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`
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`1, Max Richard Wood, hereby declare as follows:
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`1.
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`My name is Max Richard Wood, my date of birth is January 24, 1945,
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`and my address is 1380 Barhurst Concession 7, RR 7, Perth, ON, K7H 3C9
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`Canada.
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`2.
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`Since October 17, 1996 I have been a registered Patent Agent before
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`the United States Patent and Trademark Office (hereinafter “PTO”) and my
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`Registration Number is 40388.
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`In my capacity as a Patent Agent, I prepared US.
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`Application Serial Number 09/373,418 (hereinafter “’418 Application”) that issued
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`on January 30, 2001 as US. Patent Number 6,179,053 (hereinafter “’053 Patent”)
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`on behalf of the named inventor L. Murray Dallas. 1 did not file or prosecute that
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`application in the PTO.
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`3.
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`I make this declaration based on my personal knowledge and
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`recollection of the preparation of the ’418 Application.
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`4.
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`At the time I prepared the ’418 Application, I was aware that Stinger
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`Wellhead Protection Inc., a company owned and operated by Mr. Dallas, had made
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`and used a tool that I understood practiced the invention claimed in US. Patent No.
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`5,819,851 (hereinafter “’851 tool”).
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`I was aware that the ’851 tool had been used
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`in the field and that customers were generally enthusiastic about the idea of a
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`wellhead isolation tool that provided full-bore access to the production casing of a
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`“live well” Le, a well containing natural well pressure, which was one of the
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`
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`Case IPR2014-00216
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`Patent No. 6,179,053
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`features of the ’851 tool.
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`In the ’418 Application I stated that “The blowout
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`preventer protector is widely accepted in the industry and the hydraulic setting tool
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`is very convenient for securing a mandrel of a well tool in the operative position
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`requiring fixed-point packoff in the well.”
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`5.
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`I do not recall the details of the preparation of the ’418 Application and
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`cannot say with certainty what this statement was intended to convey. Nor do I
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`recall being aware at the time I was preparing the ’418 Application of how the
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`commercial embodiment of the ’851 tool had performed when used in the field.
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`In
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`particular, I have no recollection of being aware at that time that the ’851 tool had
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`failed on numerous occasions. Nonetheless, I am confident in stating that the
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`comment about the blowout preventer protector being “widely accepted in the
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`industry” was not meant to suggest that such failures had not occurred with the
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`’851 tool or that the ’851 tool actually functioned reliably for its intended purpose.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct. Further, these statements are made
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`with the knowledge that willful
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`false statements are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the 246 United States
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`Code.
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`Dated: Q0ZZ’DXIXZ
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`ngE( 42
`
`Max R. Wood
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`3
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`
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