KEITH et al. V. COELHO - Page 12




          Interference No. 103,270                                                    



                    disclosed to me the idea of providing a                           
                    mechanism to freeze a guidewire in position                       
                    within a guide catheter so that the                               
                    guidewire could not move longitudinally                           
                    relative to the guide catheter.  He                               
                    explained that with the position of the                           
                    guidewire frozen, the indwelling over-the-                        
                    wire catheter could be withdrawn,                                 
                    completely separated from the guidewire and                       
                    that with the position of the wire still                          
                    frozen, another over-the-wire catheter                            
                    could be threaded onto the guidewire and                          
                    advanced along the guidewire and through                          
                    the guide catheter.                                               
                    Coelho also testified that thereafter, at the                     
          brainstorming meeting he explained the method to those                      
          present, including Barbere (CR-12).  Barbere, a senior project              
          engineer in the NPD department, as well as Crittenden, the                  
          engineering manager of angioplasty development, both testified              
          that Coelho disclosed his idea at the meeting (CR-41, 83).                  
          However, Barbere could not recall the date of the meeting (CR-              
          42), and Coelho                                                             
          states in his brief that Barbere's testimony "was never                     
          intended to confirm the precise date of the brainstorming                   
          meeting" (CB-59).  Crittenden testified in his declaration                  
          that the meeting was "[s]ometime before December 2, 1988" (CR-              



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