who was employed at US Surgical. US Surgical sold staplers
for use in medical procedures.
18. 1 have attached a true and correct copy of another
entry from my 1995 notebook as Wang Exhibit 2036. The entry
"Earlier mtg with Leon Hirsch" is a note relating to a phone
conversation I had with Mr. Hirsch who was chairman and
chief executive officer of US Surgical.
19. Upon reviewing this notebook entry I recall
discussing with Mr. Hirsch whether US Surgical would be
interested in a partnership to develop a system where a
stapler was attached to the system disclosed in the ATP
proposal.
20. CMI continued to discuss a partnership with US
Surgical through 1997 as described in letters to Joe Devivo
and Jeff White dated May 23, 1997 and December 18, 1997,
respectively, true and correct copies are attached as Wang
Exhibits 2037 and 2038.
21. The letter to Mr. Devivo describes a partnership
to integrate the ZEUS with a One-Shot product provided by US
Surgical. ZEUS is a CMI product that includes a robotic
arm, a coupler pivotally attached to the arm, an endoscopic
instrument held by the coupler, and a controller. The
controller has a handle and is in electrical communication
with the robot arm so that movement of the controller
produces a proportional movement of the arm. The One-Shot
product sold by US Surgical was a stapler instrument.
The events that occurred as described in paragraphs 20 and
21 of Dr. Wang's declaration are after the -critical date" of 7
June 1995. Therefore, those events do not demonstrate a prior
conception.
In paragraph 17 of its declaration, Dr. Wang discusses an
entry made in his notebook (Wang Ex. 2035) regarding a phone
conversation he had with Mr. White of US Surgical on 12 January
1995, and states that US Surgical sold staplers for use in
medical procedures. Dr. Wang's statement that US Surgical sold
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