Exhibit A

Case 2:15-md-02641-DGC Document 8227-1 Filed 10/18/17 Page 1 of 28
Deposition of:

Robert McMeeking , Ph.D.

July 6, 2017

In the Matter of:

In Re: Bard IVC Filters Products

Liability

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Case 2:15-md-02641-DGC Document 8227-1 Filed 10/18/17 Page 2 of 28
Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 market.

2 BY MS. DALY:

3 Q Is it your opinion that Bard failed to

4 reduce as far as reasonably practicable the

5 remaining risks by taking adequate protection

6 measures?

7 A Can you repeat the question, please.

8 Q Yes.

9 Is it your opinion that Bard failed to

10 reduce as far as reasonably practicable the

11 remaining risks by taking adequate protection

12 measures?

13 MR. O'CONNOR: Form and foundation.

14 THE WITNESS: In certain of the designs of

15 the filters those risks, in my opinion, were not

16 reduced to the extent practicable, and I would say

17 that that applies to all of the models that we are

18 discussing in the -- in the present case.

19 BY MS. DALY:

20 Q And which risks do you identify -- that

21 you have an opinion that Bard failed to reduce?

22 A The risks of tilting, perforation,

23 migration and fracture by fatigue.

24 Q Have you determined by any research or any

25 other method that any other manufacturer of

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 percutaneously retrievable IVC filters have been

2 able to reduce as far as reasonably practical --

3 practicable by taking adequate protection measures

4 any of those risks you just identified?

5 MR. O'CONNOR: Form and foundation.

6 BY MS. DALY:

7 Q In filters.

8 A I have not investigated that in many

9 cases, and in other cases I'm under restrictions in

10 terms of what I can say when I have been involved

11 in investigating that.

12 Q Do you rely on any of the work that you

13 have done that you cannot talk to me about for your

14 opinions in this case?

15 A No.

16 MR. O'CONNOR: Form.

17 BY MS. DALY:

18 Q So anything that you have learned either

19 as a consulting expert or a retained expert with

20 respect to other IVC filters you do not rely on for

21 your opinions in the Bard litigation?

22 A Yeah, I do not rely on that other

23 information.

24 Q Okay. And I'm aware that you've been

25 retained in the Cook litigation.

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 A That's correct, yes.

2 Q Because that's been public. Okay.

3 I think you just said a moment ago that

4 with respect to all of Bard's retrievable filters,

5 that is from the Recovery to the Denali, that it is

6 your opinion that Bard has not done what is

7 reasonably practicable to take adequate protection

8 measures against tilt, perforation, migration and

9 fracture?

10 A That's correct.

11 Q Okay. Is it your opinion that the various

12 modifications that Bard has made along the way to

13 its retrievable IVC filters did nothing to reduce

14 the risks associated with either tilt, perforation,

15 migration or fracture?

16 MR. O'CONNOR: Form.

17 THE WITNESS: The -- some of the changes

18 that were made would have some effects on one or

19 more of those phenomena that can take place in

20 filters, and in some cases it's unclear whether the

21 measure taken had the effect intended, but -- but

22 there would have been some benefits from some of

23 the changes which were made.

24 BY MS. DALY:

25 Q Have you specifically modeled any filter

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 from the G2X, Eclipse, Meridian or Denali models?

2 A I've modeled the G2X. I have modeled all

3 of the filters in the sense that I've made the

4 assessment that they all have similar

5 characteristics and, therefore, in certain of the

6 aspects of the behavior, the response will be the

7 same -- will be very similar in each of the

8 filters.

9 Q When you say "model," with respect to the

10 G2X on to the Denali, you've looked at design

11 drawings, correct?

12 A Correct.

13 Q And you've taken -- you've looked at the

14 measurements of the, you know, length of legs or

15 width of legs, those sorts of things, correct?

16 A Well, I've relied on the engineering

17 drawing to give me the values of those lengths.

18 Q So in that sense you've -- you've modeled

19 from the design drawings, correct?

20 A Well, I should -- I should clarify my

21 response.

22 I have looked at those drawings and I've

23 compared all the filters with each other in terms

24 of their size and shape and so on, and then that

25 has allowed me to make a deduction that my modeling

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 of the G2 and the G2X is representative of the

2 behavior that one would expect to see in the models

3 namely the Eclipse, the Meridian and the Denali.

4 Although not exactly the same, there would be

5 similar behavior in each of these other three

6 filters.

7 Q Have you done any FEAs specific to the

8 Eclipse, the Meridian or the Denali?

9 A I have not done FEA analysis specific to

10 the Eclipse, Meridian and Denali.

11 Q And you have not done work that would tell

12 you what the specific modifications of filters that

13 Bard has -- has included would do with respect to,

14 for example, loads on the filter, strains that the

15 filter is --

16 A I have not --

17 MR. O'CONNOR: Form and foundation.

18 BY MS. DALY:

19 Q Let me finish.

20 MR. O'CONNOR: Let her finish the

21 question.

22 BY MS. DALY:

23 Q Let me finish.

24 -- strains that the filter sees or loads

25 that are put on those filters?

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 MR. O'CONNOR: Form and foundation.

2 THE WITNESS: I have not done any

3 calculations that specifically identify the

4 detailed differences that would occur because of

5 the design changes going from the G2X through to

6 the Denali.

7 BY MS. DALY:

8 Q So going back to the language of the

9 standard, on what do you base your opinion that

10 Bard has not done what is reasonably practicable to

11 take appropriate protection measures in any of its

12 retrievable filters against the complications that

13 you identified?

14 A Well, part of the issue is that they

15 should have taken certain measures sooner than they

16 ultimately did and that the measures that they

17 eventually took were not necessarily effective at

18 reducing the risk to the extent practicable and

19 they didn't investigate the consequences -- they

20 didn't investigate thoroughly the consequences of

21 the trade-offs that were involved in the design

22 changes to modify the filters from the G2

23 through -- G2X through to the Denali.

24 Q How would they have done that differently?

25 A Well, they would have done more

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In Re: Bard IVC Filters Products Liability

1 efforts that Bard made to add these anchors and

2 limiters that were unsuccessful initially and more

3 changes had to be made?

4 MR. O'CONNOR: Form.

5 THE WITNESS: I do know that some of the

6 designs of the caudal anchors that they

7 investigated did not work as well as others.

8 BY MS. DALY:

9 Q The other thing you talked about was that

10 Bard could have redesigned the configuration of its

11 filters. It was a little vague to me. What do you

12 mean by that?

13 A Well, I mean the -- the shape of the

14 limbs, the dimension of the limbs, in other words

15 their -- their diameter, they could have considered

16 different numbers of limbs, they could even have

17 considered moving to a different material. So

18 there's a fairly large number of design choices

19 that could have been considered, and they could

20 well have come up with a combination of features in

21 the design that gave them a better combination

22 of -- of phenomena in terms of how the filter

23 behaved.

24 Q Do you know -- are you aware of any steps

25 that Bard took along the way from Recovery to

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 didn't have them at that time. So you don't know?

2 A I don't know.

3 MR. O'CONNOR: Form.

4 BY MS. DALY:

5 Q Having looked at the Denali filter, you do

6 see that there are some differences in that filter

7 than the previous ones, true?

8 A Yes, that's correct.

9 Q Okay. Is it your opinion that Bard has

10 failed to reduce as far as reasonably practicable

11 by taking adequate protection measures risks of

12 tilt, perforation, fracture and migration in the

13 Denali?

14 A Yes.

15 Q And what's the basis for that?

16 A Because you still see incidences of all of

17 those phenomena in Denali filters.

18 Q We'll -- we'll talk about that further

19 later.

20 You have not undertaken to compare

21 reported rates or reported incidents, let's put it

22 that way, reported numbers of incidents of any of

23 the complications you've identified in the various

24 ones of the Bard filter models, have you?

25 A No, I have not done that.

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 fracture known and foreseeable risks of IVC

2 filters?

3 A Of many IVC filters, yes.

4 Q And are you aware that some of those

5 events have undesirable effects on the patient and

6 some don't?

7 MR. O'CONNOR: Form.

8 THE WITNESS: Well, I'm not a medical

9 expert so I can't really answer that question.

10 BY MS. DALY:

11 Q Fair enough.

12 And similarly, as an -- as an engineer,

13 you're not qualified to give an opinion as to what

14 the benefits are of any -- to any given patient of

15 the use of an IVC filter, true?

16 MR. O'CONNOR: Form.

17 THE WITNESS: No, I would not do that. I

18 would not offer such opinions on the benefits.

19 BY MS. DALY:

20 Q Okay. Are you giving any opinions in this

21 litigation that Bard complied with or failed to

22 comply with any specific FDA regulations?

23 A No, I'm not offering such opinions.

24 Q If you look at page 10 of the report

25 you're looking at now, you say that "Bard was not

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 frank and honest with the FDA and did not fully

2 inform the FDA of deficiencies in the G2 filter."

3 Do you see that? It's at the very last

4 long sentence at the bottom of 10.

5 A Yes. I see that.

6 Q What's the basis for your opinion?

7 A The basis, I'm relying on Dr. Parisian for

8 that opinion.

9 Q Okay. You have not reviewed the materials

10 that she has reviewed, for example, true?

11 A I've not reviewed --

12 MR. O'CONNOR: Form.

13 THE WITNESS: -- all of that material. I

14 probably have seen some of it.

15 BY MS. DALY:

16 Q And to your point a moment ago that you

17 are not giving opinions about FDA regulations, is

18 it also fair to say that you are not giving

19 opinions about what Bard's corporate behavior was

20 vis-a-vis what was expected by the FDA?

21 A I'm --

22 MR. O'CONNOR: Form.

23 THE WITNESS: I'm not offering such

24 opinion. Although may I go back and add to my

25 answer to your previous question --

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 severe stiffness constraint on whether the relative

2 motion of the arms and the legs can be accommodated

3 as the filter, if you like, tries to stretch. So

4 that -- that's a possibility.

5 Q Do you have any case that you can point to

6 that you have worked on where there was imaging

7 evidence of perforation, tilt or migration that

8 occurred before a leg fracture?

9 A I haven't looked into that.

10 MR. O'CONNOR: Belated objection to the

11 form of the question.

12 BY MS. DALY:

13 Q Have you done any work to determine what

14 modifications Bard could have made to the legs

15 themselves to improve on those legs' contribution,

16 if any, to tilt, perforation, fracture or

17 migration?

18 A No, I haven't looked into that.

19 Q We've talked a little bit about the

20 anchors and limiters present on the Meridian. Is

21 it your opinion that those are reasonable

22 modifications by Bard to -- to improve resistance

23 to migration, tilt and perforation?

24 A It's a reasonable concept for how the tilt

25 and migration behavior can become -- can be

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 limited.

2 Q Would -- do you have an opinion whether

3 those anchors or limiters on the Meridian would add

4 fracture resistance to that filter?

5 A I have no opinion on that.

6 Q Same questions with Denali, do you think

7 that the limiters that the Denali has will act to

8 improve resistance to migration, tilt, perforation

9 and fracture?

10 MR. O'CONNOR: Form.

11 THE WITNESS: It's -- it is reasonable to

12 expect that there will be some effect on -- on tilt

13 and migration and that those would have possible

14 knock-on consequences to perforation and fracture.

15 And so I'd like to revise my answer about the

16 Meridian in the same way, that the caudal anchors,

17 to the extent they limit tilt and migration, they

18 could have beneficial effects on perforation and

19 fracture.

20 BY MS. DALY:

21 Q Okay. What modifications to the G2 filter

22 assisted in resistance to cephalic migration? Do

23 you have an opinion on that?

24 MR. O'CONNOR: Form.

25 THE WITNESS: I'm not aware of any changes

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 that would have had an impact on cephalic

2 migration.

3 BY MS. DALY:

4 Q Are you aware that the incidents of

5 cephalic migration of G2 and later Bard filters

6 has -- has improved greatly?

7 A I'm not aware of that.

8 Q What about the change to the G2 filter

9 contributed to caudal migration, if you have an

10 opinion?

11 MR. O'CONNOR: Form.

12 THE WITNESS: Sorry, can you repeat the

13 question.

14 BY MS. DALY:

15 Q Yeah.

16 Do you have an opinion about whether any

17 design modification that Bard made to the G2 filter

18 resulted in caudal migration?

19 A You mean going from the Recovery to the G2

20 filter --

21 Q Yeah.

22 A -- whether that improved caudal migration?

23 Q No, whether it caused it.

24 A Whether it contributed to it.

25 Q Yes.

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 A I have no opinion on that because I have

2 not studied it.

3 Q Okay. Have you studied what the mechanism

4 is anatomically to create caudal migration in any

5 Bard filter?

6 A I've not studied that independently.

7 Q Okay.

8 A I've only --

9 Q What does that mean?

10 A What does it mean. I've looked at the

11 Bard report of their bench test --

12 Q Okay.

13 A -- and -- which is suggestive of a

14 mechanism that can drive caudal migration.

15 Q Okay.

16 A Because it's -- because it's associated

17 with tilt.

18 Q Okay. And have you done any work to

19 determine how Bard might have modified its filters

20 to reduce tilt that you associate with caudal

21 migration, with contributing to caudal migration?

22 MR. O'CONNOR: Form.

23 THE WITNESS: Well, the only observation I

24 have is that the effective caudal anchors would

25 have had a beneficial effect, but otherwise I've

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 done no thinking or studying of that.

2 BY MS. DALY:

3 Q All right. If you look at your report,

4 page 13, it's the G2 Express filter.

5 A Yes.

6 Q We've talked about the cap change I think

7 exhaustively.

8 A Yes.

9 Q And did you have any other observation of

10 the G2 Express as -- as having characteristics that

11 that particular filter had that contributed to any

12 of these complications different from Recovery and

13 G2?

14 A Well, the cap -- sorry, the hook on the

15 cap, because it would have touched -- during tilt

16 it would have been touched, under certain

17 assumptions about how the filth occurs, it would

18 have touched the wall of the vena cava first as

19 opposed to other points on the cap, and that would

20 have had some effect on what happens in terms of

21 perforation and tilting of the -- of the filter.

22 And it's my assumption that the big hook

23 would have taken -- would have been -- would have

24 taken longer to perforate through the wall of the

25 vena cava than the cap itself, although that's just

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 A I don't have any information on that.

2 Q What about its ability to migrate either

3 cephalad or caudal, do you have any information on

4 that?

5 A I have no direct information on that.

6 Q So your criticism is that there are

7 aspects of the Denali that in your opinion will

8 allow it -- make it that it can tilt, perforate,

9 fracture or migrate?

10 A Yes. And I -- I -- I should comment that

11 there is some description of -- of events for the

12 Denali in the supplementary report.

13 Q Right. Right. And I'm going to --

14 A I don't mean to ignore --

15 Q -- get to those.

16 A -- that.

17 Q Yeah, I'm going to get to those.

18 Okay. Do you know of modifications to the

19 Bard filters, any of them, that would have made

20 them unable to fracture, tilt, perforate or

21 migrate?

22 MR. O'CONNOR: Object to the form of the

23 question.

24 May I hear the question back again.

25 THE WITNESS: Could you repeat the

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 question.

2 MS. DALY: Can you read that one.

3 (Record read as follows:

4 "Do you know of modifications to

5 the Bard filters, any of them,

6 that would have made them unable

7 to fracture, tilt, perforate or

8 migrate?")

9 THE WITNESS: I haven't studied that.

10 BY MS. DALY:

11 Q So you -- you do not have an opinion that

12 there was a method by which Bard could eliminate

13 tilt, fracture, perforation or migration in any one

14 of its iterations from Recovery to Denali?

15 MR. O'CONNOR: Form and foundation.

16 THE WITNESS: You mean simultaneously

17 eliminate all of those negatives?

18 MR. O'CONNOR: Form.

19 BY MS. DALY:

20 Q Or one by -- or any of them, either all of

21 them or, yes, you could -- you could have

22 eliminated completely this, this or this.

23 A Well, I -- I think it's possible to

24 eliminate one of the phenomena by itself but --

25 Q What's that?

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In Re: Bard IVC Filters Products Liability

1 either with your analysis?

2 A No, I have not.

3 MR. O'CONNOR: Form.

4 BY MS. DALY:

5 Q Okay. Are you aware of any FDA

6 regulations relating to testing that Bard failed to

7 meet?

8 MR. O'CONNOR: Form.

9 THE WITNESS: I'm -- I'm not giving any

10 opinion on what they did relative to requirements

11 of the FDA.

12 BY MS. DALY:

13 Q All right. Thank you.

14 Are you going to provide an opinion that

15 Bard had a higher rate of any particular type of

16 complication relative to other filters?

17 MR. O'CONNOR: Form.

18 THE WITNESS: I'm not going to offer any

19 opinion on the relative rates of complications of

20 one filter versus another.

21 BY MS. DALY:

22 Q What about one Bard filter versus another

23 Bard filter?

24 A I'm not going to give an opinion on that

25 because I don't have enough data to truly assess

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In Re: Bard IVC Filters Products Liability

1 the situation.

2 Q Okay. You're not going to give opinions

3 on your interpretation of medical literature that

4 reports on various incidents of complications then;

5 is that correct?

6 A I'm not going to give opinions on what's

7 in the medical literature, other than to say that

8 they're consistent with my assessment of the

9 engineering considerations of the filter and that

10 they tend to confirm that the filters are --

11 have -- are dangerous.

12 Q Well, let's talk about that a minute.

13 What you -- what you would take from medical

14 literature is that there are reports of, for

15 example, fracture, perforation, tilt and migration

16 in Bard filters, true?

17 A Yes, that's correct.

18 Q And you also see medical literature that

19 says that there are perforations, tilts, migration

20 and fractures in other IVC filters on the market,

21 true?

22 A I'm aware of those reports.

23 Q Okay. And so what did you -- how are you

24 using medical literature to support a conclusion of

25 dangerousness? That's where I'm --

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In Re: Bard IVC Filters Products Liability

1 Q Did you read her report?

2 A I read it at the time that I wrote this

3 report.

4 Q Okay. Did you review any of the actual

5 data that she analyzed?

6 A I looked at tables and other information

7 in her reports. So in that sense I -- I reviewed

8 it.

9 Q Her Excel sheets, did you --

10 A No, I didn't --

11 Q -- review her --

12 A No, I did not look at her Excel sheets.

13 Q Okay. Do you know what information her

14 spreadsheets contain or don't contain with respect

15 to information about the Simon nitinol filter

16 versus other Bard filters?

17 A Well, I understand that the -- her Excel

18 sheets contain information about failures that were

19 identified in Bard and -- well, Bard filters and

20 that the source of some of that information was

21 more data, and so on.

22 Q Do you know what time frames she had data

23 for -- data from?

24 A I would need to look at her report to give

25 you a specific answer to that.

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In Re: Bard IVC Filters Products Liability

1 Q Okay. If I tell you that she had data on

2 the Simon nitinol from 2004, do you know that one

3 way or another?

4 A I --

5 MR. O'CONNOR: Form.

6 THE WITNESS: I don't know that

7 information, but I could establish it by reviewing

8 her report.

9 BY MS. DALY:

10 Q Well, it -- that's fine.

11 You did not perform any of the biostat- --

12 biostatistical calculations that went into her

13 report, true?

14 A No, I -- yes, that's true, I did not carry

15 out any of those calculations.

16 Q And you did not independently verify her

17 work?

18 A No.

19 Q Did you provide her with any information

20 that she used in her report or that she

21 considered --

22 A No --

23 Q -- as far as you know?

24 A -- I provided her no information.

25 Q Have you talked to her about the report?

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In Re: Bard IVC Filters Products Liability

1 Q You received it from an attorney?

2 A I received it from an attorney.

3 Q Okay. And you had not had that before?

4 A No, I had not had an exemplar in my

5 possession before.

6 Q Did your examination of the exemplar

7 change anything that you've written in the rebuttal

8 report about the SNF --

9 A No.

10 Q -- or how it compares --

11 A No.

12 Q -- to the Bard filters?

13 A No.

14 Q All right. You -- to do your rebuttal

15 report, you looked at the engineering drawings for

16 the SNF --

17 A Correct.

18 Q -- is that true?

19 A That's correct.

20 Q What else did you look at?

21 A I looked at -- well, I was looking at the

22 510(k) for the Recovery --

23 Q Okay.

24 A -- and it told me various things to do

25 with changes that were made, such as the diameter

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Robert McMeeking , Ph.D. July 6, 2017

In Re: Bard IVC Filters Products Liability

1 of the -- of the limbs and the material of which

2 the filters were made, and so that enabled me to

3 draw conclusions about how to compare the Simon

4 nitinol with the other filters.

5 Q Okay. And the Simon nitinol filter is

6 basically -- got a round -- a rounded dome with

7 petals. You've got a good diagram of that at the

8 back of the report. And then legs on the bottom,

9 six legs?

10 A That's correct, yes.

11 Q Okay. What design characteristics of the

12 Simon nitinol filter make that filt- -- made that

13 filter not retrievable percutaneously?

14 MR. O'CONNOR: Form and foundation.

15 THE WITNESS: Well, I'm not entirely sure

16 because I've not investigated that situation, but

17 it's my surmise that it is the extent of -- of

18 connection among the wire -- wires of the petals

19 and the vena cava wall which presents more material

20 that can bond from the vena cava wall to the petals

21 of the -- of the filter, and so that will generate

22 a robust connection between the filter and the vena

23 cava wall.

24 BY MS. DALY:

25 Q Did --

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1 A And also the -- the legs do seem to

2 perforate to some extent through the wall of the

3 vena cava, and I -- I'm assuming that that would

4 present complications upon retrieval.

5 Q Did you investigate whether once deployed

6 that petal formation was at all difficult to slim

7 back down, if you will, to crimp it into a sheath

8 for retrieval?

9 A Well, I made an estimate of the stiffness

10 of those petals, and so although I didn't make a

11 comparison with what is required to put it into the

12 delivery sheaths, I -- I did have the analysis at

13 hand from which that could be undertaken.

14 Q And you determined they were pretty stiff?

15 A They're -- they're

16 Q Not to use a good engineering term.

17 A Yeah, they're -- they're stiff compared to

18 the Bard arms -- sorry, the arms on the Recovery,

19 the G2, and other subsequent filters.

20 Q And the legs are stiffer than the Recovery

21 and other retrievable --

22 A Yes.

23 Q -- Bard filters as well?

24 A That's correct.

25 Q Okay. You understand that the -- that

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1 filter overall, anything like that, that

2 contributes to migration resistance?

3 A Well, the diameter of the wire controls

4 the stiffness of the wire -- of the components that

5 are made from the wire, so that has a -- that has

6 an effect, which I've already alluded to in the --

7 in the answers I just gave.

8 Q Okay.

9 A The length of the petals and the lengths

10 of the legs also contribute to controlling the

11 stiffness, so those would contribute as well. And

12 I'm not sure if I can identify anything else, but

13 those were -- those would be the things that I

14 would identify.

15 Q Did you do any analysis of how one would

16 make changes to either the petal dome or the legs

17 of the SNF to allow it to be retrievable?

18 A Can I augment my answer of just a second

19 ago? The -- the diameter or the span of the petals

20 and the span of the arms -- the legs relative to

21 the diameter of the vena cava would contribute to

22 the forces which are involved and, therefore,

23 contribute to the question of whether migration is

24 or is not likely in the Simon nitinol filter.

25 But to move on to your subsequent

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1 question, I didn't make -- do any analysis to look

2 at what changes might -- what changes -- what

3 impact they would have on the behavior of the -- of

4 the filter.

5 Q Including the last thing that you just

6 mentioned to me, the difference in span?

7 A Yes.

8 Q How that might have to be re-engineered to

9 allow for retrieval?

10 A I did not look at that.

11 Q Okay. The next thing that I saw from your

12 report was that the design of the SNF legs make

13 them more prone to perforation than the struts of

14 the Recovery and the G2?

15 MR. O'CONNOR: Where are you looking at in

16 the report?

17 BY MS. DALY:

18 Q The different ones start on page 11. Your

19 first one was migration, and then the little B on

20 page 11 is where I'm reading from right now.

21 I'm sorry, that's not where I got it from.

22 Go to page 13. I apologize. B on page 13.

23 A Yes.

24 Q So I think what you concluded there was

25 that the legs of the Simon nitinol were more prone

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