Free Declaration - District Court of Delaware - Delaware

I/A Case 1 :04-cv-01258-SLR Document 156 Filed 12/15/2005 Page 1 01 4
IN THE UNITED STATES DISTRICT COURT `
FOR TI·IE DISTRICT OF DELAWARE
MCKES SON INFORMATION SOLUTIONS
LLC,
Plaintiff;
v. Civil Action N0. 04-1258-SLR
THE TRIZETTO GROUP, INC.
Defendant.
DECLARATION OF JOHN DANZA
IN SUPPORT OF THE TRIZETTO GROUP, 1NC.'S
MO'I'ION FOR SUMMARY JUDGMENT OF N ON-INFRIN GEMEN T

P Case 1 :04-cv-01258-SLR Document 156 Filed 12/15/2005 Page 2 of 4
I, John Danza, declare as follows: °
1. I am employed by The TriZetto Group, Inc. ("TriZetto") as Manager of QicLink
Product Management. I submit tl1is declaration in support of TriZetto's motion for summary
judgment of non-infringement. 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. QicLink is a software product used by insurers, health maintenance organizations
(HMOs), third party administrators (TPAs), and other health benefit providers to process claims
for medical services. QicLink can perform a wide range of claims processing functions,
including clinical editing. I
h 3. Clinical editing involves checking and editing the medical procedure codes on a
medical claim in accordance with expert-derived clinical criteria. For a further description of
clinical editing, see the Declaration of Craig P. Luftig, tiled herewith, at paragraph 3.
4. The clinical criteria in QicLi11k are contained ir1 an ISAM iile, not a database.
5. QicLink provides an interface that the customer can use to modify clinical criteria
in the ISAM file as desired. The customer can activate or deactivate particular clinical criteria,
delete existing clinical criteria, add new clinical criteria, or change the terms of particular clinical .
criteria. 1
6. QicLink does not check to see if a received claim has more than one code in order
to perform clinical editing. QicLink will perform clinical editing (including multiple·code edits,
if applicable) on all claims received, regardless of the number of codes present on the claim. In
the process of clinical editing, QicLink will examine any codes submitted on earlier claims for _
the same patient together with the code or codes &om the current claim.
2


Case 1 :04-cv-01258-SLR Document 156 Filed 12/15/2005 Page 3 of 4
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
This declaration was executed this 14th day of December, 2005, at Chicago, Illinois.
5 John Danzj
wsB.tmp
3

Case 1:04-cv-01258-SLR Document 156 Filed 12/15/2005 Page 4 of 4
CERTIFICATE OF SERVICE `
I, Jack B. Blumenfeld, hereby certify that on December 15, 2005 I electronically
filed Declaration of John Danza in Support of the TriZetto Group, Inc.’s Motion for Summary
Judgment of Non-Infringement with the Clerk of the Court using CM/ECF, which will send
notification of such filing(s) to the following:
Thomas J. Allingham, II
Skadden, Arps, Slate, Meagher & Flom LLP
I also certify that copies were caused to be served on December 15, 2005 upon the
following in the manner indicated:
BY HAND
Thomas J. Allingham, II
Skadden, Arps, Slate, Meagher & Flom LLP
One Rodney Square
P.O. Box 636
Wilmington, DE 19899
BY EMAIL
Jeffrey G. Randall
Skadden, Arps, Slate, Meagher & Flom LLP
525 University Avenue
Suite 1100
Palo Alto, CA 94301]
/s/ Jack B. Blumenfeld (#1014)
Morris, Nichols, Arsht & Ttmnell
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899
. (302) 658-9200
jblumenf`[email protected]