)
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Case 1 :04-cv-01258-SLR Document 401 Filed-06/0·8f2006 ——·——P-age—3=c>f=3i»=i= ·-== A - i·
AMS Claim Level Edits prepared by The Health Data Institute dated June 17
1986 bearing Bates Nos. RD000325 — RD000419
Excerpts from Trial Transcripts, Volume D before Honorable Sue L. 18
Robinson dated April 20, 2006
I declare under penalty of perjury that the foregoing is true and
correct.
Executed: June 1, 2006
E Michael A. Barlow (LD. # 3928)
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