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TVS2200: How many GND via holes is sufficient for the surge energy IEC 61000-4-5 (8/20 µs): 40 A

Part Number: TVS2200

Tool/software:

Hi expert, 

Customer would like to know if the TVS2200 GND side has layout limitation and cannot connect to the PGND plane of the surface side which means TVS2200 GND is an independent small plane. If so, then how many GND via holes is recommended for the surge energy IEC 61000-4-5 (8/20 µs): 40 A? 

Best regards, 

Randy