Outside Counsel Policy (“OCP”)

Outside Counsel Policy
(“OCP”)
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TableofContents
1. PURPOSE AND SCOPE ..................................................................................................... 4 2. PROFESSIONAL RESPONSIBILITY RULES AND CHOICE OF LAW ........................ 4 3. ETHICAL CONDUCT ........................................................................................................ 4 4. RETENTION OF OUTSIDE COUNSEL & DIRECTION OF LEGAL SERVICES......... 5 5. CONFLICTS OF INTEREST .............................................................................................. 5 6. STAFFING, BILLING, FORECASTING and ACCRUALS .............................................. 6 a. Staffing ..................................................................................................................................7 b. Billing ...................................................................................................................................7 c. Estimates, Forecasts, Adjustments and Accruals ................................................................10 d. Early Case Assessment (ECA)............................................................................................11 e. Bonds, Letters of Credit, & Insurance ................................................................................11 f. Legal Diversity Statement...................................................................................................11 g. ProBono/Community Service .............................................................................................11 7. SARBANES OXLEY ACT REQUIREMENTS ............................................................... 11 8. NONCOMPLIANCE ......................................................................................................... 12 9. MISCELLANEOUS .......................................................................................................... 12 a. Document Retention ...........................................................................................................12 b. Media ..................................................................................................................................12 c. Marketing ............................................................................................................................13 Appendix A–Engagement\Retainer Letter .................................................................................... 14 Appendix B- Accrual Calendars, Forecast and Accrual Forms .................................................... 17 Appendix C-Travel Policy ............................................................................................................ 19 a. Introduction .........................................................................................................................19 b. Trip Planning ......................................................................................................................19 c. Travel Authorization ...........................................................................................................19 d. Travel Arrangements ..........................................................................................................19 e. Logical Fare (LLF) .............................................................................................................19 f. Class of Service...................................................................................................................19 g. Air Travel Restrictions ........................................................................................................20 h. Upgrades and Incidentals ....................................................................................................20 2
i. Insurance .............................................................................................................................20 j. Lost Luggage ......................................................................................................................20 May 23, 2014
k. Helicopter Travel ................................................................................................................20 l. Car Rental ...........................................................................................................................20 m. Ground Transportation ........................................................................................................22 n. Meals ...................................................................................................................................22 Appendix D-Conflict Waiver Request .......................................................................................... 23 Appendix E–International Retainer Letter .................................................................................... 24 Appendix F-Approved Third-Party Vendors ................................................................................ 27 Appendix G-Medtronic Competitors by Division ........................................................................ 28 Appendix H-Electronic Invoice Submission Guidelines .............................................................. 34 3
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1. PURPOSEANDSCOPE
As the global leader in medical technology, Medtronic expects world-class legal services
from its legal partners. Legal services must be cost-effective and compliant with legal
and ethical requirements governing lawyer professional responsibility, and strategically
aligned with Medtronic’s business objectives and mission of alleviating pain, restoring
health and extending life for millions of people around the world.
This policy applies to outside counsel representing or advising Medtronic, Inc., including
any Medtronic business unit, functional area, employee in their official capacity, board or
board member in their official capacity, subsidiary, or other Medtronic-owned entity
(collectively “Medtronic”). Medtronic retains outside legal counsel pursuant to this
Outside Counsel Policy, not pursuant to any law firm’s retainer agreement. This Policy
should, of course, be interpreted so as to be consistent with the laws and bar association
(or equivalent) professional rules applicable to the practice of law.
Exceptions to this policy may be granted only by the Medtronic Board of Directors
(“Board”) or its Lead Independent Director, Chair of the Board of Directors, General
Counsel, or their authorized designees. Outside counsel seeking an exception to any
provision of this policy should consult with the in-house Medtronic attorney they are
working with, who, in turn, will seek appropriate internal consideration for any requested
exception.
2. PROFESSIONALRESPONSIBILITYRULESANDCHOICEOFLAW
Outside counsel representing Medtronic agree to adhere to the Minnesota Rules of
Professional Conduct or to the rules governing attorney conduct in the jurisdiction where
the litigation for which counsel has been retained is venued, whichever rules place greater
restrictions on counsel’s conduct, on matters related to attorney/client conflict of interest,
privilege and confidentiality, waivers, and client rights following termination of an
attorney/client relationship (including, but not limited to, rights relating to return of client
files). In the event of a dispute between Medtronic and outside counsel arising out of
representation of Medtronic, outside counsel consent to the jurisdiction of Minnesota
State or federal courts for resolution of any dispute. Except as otherwise stated herein or
in the case of counsel outside the United States, as stated in Medtronic’s International
retainer letter (Appendix E), outside counsel further agree that such disputes will be
governed by Minnesota law, without regard to any conflict of law principles, treaties,
rules, statutes, decisions or issues.
3. ETHICALCONDUCT
Medtronic conducts its business in accordance with the highest ethical standards and
expects the same of its Outside Counsel. Medtronic expects its Outside Counsel to
advise the company of all responsibilities under applicable laws and regulations and of
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any legal risks of a proposed course of action. If Outside Counsel believes that a
Medtronic employee (including Legal Department personnel) has or will engage in illegal
or unethical activity, the most senior Outside Counsel responsible for the matter through
which such activity is discovered must immediately and confidentially contact
Medtronic’s General Counsel or Deputy General Counsel for Litigation and
Investigations, as appropriate. No Medtronic employee has the authority to instruct
Outside Counsel to act in an unethical manner in connection with any Medtronic matter.
4. RETENTIONOFOUTSIDECOUNSEL&DIRECTIONOFLEGAL
SERVICES
Only the General Counsel or his/her designees may hire outside counsel to represent or
advise Medtronic. The Board, its Lead Independent Director or Chair of the Board may
hire outside counsel to represent or advise the Board or a member or Committee thereof.
Most engagements are reviewed by the General Counsel for suitability for the matter.
Upon retention for each new matter, outside counsel must acknowledge in writing receipt
of this Outside Counsel Policy and counsel’s agreement to abide by its terms. In most
matters, Medtronic will send an engagement letter (see Appendix A or Appendix E) to
define the scope of representation and memorialize any matter-specific fee arrangements.
Outside counsel may, as directed or permitted by in-house Medtronic legal counsel, have
direct communication and interaction with non-legal Medtronic employees; however,
outside legal counsel may only take direction from in-house Medtronic legal counsel (or,
where retained by the Board, from the Board or its designee), as to the course, scope,
strategy and tactics associated with representation of Medtronic. Medtronic, as a
corporation, is the “client” of its in-house and outside legal counsel, except where stated
otherwise in writing (e.g., in the representation of an individual). Medtronic in-house
legal counsel and the Medtronic Board of Directors have sole authority to decide how to
manage, maintain and whether to waive any privilege or protection owned solely by the
corporation (e.g., attorney-client, attorney work product, “self-critical analysis”). In
instances where a privilege may be jointly owned by Medtronic and another person or
entity (e.g., in connection with joint defense agreements), Medtronic must consent, in
writing, to waiver of any such privilege.
5. CONFLICTSOFINTEREST
For purposes of this Outside Counsel Policy, “Conflict of Interest" or "conflict" means a
situation in which outside counsel (as an individual or law firm):
(1) has a personal, business, or financial interest or other relationship that would
cause a reasonable individual with knowledge of the relevant facts to question
their integrity or impartiality;
(2) was or is counsel to a party adverse to Medtronic in a business transaction,
lawsuit, arbitration, claim or other dispute; or,
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(3) engages in an activity that would cause Medtronic to question the judgment or
impartiality of a lawyer or law firm representing or advising Medtronic;
(4) or is at risk of disclosing confidential Medtronic information to a lawyer
representing a Medtronic competitor (Appendix G) albeit inadvertently. Such a
situation can arise, for example, when a lawyer or law firm represents both
Medtronic and a Medtronic competitor.
Outside counsel is required to advise Medtronic immediately of any actual or potential
representation which may be or may become adverse to the interests of Medtronic or of
any situation that otherwise may involve a Conflict of Interest, including issue Conflicts
(such as where a firm asserts a legal position adverse to the interests of Medtronic on
behalf of another client in another case) and representation of Medtronic competitors.
Questions about whether another client competes with Medtronic should be addressed to
in-house counsel. Medtronic expects loyalty from its outside counsel and may regard as
an actual or potential conflict of interest the representation of another party, which may
have differing interests, whether such interests be conflicting, inconsistent, diverse or
otherwise discordant. The foregoing description of “Conflict of Interest” may be broader
than any otherwise applicable definition under outside counsel’s local bar rules or canons
of ethics. Any such circumstance should be explained in writing addressed to the VP of
Risk Management or his/her designee @ rs [email protected] using the Medtronic
disclosure and waiver request form (Appendix D).
Upon receipt of the completed form, the waiver request will be submitted to the
Medtronic Legal Conflict Committee. Outside counsel will be advised promptly whether
the requested waiver is granted, and the conditions thereto, or declined, in which case
Medtronic will not consent to waive any such actual or potential Conflict. Each conflict
must be separately disclosed. Each waiver will be determined on a case-by-case basis.
Any consent so granted shall be on the condition that such consent will be reconsidered
in the event that the interests of outside counsel’s client and of Medtronic change
materially.
“Medtronic Competitors” means any individual or entity that competes with Medtronic.
Questions concerning whether a particular individual or entity is a Medtronic competitor
should be directed to Medtronic’s in-house legal counsel.
6. STAFFING,BILLING,FORECASTINGandACCRUALS
Counsel must comply with Medtronic’s applicable billing and forecasting procedures.
Legal fees and associated expenses charged to Medtronic must be appropriate, reasonable
and reflect fair value for the services rendered. Invoices should be submitted on a
monthly basis for work performed and expenses incurred the previous month. Invoices
submitted for work conducted more than two months prior to the submission of a bill will
be disallowed by our e-billing system.
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a. Staffing
Matters should be appropriately staffed. Matters should not be overstaffed or under-staffed. Senior lawyers, junior lawyers, paralegals and
legal assistants should be assigned matters appropriate for their position.
Lawyers should not perform, for example, paralegal work and charge
Medtronic at lawyer rates for such work. Senior lawyers should not
perform work such as detailed legal research, basic contract drafting,
unless agreed to by Medtronic.
Medtronic views support staff as part of law firm overhead. Absent
unusual circumstances, Medtronic will not pay for timekeepers other than
attorneys and paralegals. If there is a documented need for an added
timekeeper, it must be preapproved in writing by the Medtronic in-house
counsel supervising the matter.
Multiple professionals should not attend meetings or events, unless agreed
to in advance by Medtronic. Such events include deposition preparation
sessions, depositions, negotiations, mediations, hearings or other court
appearances. Likewise, only necessary outside counsel should participate
in phone calls or meetings with the Medtronic internal team handling a
matter.
Experts, consultants, vendors and other non-firm personnel must not be
retained without advance permission from Medtronic.
Medtronic does not pay for replacement attorney or paralegal learning
time.
Medtronic has internal resources and/or preferred vendors to provide
products or services to assist in such matters as photocopying, e-discovery,
medical record processing, translations, computer forensics, document
review and analysis, and graphic and demonstrative presentations.
Outside counsel should inquire whether Medtronic has a preferred vendor
before engaging one or utilizing firm resources.
b. Billing
Medtronic maintains an e-billing system - Datacert’s Passport Matter
Management System (“Passport”) (Appendix H) - a web-based application
which facilitates the approval and payment of electronic invoices between
law firms and the Medtronic corporate legal and finance functions.
(Except for outside counsel outside of the United States; those billing
arrangements are governed by the engagement letter under Appendix E.)
The Passport system significantly improves bill processing and payment
timing, and allows Medtronic to validate invoices against outside counsel
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guidelines. Law firms must submit all invoices through Passport, and
therefore must engage with Datacert to submit bills to Medtronic through
Passport. Fees for using Datacert are the responsibility of the law firm.
Medtronic will not pay nor reimburse Datacert law firm fees. Medtronic
will soon require that all forecast submissions be entered and updated in
the e-billing system.
Medtronic may require detailed work plans, detailed forecast estimates
and accruals, and other requirements in certain matters at any time
throughout the life of the matter.
Medtronic welcomes proposals from outside counsel for alternative billing
arrangements, such as fixed rates, blended rates and discounts for certain
work.
All legal vendors must submit invoices using our e-billing system and
must not charge Medtronic for use of that system. Medtronic requires
each fee and expense line item have a UTBMS task code assigned.
Missing task and expense codes will cause the line item (or file) to fail and
the entire invoice will be rejected. Agreed-upon rates should encompass
all overhead and internal charges and administrative costs associated with
a firm’s practice, including printing, scanning, cellular/PDA usage
charges, routine secretarial or clerical work, including telephone charges,
routine/small copying, mail room and fax labor charges, computer
charges, and overtime services, including any travel expenses for
personnel working OT. Large or complex scanning and photocopying
jobs must be referred to Medtronic’s preferred outside vendor.
Medtronic uses the UTBMS codes for expenses. Absent preapproval,
Medtronic will not pay for the following expenses.
Word Processing
Facsimile
Telephone (long distance, mobile,
conference)
Online research
E103
E104
E105
E106
Medtronic will pay for the following expenses when billed at cost with no
mark-up or override.
Delivery Services/Messengers
Postage
Local Travel (cars, parking, taxis) (provide
detail and subject to limits)
Out-of-Town Travel (hotels, planes &
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E107
E108
E109
E110
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trains)(provide detail and subject to
limits)
Meals (provide detail and subject to
limits)
Court Fees
Subpoena Fees
Witness Fees
Deposition Transcripts
Trial Transcripts
Trial & Hearing Exhibits
Litigation-Support Vendors (Prior
Approval & Detail)
Experts
Private Investigators
Arbitrators & Mediators
Local Counsel
Other Professionals (Prior Approval &
Detail)
E111
E112
E113
E114
E115
E116
E117
E118
E119
E120
E121
E122
E123
Professional services should be billed in increments of 0.10 hour
All EDRM (Electronic Discovery Reference Model) issues must be
communicated and processed through the internal Medtronic eDiscovery
team. This includes but is not limited to: search term definition, early data
assessment, preservation, collection, processing, review and analysis.
Outside counsel is required to work with the Medtronic eDiscovery team
prior to making any commitments to timelines and/or filtering
requirements.
Counsel may not increase the hourly rates charged for services rendered
during the life of a matter (pendency of the specific engagement).
Exceptions to these procedures require written preapproval by Medtronic.
Charges by outside vendors must be supported by copies of invoices. The
invoices need not be submitted when a firm is submitting invoices
electronically. However, the firm should retain a copy to be provided if
Medtronic requests. A firm should advance costs that do not exceed
$2,500. Any expenses that exceed $2,500 may be forwarded directly to
Medtronic for payment once they are reviewed and recommended for
payment by counsel who manage the goods or services provided by the
vendor. Outside counsel must consult with the Medtronic lawyer with
whom they are working on a matter for advance approval of any
significant expense or before undertaking any significant activity.
Outside counsel traveling on behalf of Medtronic must comply with the
Medtronic Travel Policy (See Appendix C, provided herewith). Among
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other things, outside counsel should charge only for coach class travel,
stays at hotels of the same class permitted for Medtronic in-house counsel,
and strictly minimize meal expenses. Any travel must be approved by the
Medtronic lawyer assigned to each matter.
When possible, utilize videoconferencing instead of travel.
Medtronic does not permit charges for time spent in travel except for time
when counsel is actually performing Medtronic legal work.
c. Estimates,Forecasts,AdjustmentsandAccruals
Prior to or soon after engagement on a matter (within 30 days), outside
counsel must provide Medtronic with a written estimate of the fees and
expenses reasonably anticipated for the life of the matter. Where possible,
such estimates should also indicate the Medtronic fiscal month, quarter
and fiscal year in which the fees and expenses are anticipated to be
incurred. Changes anticipated to any forecast estimate should be
promptly communicated in writing to allow Medtronic to make
appropriate adjustments to its internal financial forecasts.
Medtronic performs monthly accrual reporting for each major matter (as
defined by the assigned MDT lawyer) with respect to outside attorneys’
fees and expenses and requires counsel and vendors to submit the
following:
AS TO EACH FILE OR MATTER, IT IS IMPERATIVE THAT AT
LEAST SEVEN DAYS PRIOR TO THE CLOSE OF EACH
MEDTRONIC FISCAL MONTH OR QUARTER, (APPENDIX B)
OUTSIDE COUNSEL REPORT THE FOLLOWING
INFORMATION TO THE MEDTRONIC IN-HOUSE ATTORNEY
WITH WHOM THEY ARE WORKING:
1.
2.
3.
4.
The name of the file or matter;
Total fees and expenses billed and unpaid to date, including
invoice number and amount;
Total fees and expenses accrued and unbilled to date,
including an estimate for fees and expenses to be billed
through the last Friday of the month. Expense estimates
shall be all-inclusive, to include, experts, consultants, thirdparty vendors.
Forecasts must be updated by Outside Counsel and sent to
the Medtronic lawyer for review and approval.
Questions regarding this section should be directed to the Medtronic inhouse attorney responsible for the matter or to Medtronic Legal
Operations.
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d. EarlyCaseAssessment(ECA)
Outside Counsel agrees to work through an early case assessment process
in both matter and eDiscovery strategies (Early Data Assessment or EDA).
Discussions should be directed to Medtronic’s in-house legal counsel.
e. Bonds,LettersofCredit,&Insurance
Outside counsel in need of any bond, letter of credit or certification or
proof of insurance should consult with the in-house Medtronic counsel
with whom they are working on the matter. As to bonds related to
appellate matters, outside counsel may consult with the Vice President,
Litigation. Requests for letters of credit or for certificates of insurance or
proof of insurance may be directed to the Vice President, Risk
Management.
f. LegalDiversityStatement
Medtronic is dedicated to retaining the best lawyers by assuring that we
have diverse talent and legal representation that reflects the diversity of
our employees, customers and communities where we do business. To
that end, we have made a Member Commitment to A Call to Action for
Sustainable Change in Diversity in the Legal Profession and have
affirmed our commitment to the mission of the Leadership Council on
Legal Diversity to bring together the leadership of companies and law
firms to use all of the means at our disposal to realize a truly diverse
profession. We welcome and value diversity in legal teams that represent
us.
g. ProBono/CommunityService
Medtronic encourages the members of its Legal Department to participate
in their community through the provision of pro bono services. Medtronic
invites creative partnership by its MP3 network firms to support, develop
and co-lead pro bono projects with members of the Medtronic Legal
Department.
7. SARBANESOXLEYACTREQUIREMENTS
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Where applicable, outside legal counsel must comply with section 307 of the SarbanesOxley Act of 2002 (“SOX”), and U.S. Securities and Exchange Commission Rules
promulgated in 17 C.F.R. § 205 et seq. regarding attorney professional conduct and
reporting. Any required reporting in connection with that statute or Commission Rules
may be made to the Medtronic General Counsel or Medtronic Audit Committee.1
8. NONCOMPLIANCE
Failure to comply with this policy may result in:





Denial of a request to represent Medtronic
Denial of a waiver request
Termination of legal services
Disallowance in whole or in part of fees for services rendered (including for
failure to comply with the billing requirements provided herein)
Other action, including referral to the appropriate attorney licensing authority.
In the event legal services are terminated, outside counsel representing Medtronic must
continue to maintain as confidential all Medtronic confidential and proprietary
information, immediately return to Medtronic all files (including all documents and
things governed by any privilege, including attorney work product), and otherwise
cooperate fully in the orderly transfer of matters as directed by Medtronic in-house legal
counsel.
9. MISCELLANEOUS
a. DocumentRetention
Medtronic corporate policy requires that files on legal matters, such as the
records of a particular litigation, be kept for 10 years. Outside counsel’s
own document retention schedule should equal Medtronic’s.
b. Media
Outside counsel representing Medtronic may not make any public or
media statement about a current or former matter absent approval by
Medtronic’s General Counsel or Medtronic’s Board or its designee, except
as to communications made to third-party individuals (e.g., opposing
counsel), tribunals, agencies, etc. in the normal course of representation
and for purposes of representation of Medtronic. Any media inquiries
should be immediately directed to Medtronic’s General Counsel.
1
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May 23, 2014
c. Marketing
Outside counsel must receive approval of Medtronic’s General Counsel or
designee if they wish to disclose or advertise their representation of
Medtronic in law firm marketing materials, including on a firm website in
connection with statements regarding representative clients of the firm.
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AppendixA–Engagement\RetainerLetter
[Date]
RE:
Dear:
Thank you for agreeing to represent the interests of Medtronic, Inc., in the abovereferenced matter.
This letter is the formal retainer agreement between you, your firm, and Medtronic in
connection with this matter. Our engagement is governed by Medtronic’s Outside-LegalCounsel Policy (“OC Policy”) including its subparts: Outside Counsel Policy; Medtronic
Outside Counsel Travel Policy; No Conflict Acknowledgement Form; and Conflict
Waiver Request Form. These documents are available at http://www.medtronic.com/ocp.
All members of your firm who work on, or may work on, Medtronic matters should
become familiar with the OC Policy, including members of your accounting, billing, and
conflict-checking groups. If, after review of the OC Policy, you have any questions,
please contact me directly to discuss. Otherwise, please sign the retainer-agreement
acknowledgment below and return the signed copy to my administrative assistant at the
e-mail or fax number noted near my signature block.
Coordination, Contacts, and Communication
I am your principal contact at Medtronic on this matter. Please keep me timely informed
of all notable developments. In the event you are unable to reach me with questions or
concerns on the case, please contact my administrative assistant.
My activities sometimes take me away from my office; feel free to send me an e-mail
message if you are unable to reach me by phone. I typically have access to a computer
and check e-mails regularly. For the same reason, please do not send me a document by
mail or facsimile transmission without an accompanying e-mail notification of your
transmission.
For record-keeping reasons, please provide my administrative assistant with electronic
copies of all correspondence, briefs, important dates, and deadline information. It is
preferred that drafts of documents and other information or materials on which you
would like comment be provided electronically. Drafts should be emailed to me. Final
pleadings or other work product, however, should be emailed in PDF format to me and
my administrative assistant for recording in one or more of Medtronic’s databases.
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Cost Management
Medtronic expects you to keep at least a six-quarter rolling forecast of fees and expenses
for the matter, though a life-of-matter forecast is preferred. Medtronic asks that you give
it as much advance notice as is practicable for any change to the forecasted fees or
expenses.
We have agreed that the following attorneys and paralegals will work on this matter at
the following hourly rates:
Attorney
Rate ($/hr)
Paralegal
Rate ($/hr)
Medtronic understands that in certain circumstances attorneys and paralegals may need to
be replaced on Medtronic matters. Any required substitution must occur at no cost to
Medtronic for the new timekeepers to come up to speed on the matter. Please note that in
accordance with the OC Policy Medtronic will not pay for other timekeepers unless agreed
to in writing before any such work commences. Further in accordance with the OC Policy,
the rates agreed to for this matter cannot increase without the prior written approval of
Medtronic.
The following aspects of the matter are subject to a fixed fee or cost cap, as so indicated
below.
Description
Task
Code
Activity
Code
$ per
Fixed
Fee/ Cap
The flat fees and caps detailed above do not include reimbursable expenses as detailed in
the OC Policy. Medtronic does expect that expenses will be accurately projected and
included in forecasts and responses to any accrual request. Should there occur a major
change in the nature of the matter, Medtronic will discuss an appropriate revision to the
flat fee or cost cap. Absent a forewarning and agreement to revise, however, you agree
that the fixed fee and cost cap numbers are firm.
Medtronic greatly values you and your firm’s services and expertise. I look forward to
working with you on this matter.
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MEDTRONIC OUTSIDE COUNSEL ACKNOWLEDGMENT
The law firm noted herein acknowledges receipt of, access to, and agreement with the
terms of Medtronic’s Outside-Legal-Counsel Policy including its subparts in connection
with that firm’s representation of Medtronic regarding the re line of this retainer
agreement.
Pursuant to the Medtronic Outside Counsel Policy, the so-noted law firm certifies that,
upon reasonable inquiry, it
1. has no prior or current actual or potential conflict of interest in representing
Medtronic;
2. has an effective internal process for receiving, reviewing, tracking and
managing potential conflicts which may arise in connection with our
representation of clients;
3. has placed the representative list of Medtronic Competitors and representative
list of Medtronic Companies into its conflict checking system; and,
4. has no undisclosed prior or current actual or potential conflict of interest in
representing Medtronic.
Signed on behalf of [Name of Firm]:
__________________________
Date:
[Name of Responsible Partner]
Sincerely,
[Name of Medtronic Attorney]
[Title]
[Address]
[E-mail]
[Work phone]
[Mobile phone]
[Name of Administrative Assistant]
[E-mail]
[Fax]
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AppendixB‐AccrualCalendars,ForecastandAccrualForms
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AppendixC‐TravelPolicy
a. Introduction
Consistent with the Travel Policy for Medtronic employees, this policy
provides guidelines and procedures for outside counsel traveling on behalf of
Medtronic.
An attorney traveling on behalf of Medtronic is expected to exercise the same
care in incurring expenses as a prudent person traveling for personal reasons.
Failure to comply with this policy may result in the delay or withholding of
reimbursement.
Direct any questions regarding this policy to the Medtronic in-house attorney
with whom you are working.
b. TripPlanning
When to Travel
The decision to travel must be based solely on the need to fulfill the business
objectives of the company when a more economical alternative to travel does
not exist.
c. TravelAuthorization
Outside counsel must consult with the in-house Medtronic attorney for pretravel authorization. No particular form of pre-authorization is required;
verbal approval is acceptable.
d. TravelArrangements
Outside counsel should make their own travel arrangements. Outside counsel
should inquire as to whether Medtronic may have a preferred vendor rate at
hotels in the travel destination. Travel reservations should be made as far in
advance as possible to minimize cost.
e. LogicalFare(LLF)
All air travel must be booked at the lowest logical fare routing.
f. ClassofService
Coach class must be used for travel in and among the U.S., Canada, Mexico,
Puerto Rico, or the Caribbean.
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g. AirTravelRestrictions
Use of private aircraft or non-approved charter aircraft is not allowed.
h. UpgradesandIncidentals
Class of Service upgrades, at the expense of the company, is not permitted.
Individuals choosing to upgrade do so at their own expense.
Incidental travel charges such as in-flight internet access or checked bag fees
are not reimbursable unless specifically approved by Medtronic.
If staying over a Saturday night will result in a lower fare than the LLF quoted
by the travel agency, the company will reimburse the additional hotel night
stay, meals and other related expenses up to the amount of 1/2 the savings
realized from the discounted airfare. This is an option that can be voluntarily
chosen and is not a LLF requirement. The expenses attached to the Saturday
night stay must be incurred in the same city where the Medtronic business was
conducted.
The accumulation of "points" by participating in airline promotions is for the
traveler’s personal benefit.
i. Insurance
Personal insurance is not reimbursable. Outside counsel traveling on behalf of
Medtronic should provide their own travel and/or personal injury related
insurance.
j. LostLuggage
Lost luggage is not the responsibility of Medtronic.
k. HelicopterTravel
Helicopter travel is not permitted for point-to-point travel. Helicopter transfers
between airports for domestic to international connections (generally in New
York and Los Angeles) are permitted if provided free of charge by the airline
from which air transportation is purchased.
l. CarRental
Preferred Vendors
A car may be rented, if necessary, in connection with travel on behalf of
Medtronic. Outside counsel should consult with the Medtronic in-house
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attorney they are working with to identify Medtronic-preferred rental
company vendors (currently National Car Rental and Avis Car Rental).
Insurance
Medtronic’s rates through its preferred suppliers include liability insurance
coverage. All supplemental insurance on domestic rentals should be
declined. If extra insurance is elected, it is not a reimbursable expense.
Travelers are asked to accept the insurance coverage on international
rentals only if the rental is with a non-preferred supplier.
Collision Damage Waiver (CDW) insurance is a reimbursable expense on
international rentals not covered under a Preferred Supplier agreement. In
many European countries there is an Excess Damage charge (deductible)
that the traveler will be charged regardless of coverage provided by our
negotiated rate. Rental car agencies in Europe will often offer additional
insurances such as PAI and Excess Damage. PAI is considered additional
personal insurance and is not reimbursed by Medtronic.
"Excess Damage" is a maximum liability that still exists above and
beyond the insurance coverage provided in the Medtronic rate should the
vehicle become involved in an accident. Excess damage is a non-waivable
deductible for which the traveler is responsible, regardless of the purchase
of CDW. This liability can be "bought down" for an additional rate offered
by the car rental agency in the specific country in question.
Medtronic's travelers should not purchase any insurance over and above
that which you will receive simply by renting the car under the Medtronic
National Rental Car program agreement. In other words DO NOT "buy
down" the excess damage liability insurance under any circumstance.
Size of Car
When it is necessary to rent a car, use the smallest size vehicle appropriate
to accomplish your business purpose. As a general guide, when traveling
alone, a compact or an intermediate size car should be rented. When two
or more are traveling together, an intermediate or full size car may be
rented.
Refueling
Due to the surcharge added for refueling by the rental car company,
travelers are requested to refill the tank before returning the car.
Incidental Expenses
21
May 23, 2014
Medtronic reimburses for parking and tolls. All tickets or fines associated
with parking, and traffic violations are the responsibility of the individual
and will not be reimbursed.
m. GroundTransportation
Taxicab fares are reimbursable while on company business.
n. Meals
Medtronic will provide reimbursement for bona fide, reasonable business-related
meal expenses, accompanied by an original itemized receipt. Tips included on
receipts will be reimbursed. As a general rule, tips should not exceed 15% of the
total cost.
22
May 23, 2014
AppendixD‐ConflictWaiverRequest
CONFLICT WAIVER REQUEST
Date:
Completed by:
TO:
Vice President, Risk Management
Medtronic, Inc.
710 Medtronic Parkway
Minneapolis MN 55432
(Or by e-mail to: rs [email protected])
Section A: REQUESTING LAW FIRM COMPLETE
The following information is provided in support of a request for waiver from the
conflict provisions of the Medtronic Policy for Outside Legal Counsel Regarding
Conflicts of Interest.
1. Name of attorney requesting waiver:
Name of law firm:
Address:
Phone:
2. Date by which a waiver decision is requested:
3. Describe the conflict you believe exists:
4. Describe the work that was, and/or currently is being, performed for
Medtronic:
5. Names of attorneys of the firm involved in the prior and/or current matter:
6. Have you obtained a waiver from the other party as to this issue? If not,
please explain:
7. Have you previously asked any Medtronic employee for a waiver in regard to
this matter? If yes, please explain:
8. Are you seeking any limitations as to the waiver request? (e.g., that the
waiver will apply only to a particular matter or to particular individuals within
the firm requesting the waiver) If so, please explain:
9. Please provide any other relevant information which would allow “informed
consent” in assessing whether to grant a waiver.

In the event a decision has not been made by the requested date, requesting firm should not presume that a
waiver has been, or will be, granted.
May 23, 2014
23
AppendixE–InternationalRetainerLetter
[Date]
RE:
Representation of Medtronic and its Affiliates
Dear:
In working with your firm and other outside counsel, Medtronic’s objective is to obtain
superior legal services in the most cost-effective manner. In this context, we would like
to introduce you to the Medtronic Outside Counsel Policy (“OCP”), as attached, which
from now on will govern the relations with our outside counsels worldwide, including
yourselves. Please take some time to familiarize yourself with it and consult your contact
in-house lawyer at Medtronic in case of any questions.
Clearly, such a worldwide Policy cannot accommodate certain local differences. Please
be informed that, by way of exception, the following paragraphs are not applicable to our
relationship with you:
1. Professional Responsibility Rules and Choice of Law- The relevant
Professional Responsibility rules are those applicable in the jurisdiction under
which you are providing the relevant services to us. Similarly, the governing law
applicable to our relationship will be the relevant national law.
2. Conflicts of Interest and Medtronic Competitors – For the relevant list of
Medtronic Competitors, please use attached list. In case of any changes, we will
send you an update to be used going forward. With respect to the required
disclosures, we will respect any local confidentiality rules that are applicable and
may prevent you from disclosing clients’ names. In such cases, please consult
your relevant Medtronic in-house lawyer.
3. Sarbanes Oxley- To avoid any misunderstanding, these rules are only applicable
in the case you are providing advice under the laws of the USA.
Finally, we would like to stress the critical importance we attach to the observance of the
following billing requirements.
Statements not in compliance with these
requirements cannot be processed for payment and delays will inevitably result.
24
May 23, 2014
Billing. Unless otherwise agreed:
- billing statements and invoices must be submitted monthly within 30 days after the end
of the each month covered in the format required by the company in accordance with the
hourly rates appended to this letter or as may be otherwise agreed from time to time; and
- each statement should be addressed and sent to a designated Medtronic entity with a
given Purchase Order Number in accordance to Medtronic’s procurement policy for
review and approval by the relevant in-house counsel (payment will be made to your firm
upon our instruction).
Each statement must include, for each separate matter involved, (1) a detailed statement
of the services rendered on that matter during the month, (2) the name of the Medtronic
contact person, and (3) a chart identifying each attorney or paralegal who worked on the
matter, their respective hourly rate, and the total number of hours billed (you must
maintain a computerized or equivalent daily record of the time and nature of the services
provided by each individual which you will provide to designated counsel upon request).
The statement should also itemize disbursements by type and amount (for each matter if
possible).
We will use all reasonable efforts to ensure that invoices meeting these criteria are
promptly paid. We also expect that your firm will maintain back-up documentation for
all expenses for our review as we may request. In this regard, Medtronic reserves the
right to audit any billing statement or invoice at any time. Please be advised that we are
moving toward electronic bill submission and will let you know when we have that
system in place.
Please review this letter carefully and let your contact in-house lawyer at Medtronic
know immediately if you have any questions. We expect your adherence to these terms
and appreciate your working with us to achieve our objective of providing Medtronic
with superior legal services in the most cost-effective manner.
Yours sincerely,
Legal VP of Region
(insert lawyer’s name)
Medtronic International
AGREED AND ACCEPTED:
______________________________
By:
Date:
25
May 23, 2014
For International Use Only
List of Principal Medical Device Companies in Europe
Whose Representation Should be Disclosed to Us by Your Firm.
26

Abbott Laboratories

Biomet

Biotronik

Boston Scientific

Cook

Roche

Edwards Lifesciences

WL Gore

J&J

Smith & Nephew

Sorin Biomedica/ELA Medical

St. Jude Medical

Stryker

Synthes

Zimmer
May 23, 2014
AppendixF‐ApprovedThird‐PartyVendors
 MEDICAL RECORD COLLECTION/REVIEW AND ANALYSIS
Medical Research Consultants “MRC”
Gretchen Watson
[email protected]
National Account Representative
713.528.6326 (direct)
713.522.7386 (fax)
www.mrchouston.com
 COURT REPORTING
TSG Reporting, Inc.
Michael Rixon, CEO
[email protected]
Todd Dannhauser
Director of Global Business Development
(Phone) 877.702.9580
[email protected]
 LEGAL DOCUMENT SERVICES
(Copies, imaging, coding, digital)
RICOH USA, Inc. - www.ricoh-usa.com
 EDISCOVERY**
**Medtronic has preferred providers for eDiscovery work. Please contact your
Medtronic eDiscovery representative for all eDiscovery services.
27
May 23, 2014
AppendixG‐MedtronicCompetitorsbyDivision
Confidential and Proprietary
Rev.5/2014
Medtronic Competitors by Division
CVG (Cardiac Rhythm Disease Mgt)
ADVANCED CARDIAC THERAPEUTICS
(ACT)
AFREEZE
ATRICURE
BARD
BIOSENSE WEBSTER
BIOTRONIK CORPORATION
BOSTON SCIENTIFIC, INC.
CAMERON HEALTH (PART OF BOSTON
SCIENTIFIC)
CARDIOFOCUS
CATHRX
CRYCOR (NOW PART OF BSX)
ELA MEDICAL
EP MED SYSTEMS
ENDOSENSE
FLUX MEDICAL
IMRICOR
JOHNSON & JOHNSON COMPANIES
NANOSTIM
RHYTHMIA
SCOTTCARE
SORIN/ELA MEDICAL
ST. JUDE
TOPERA
TORAY
TRANSOMA
VOYAGE MEDICAL
CVG (Coronary)
ABBOTT
BIOTRONIX
BOSTON SCIENTIFIC/GUIDANT
CORDIS/JOHNSON & JOHNSON
ST. JUDE
TERUMO
CVG (Endovascular Therapies)
ABBOTT
ACOTEC (CHINA DEB)
ALTURA (AAA)
ANGIOMED
APTUS MEDICAL
ARSENAL
ATRIUM
AVINGER
BARD
BIOTRONIK
BOLTON
28
BIOSENSORS INTERNATIONAL
BOSTON SCIENTIFIC/GUIDANT
CARDIATIS
COOK MEDICAL
CORDIS/JOHNSON & JOHNSON
CORIDION
COVIDIEN
EDWARDS LIFESCIENCES
ENDOLOGIX
ESTECH
EUROCOR
GISH BIOMEDICAL
GORE MEDICAL
JOTEC
LIFETECH
LOMBARD
MEDRAD
NAJUTA
SHANGHAI MICROPORT
SORIN
SPECTRANETICS
ST. JUDE
TERUMO
TRIVASCULAR
VASCULAR SOLUTION
VASCUTEK
VOLCANO
CVG (Renal Denervation)
ABLATIVE SOLUTIONS
BIOSENSE WEBSTER/JOHNSON &
JOHNSON
BOSTON SCIENTIFIC/VESSIX VASCULAR
CARDIOSONIC
COVIDIEN
KONA MEDICAL
RECOR MEDICAL
ST. JUDE
TERUMO/ANGIOCARE
CVG (Structural Heart)
ABBOTT
ATRICURE
BOSTON SCIENTIFIC
BRAILE BIOMEDICA
DIRECT FLOW
EDWARDS LIFESCIENCES
ESTECH
May 23, 2014
JENAVALVE
MAQUET
MICROPORT
SYMETIS
SORIN GROUP
ST. JUDE
TERUMO
Diabetes
ABBOTT DIABETES
ANIMAS
ASANTE SOLUTIONS
DEXCOM
DISETRONIC, A DIVISION OF ROCHE
INSULET CORP
JOHNSON & JOHNSON – ONLY ANIMAS
AND LIFESCAN
OMNIPOD
ROCHE
SMITH’S MEDICAL
TANDEM
Neuromodulation
Al MANN FOUNDATION
ALLERGAN
BOSTON SCIENTIFIC
EUROPLASTY
FLOWONIX
JOHNSON & JOHNSON (CODMAN,
ETHICON, MENTOR)
NEUROPACE
NEUROS MEDICAL
NEVRO CORP
QiG GROUP (GREATBATCH)
SALIX
SALUDA MEDICAL
SAPIENS
SORIN
SPINAL MODULATION
SPR THERAPEUTICS
ST JUDE MEDICAL
STIMWAVE TECHNOLOGIES
Spinal
360 SPINE
4-WEB SPINE
AAP IMPLANTE
AAXTER
ACOLOGIX
ADAPTIVE SPECIALTY
ADVANCED BIOLOGICS
ADVANCED MEDICAL TECHNOLOGIES
ADVANCED VERTEBRAL SOLUTIONS
AESCULAP
AG DIGITAL TECHNOLOGY
29
ALGEA THERAPIES
ALLEGIANT SPINE
ALLIANCE SPINE
ALLOSOURCE
ALLURE SPINE
ALPHATEC SPINE
AMEDICA SPINE
AMENDIA (NBD, NIS, & SPINAL DEVICES)
ANATOMICA
ANOVA CORPORATION
ANULEX
AOI MEDICAL
APOLLO SPINE
APPLIED SPINE TECHNOLOGIES
ARCHIMED
ARCHUS ORTHOPEDICS
ARTHRO KINETICS
ARTHROCARE
A-SPINE USA
ATLAS SPINE
AUDAX MEDICAL
AURORA SPINE
AXIAL BIOTECH
AXIOMED
AXIS SURGICAL TECHNOLOGIES
BACTERIN
BAXANO
BENVENUE MEDICAL
BERKELEY ADVANCED BIOMATERIALS
BINDER BIOMEDICAL
BIOACTIVE BONE SUBSTITUTES
(FINLAND)
BIOCERAMIC THERAPEUTICS (U.K.)
BIOCOMPOSITES
BIOCURE
BIOE
BIOMEDICAL ENTERPRISES, INC.
BIOMEDICAL TISSUE SERVICES
BIOMET SPINE
BIOMIMETIC THERAPEUTICS
BIORTHEX
BIOSPINE (KOREA)
BIOSTRUCTURES
BIOSURFACE ENGINEERING
TECHNOLOGIES (BIOSET)
BIOSYNTECH (CANADA)
BIOTECHNI SA (FRANCE)
BIOTEK ORTHO (INDIA)
BK MEDITECH (KOREA)
BONE BIOLOGICS
BONEGRAFIX
BONE SOLUTIONS
BONESUPPORT AB
BRIGHT SPINE
CALCITEC
May 23, 2014
CALVARY SPINE
CAPTIVA SPINE
CARDINAL SPINE
CARDO MEDICAL (VERTEBRON)
CAREFUSION (CARDINAL HEALTH
SPINOFF)
CELLUMED
CENTINEL SPINE (RAYMEDICA)
CERAPEDICS
CERAVER
CHI2GEL
CHOICE SPINE
CITAGENIX
CLEARANT
CO.DON
CO-LIGNE AG
COALIGN INNOVATIONS (INNVOTEC
SURGICAL)
COLLAGEN MATRIX
COLLPLANT
COLUMNA PTY
CORELINK
CORENTEC
CORIN
COUSIN BIOTECH
COWELLMEDI
CREASPINE SAS
CROSSTREES MEDICAL
CRYOLIFE
CURATIVE BIOSCIENCES
CUSTOM SPINE
CUTTING EDGE SPINE
CYTOMEDIX
DALLEN MEDICAL
DEPUY SPINE (JOHNSON & JOHNSON)
DFINE
DIFUSION TECHNOLOGIES
DIO MEDICAL (KOREA)
DISC DYNAMICS
DISC MOTION TECHNOLOGIES
DISCOMEDIX
DOCTORS RESEARCH GROUP
DOXA
DYNAMIC SPINE
EDEN SPINE
EISERTECH
ELITE SURGICAL SUPPLIES
EMINENT SPINE
ENZTEC
ERGOSPINE
ESM TECHNOLOGIES
ESPINA
ETEX
EXACTECH SPINE (+ALTIVA)
EXPANDING ORTHOPEDICS
30
EVOLOGICS
FACET SOLUTIONS
FIBROGEN
FIXANO
FLEXUSPINE
G SURGICAL CO
GAMMA SPINE
GENTIS
GERRASPINE
*GLOBUS MEDICAL (Tier 2)
GM REIS (BRAZIL)
GOLD STANDARD ORTHOPEDICS
GRAFTYS
GS MEDICAL
GENESYS SPINE
HARVEST TECHNOLOGIES
HIGHGATE ORTHOPEDICS
HOOGLAND SPINE PRODUCTS (SPINE
NOW)
ICOTEC (SWITZERLAND)
IMPLANTS INTERNATIONAL (U.K.)
IMPLIANT
INCITE INNOVATION
INLAND SPINE
INNOVASIS
INNOVATIVE SURGICAL DESIGNS
INNOVATIVE SURGICAL SOLUTIONS
INTEGRA SPINE
INTELIFUSE
INTELLIGENT IMPLANT SYSTEMS
INTERVENTIONAL SPINE
INTRALINK-SPINE (ILS)
INTRINSIC THERAPEUTICS, INC.
IONICS MEDICAL
ISTO TECHNOLOGIES
JEIL MEDICAL
JEMO SPINE
JOIMAX
K2 MEDICAL
KAPSTONE MEDICAL
KASIOS
KENSEY NASH
KINAMED
KISCOMEDICA (FRANCE)
KOREA BONE BANK
KUROS BIOSURGERY
L & K BIOMED CO.
LANX, LLC
LDR SPINE
LFC MEDICAL (POLAND)
LIFE SPINE, LLC
LIFELINK
LIFENET
LIFESOURCE
LINARES MEDICAL DEVICES
May 23, 2014
LOUKAS MEDICAL
LUCERO MEDICAL
MAGELLAN SPINE TECHNOLOGIES
MAGEN MEDICAL SOLUTIONS
MAGROD
MAZOR ROBOTICS
MEDACTA INTERNATIONAL
(SWITZERLAND)
MEDICAL DESIGNS
MEDICALEX
MEDICINELODGE
MEDICREA
MEDIMONDI (BRICON)
MEDITECH ADVISORS
MED-TITAN SPINE
MEDYSSEY (KOREA)
MEKANIKA INC.
MERLOT ORTHOPEDIX
MERRIES INTERNATIONAL
MESOBLAST
MI4 SPINE
MIKAI SPINE (ITALY)
MIMEDX (SPINEMEDICA)
MUSCULOSKELETAL TRANSPLANT
FOUNDATION
NEURO FRANCE (FRANCE)
NEUROPRO TECHNOLOGIES
NEXGEN SPINE
NEXXT SPINE
NICAST (U.K.)
NOCIMED (DISCOGRAPHY)
NON LINEAR TECHNOLOGIES
NOVABONE
NOVASPINE
NP SOLUTIONS
NUTECH MEDICAL
NUVASIVE (CERVITECH)
OCTANE MEDICAL GROUP (CANADA)
OLSEN MEDICAL
ORTHO DEVELOPMENT
ORTHO SENSOR
ORTHO SOL MANUFACTURING
ORTHOBOND
ORTHOCON
ORTHODATA
ORTHOFIX
ORTHONICS
ORTHOPEDIC DEVELOPMENT CORP
(minSURG)
ORTHOVITA
OSD (FRANCE)
OSIRIS THERAPEUTICS
OSPREY BIOMEDICAL CORP
OSSEON THERAPEUTICS
OSTEOMED
31
OSTEORESORB
OSTEOSPHERE
OSTEOTECH
OTIS BIOTECH
OUROBOROS
PARADIGM SPINE (VISCOGLIOSI BROS.)
PARTEQ INNOVATIONS
PERFORMANCE GRAFTS
PHYGEN SPINE
PINA MEDIZINTECHNIK
PINNACLE SPINE
PIONEER SURGICAL TECHNOLOGY
PISHARODI SURGICALS, INC.
PRECIMED
PRECISION SURGERY LIMITED
PROGRESSIVE SPINAL TECHNOLOGIES
PROSPINE
PROVIDENCE MEDICAL TECHNOLOGY
R TREE INNOVATIONS
RANIER TECHNOLOGY
REDUCTION TECHNOLOGIES
REGENEEX
REGENTEC
RELIANCE MEDICAL SYSTEMS
RENOVIS SURGICAL TECHNOLOGIES
REPLICATION MEDICAL
RESTORATIVE PHYSIOLOGY GROUP
ROBERT REID
ROYAL OAK MEDICAL DEVICES
RSB SPINE
RTI BIOLOGICS
RX SPINE
S14 IMPLANTS
SANACOR
SANFORD HEALTH (DR. ASFORA)
SCIENT'X
SCIL TECHNOLOGY
SCOLIO GMBH (SWITZERLAND)
SCORPION SURGICAL TECHNOLOGIES
SEASPINE
SHOWA IKA KOHGYO
SI-BONE
SIGNUS MEDICAL
SIMPIRICA SPINE
SIMPLICITY ORTHOPEDIC SOLUTIONS
SINTEA PLUSTEK
SKELTEX (CANADA)
SMART DISC
SOLCO BIOMEDICAL
SOTEIRA
SOUTHERN SPINE
SPARTEK MEDICAL
SPECIALTY SPINE PRODUCTS
SPINAL EDGE
SPINAL ELEMENTS
May 23, 2014
SPINAL INSTRUMENTATION
SIMPLIFICATION SYSTEMS
SPINAL KINETICS
SPINAL RESTORATION
SPINAL USA
SPINALMOTION
SPINE SELECT
SPINE SURGICAL INNOVATION
SPINE WAVE, INC
SPINE21
SPINE360 (OMNI SURGICAL/ACME
SPINE)
SPINEALIGN MEDICAL (SPINEWORKS
MEDICAL)
SPINEART
SPINECRAFT
SPINEFORM LLC
SPINEFRONTIER
SPINEGUARD
SPINELAB
SPINEMEDICA
SPINENET (REO SPINELINE)
SPINEOLOGY INC.
SPINEOVATIONS
SPINESMITH LP
SPINEVIEW
SPINEVISION
SPINEWELDING AG
SPINEWORKS LLC
STABLE SPINE
STOUT MEDICAL GROUP
STRYKER CORP.
SURGICRAFT (U.K)
SURGIVAL (SPAIN)
SUSHRUT SURGICALS (INDIA)
SYNERGY DISC REPLACEMENT
SYNTEC SCIENTIFIC
SYNTHES
TAE YEON MEDICAL (KOREA)
TAKIRON
TECRES SPA
TEKNIMED
THE 4TH COLUMN
THERMOGENESIS
TISSUE BANKS INTERNATIONAL
TITAMED (SOUTH AFRICA)
TITAN SPINE
TORNIER
TRANS1
TRANSCORP
TRAUSON MEDICAL INSTRUMENT CO.
TRINITY ORTHOPEDICS
U & I (KOREA)
ULRICH MEDICAL
ULTIMATE SPINE
32
VARIAN
VERTEBRAL TECHNOLOGIES
VERTEBRATION
VERTECH
VERTICOR
VERTIFLEX
VERTOS MEDICAL
VEXIM
VG INNOVATIONS
VIDACARE
WARSAW ORTHOPEDIC
WENZEL SPINE (DJO/ENCORE MEDICAL)
WINTHERIX
WRIGHT MEDICAL
X-SPINE SYSTEMS
ZIMMER (+ABBOTT SPINE)
ZYGA TECHNOLOGY
Surgical Technologies (AE)
ACCLARENT
AESCULAP
ANSPACK
ARTHROCARE
BAXTER
BRAINLAB
CODMAN
CONMED
COVIDIEN
DOMAIN SURGICAL
ETHICON
GENERAL ELECTRIC
GORE
GYRUS
HAEMONETICS
INTEGRA
JOHNSON & JOHNSON
LORENZ
MEGADYNE
ORTHOVITA
PHILIPS
PRAXIM
RADIONIX
SIEMENS
SYNOVIS
SYNTHES
TOSHIBA
US MEDICAL INNOVATIONS, LLC
(CANADY)
UTAH MEDICAL
VALLEYLAB
Surgical Technologies (ENT)
ARTHROCARE
BRAINLAB
GENERAL ELECTRIC HEALTHCARE
May 23, 2014
JOHNSON & JOHNSON (ACCLARENT)
KARL STORZ ENDOSCOPY
OLYMPUS/GYRUS
STRYKER
Surgical Technologies (NAV)
BRAINLAB
Surgical Technologies (Neuro)
ANSPACK / SYNTHESIS
INTEGRA
STRYKER
33
May 23, 2014
AppendixH‐ElectronicInvoiceSubmissionGuidelines
34
May 23, 2014
35
May 23, 2014

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