Medtronic is a medical device company that produces and markets class III devices, which include implantable cardiac pulse generators and neurological stimulators (devices), as well as other medical therapy devices (leads). Medtronic’s parent company, Medtronic US, and its distributer, Medtronic USA, Inc. are located in the United States, and its class III device manufacturer, Medtronic Puerto Rico Operations Co. (MPROC), is located in Puerto Rico. Medtronic allocates the profit earned from its devices and leads between Medtronic US, Medtronic USA, and MPROC through its intercompany licensing agreements.