CHRIS T. WILSON, Individually and as Representatives for all others similarly situated and the General Public. This is a national class action against:

MEDTRONIC, INC.

on behalf of all those who allege to have had certain heart defibrillator devices known as implantable cardioverter defibrillators (ICD) and cardiac resynchronization therapy defibrillators (CRT-D) installed in their body. For a period of time believed to extend from 2001 to 2003, defendant placed defective batteries in the devices, in that they can rapidly become depleted and lose power due to a design or manufacturing flaw, sometimes with no advance warning indications. The suit asks for an injunctive relief, exemplary damages, compensatory damages suffered by Plaintiffs and the members of the Class, attorneys fees, and costs of suit.