Free Declaration - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 382 Filed 06/01/2006 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
POR THE DISTRICT OP DELAWARE
MCKESSON INFORMATION SOLUTIONS )
LLC, )
)
Plaintiff, )
)
v. ) C.A. No. 04-1258 (SLR)
)
THE TRIZETTO GROUP, INC., )
)
Defendant. )
DECLARATION OF ANTHONY B. BELLOMO
IN SUPPORT OF THE TRIZETTO GROUP, INC.’S
MOTION FOR SUMMARY JUDGMENT OF INVALDITY
MORRIS, NICHOLS, ARSHT & TUNNEL}., LLP
Keck B. Blumenfeld (#1014)
Rodger D. Smith, II (#3778)
120} N. Market Street
P.O. Box 1347
Wilmington, DE 19899
(302) 658-9200
Attorneys for Defendant T he TriZe1‘t0 Group, [nc.
OF COUNSEL:
Jeffrey T. Thomas
David A. Segal.
Michael A. Sitzman
GIBSON, DUNN & CRUT CHER LLP
Jamboree Center
4 Park Plaza
Irvine, CA 92614-8557
(949) 45 l -3800
June I, 2006

Case 1 :04-cv-01258-SLR Document 382 Filed 06/01 /2006 Page 2 of 4
I, Anthony B. Bellomo, declare as follows:
l. I am the executive Viee—President of Enterprise Software for The TriZetto Group,
Inc. ("T1iZetto"). l submit this declaration in support of TriZetto's motion for summary
judgment of invalidity on grounds of anticipation and obviousness. I have personal knowledge
of the facts set forth herein and if called upon to do so, I could and would testify competently
hereto.
2. In 2000, TriZetto acquired Erisco Managed Care Technologies, Inc. ("Erisco"), a
manufacturer of software products used by medical insurance companies and reiated entities for
the processing and management of medical insurance claims. Prior to 1984, Erisco was a
division of Thomas National Group. ln 1984, Thomas National was acquired by Dun &
Bradstreet Corporation and Erisco became a subsidiary of Dun & Bradstreet.
3. l began working at Erisco in 1977 as Manager of Systems and Programming. in
1980, I was promoted to Vice-President of Development. From 1980 to 1994, l held several
executive management titles. In March E994, I became President of Erisco, a position that I held
until October 2000, when Erisco was acquired by TriZetto and I became Executive Vice»
President of TriZetto.
4. In l980, Erisco launched Claimliacts, a computer software product that provided
automated processing of medical claims. Claimliacts included several different modules that
performed various claims processing functions. l was personally involved in the design and
programming of Claimliacts.
5. From the time of its launch in 1980, Claimliacts was capable of determining the
validity of medical codes contained on medical claims received by the system:
• Claimliacts would receive medical claims containing one or more medical codes,
such as CPT codes. The CPT codes are a set of numerical codes established by
the American Medical Association ("AMA") that describe certain medical
procedures and health care tasks.
2

Case 1 :04-cv-01258-SLR Document 382 Filed 06/01/2006 Page 3 of 4
aeittia ee 15; za teeeemmeaa TRIZETTD moe ea/ea
• C}ai_mFactsine0t‘pc1‘ated a CPT database containing all thc valio CPT codes
recognized by the AMA.
• CiaimFa.cts would check the CPT database to detemutoe whether or not a
received medical eode was present in that database.
• If a medical code was not present to the CPT database. CiaimFacts would
display an envot message ixtfotimiog the user that the code was not found in the
database.
6. ClaimFaots (including the c:ode·validaticxt timction described in Paragraph. 5) was
sold to and used by §EZ1tsco’s customers begimmiag in 1980.
7 . The co<:le»val.i.ciation function described in Paragraph 5 has remained subetaattatly
the same in Clai.mIFacte {mm “l93O tothe present day.
S. G1EtLl1'!1F acts in 1980 was also capable of detecting redundant medtoai codes on a
medical claim. It a 1nedic:a} claim was received with two identical mMical codes, ClaimFacts
watt oapable of rejecting one of the codes and sm;l1o1·l ximg the other oocie for turtlzer processing.
I declare under penalty ofpezjuty under the laws ofthe United States cfAmet1t:a that the
foregoing is tme and correct.
This declaration was executed this [L day of May, 2006, at Union, New Jersey.
Anthony B. Bellomo
l0(10D2053__l .mo<;
3

Case 1:04-cv-01258-SLR Document 382 Filed 06/01/2006 Page 4 of 4
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on June 1, 2006, { caused to be
electronically filed the Declaration of Anthony B. Bellonio in Support of The Trizetto Group,
lnc.’s Motion for Summary Judginent of Invalidity with the Clerk of the Court using CM/ECP,
which will send notification of such filing(s) to the following:
Michael A. Barlow
Skadden, Arps, Slate, Meagher & Flom LLP
I also certify that copies were caused to be served on June 1, 2006, upon the
li`ol.lowing in the manner indicated:
BY EMAIL AND HAND
Michael A. Barlow
Skadden, Arps, Slate, Meagher & Flom LLP
One Rodney Square
Wilmington, DE l980l
BY EMAIL AND FEDERAL EXPRESS
Jeffrey G. Randall
Skadden, Arps, Slate, Meagher & Flom LLP
525 University Avenue
Suite 1100
Palo Alto, CA 94301
/s/ Rodger D. Smith H (#3 778)
Morris, Nichols, Arsht & Tunnell LLP
1201 N. Market Street
P.O. Box 1347
Wilmington, DE l9899
(302) 658-9200
[email protected]