Free Redacted Document - District Court of Delaware - Delaware

Case 1 :04-cv-01258-SLR Document 192 Filed 12/22/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS LLC, )
Plaintiff, A l CIVIL ACTION NO. 04··1258-SLR
v. g
THE TRIZETTO GROUP, INC., % REDACTED PUBLIC VERSION
D€fcndant_ 3 Confidential Version Filed: December 15, 2005
Redacted Version Filed: December 22, 2005
TRANSMITTAL DECLARATION OF MICHAEL A. BARLOW IN SUPPORT OF
PLAINTIFF MCKESSON INFORMATION SOLUTIONS LLC’S MOTION _
FOR SUMMARY JUDGMENT OF INFRINGEMENT
I Michael A. Barlow hereby deposes and says:
I am associated with Skadden, Arps, Slate, Meagher & Flom LLP, counsel for the
plaintiff in this action. I submit this transmittal declaration in support of Plaintiff McKesson
Information Solutions LLC‘s Motion for Summary Judgment of Infringement.
1. Attached as Exhibit A is a true and accurate copy of U.S. Patent No. 5,253,164 entitled
"Systcm and Method for Detecting Fraudulent Medical Claims via Examination of
Service Codes."
2. Attached as Exhibit B is a true and accurate copy ofthe parties' Joint Claim Construction
Chart filed concurrently with the Court.
3. Attached as Exhibit C is a true and accurate copy of TriZetto's Supplemental Proposed
Claim Construction dated October I1, 2005.
4. Attached as Exhibit D is a true and accurate copy of excerpts from the depositions taken
of various TriZetto customers, employees, and executives as well as excerpts from
K

Case 1 :04-cv-01258-SLR Document 192 Filed 12/22/2005 Page 2 of 3
various documents produced during discovery in this case relating to claim 3 of the *164
patent.
5. Attached as Exhibit E is a true and accurate copy of the Rebuttal Report of Randall Davis,
served on November 14, 2005.
6. Attached as Exhibit F is a true and accurate copy of excerpts trom depositions takn of
various TriZetto customers, employees, and executives relating to CPT codes.
7. Attached as Exhibit G is a true and accurate copy of excerpts from depositions taken of
various TriZetto customers, employees, and executives relating claims 15 and 16.
8. Attached as Exhibit H is a true aud accurate copy of excerpts from deposition of Randall
Davis, PhD., relating to claim 3 ofthe '1 64 patent.
A 9. Attached as Exhibit I is a true and accurate copy ot`PfEzer·, Inc. v. T eva Phctrms. USA, Inc.,
2005 UTS. Dist. LEJHS 29050.
10. Attached as Exhibit J is a true and accurate copy of excerpts irom the deposition of
Anthony B. Bellomo, taken September 16, 2005.
ll. Attached as Exhibit K is a true and accurate copy of excerpts irom the deposition of
Anthony B. Bellomc, taken September 19, 2005.
12. Attached as Exhibit L is a tme and accurate copy of excerpts from the deposition of Blue
Cross Blue Shield of Tennessee (John Blake), taken September 22, 2005.
13. Attached as Exhibit M is a true and accurate copy of excerpts from the deposition of John
Dauza, taken September 12, 2005.
14. Attached as Exhibit N is a true and accurate copy of excerpts from the deposition of
Randall Davis, PhD., taken November 30, 2005.
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Case 1 :04-cv-01258-SLR Document 192 Filed 12/22/2005 Page 3 of 3
15. Attached as Exhibit O is a true and accurate copy of excerpts from the deposition of
Harrington Benefits (Patricia Kep1inger),talcen September 14, 2005.
16. Attached as Exhibit P is a true and accurate copy of excerpts from the deposition of Key
Benefit Administrators (Clifton Eones), taken September 23, 2005.
17. Attached as Exhibit Q is a true and accurate copy of excerpts from the deposition of
Karen Lampe, taken September 14, 2005. l
18. Attached as Exhibit R is a true and accurate copy of excerpts from the deposition of Craig _ 0
Luftig, taken September 9, 2005.
19. Attached as Exhibit S is a true and accurate copy of excerpts from the deposition of
Jeffrey R. Margolis, taken October 3, 2005.
20. Attached as Exhibit T is a true and accurate copy of excerpts from the deposition of
Premera Blue Cross (Kirsten Kemp), taken October 10, 2005.
21. Attached as Exhibit U is a true and accurate copy of excerpts from the deposition of
Providence Health Plan (Tracy Pierson and Carolyn Drini), taken September 12, 2005.
22. Attached as Exhibit V is a true and accurate copy of excerpts from the deposition of Tara ·
Smith, taken September 14, 2005.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 15, 2005. g 2 i
Michael A. Barlow (LD. #3928)
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