Case 1:04-cv-01258-SLR Document 171 Filed 12/16/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MCKESSON INFORMATION SOLUTIONS LLC, )
Plaintiff, g CIVIL ACTION NO. 04-1258-SLR
. v_ {
THE TRIZETTO GROUP, INC., g
Defendant. g
)
DECLARATION OF MICHAEL A. BARLOW IN SUPPORT OF
PLAINTIFF MCKESSON INFORMATION SOLUTIONS LLC’S
OPENING CLAIM CONSTRUCTION BRIEF
I, Michael A. Barlow, a member of the Bar of the State of Delaware and an associate of
` the firm of Skadden, Arps, Slate, Meagher & Flom LLP, attorneys for plaintiff McKesson
Infomation Solutions LLC, pursuant to 28 U.S.C. §1'/46, do hereby state and declare and
follows:
l. Attached as Exhibit I is a true and accurate copy of U.S. Patent No. 5,253,164 entitled
"System and Method for Detecting Fraudulent Medical Claims via Examination of
v_ Service Codes." { _
2. Attached as Exhibit 2 is a true and accurate copy of TriZetto's Proposed Claim
Construction dated December 9, 2005.
I 3. Attached as Exhibit 3 is a true and accurate copy of TriZetto's Supplemental Proposed
Claim Construction dated October ll, 2005.
4. Attached as Exhibit 4 is a true and accurate copy of TriZetto's Proposed Claim
Construction dated December 13, 2005.
5. Attached as Exhibit 5 is a true and accurate copy of Atojina v. Great Lakes Chem. Corp.,
2005 US. Dist. LEXIS 7365.
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Case 1:04-cv-01258-SLR Document 171 Filed 12/16/2005 Page 2 of 2
6. Attached as Exhibit 6 is a true and accurate copy of Pfizer, Inc. v. Teva Pharms. USA,
Inc., 2005 US. Dist. LEXIS 29050.
7. Attached as Exhibit 7 is a true and accurate copy of excerpts from Merriam Websterls
Collegiate Dictionary, Tenth Edition (1996).
I declare under penalty of perjury that the foregoing is true and correct.
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Executed on December 15, 2005. { g Z
Michael A. Barlow (#3928)
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