Paper No. 70
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BAKER HUGHES, A GE COMPANY, LLC
`and
`BAKER HUGHES OILFIELD OPERATIONS LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.
`Patent Owner
`
`______________
`
`Case IPR2016-01496
`Patent 7,134,505
`______________
`
`
`PETITIONERS’ MOTION TO EXCLUDE
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`28743210.1
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`
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`BAKER HUGHES, A GE COMPANY, LLC
`and
`BAKER HUGHES OILFIELD OPERATIONS LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES, INC.
`Patent Owner
`
`______________
`
`Case IPR2016-01496
`Patent 7,134,505
`______________
`
`
`PETITIONERS’ MOTION TO EXCLUDE
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`28743210.1
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`Case IPR2016-01496
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`Petitioners move to exclude the following exhibits and testimony pursuant to
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`Rule 42.64:
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`Ex. 2039 (Weatherford Presentation)
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`Objections: (1) Authentication – Federal Rule of Evidenec (“FRE”) 901(a); and
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`(2) Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 571 at 1-2.
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`Locations exhibit is relied upon by Rapid Completions (“RC”): Patent
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`Owner’s Response (“POR” – Paper 56) at 23, 28-29; and, to the extent considered,
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`Exs. 2081/2084 at 33-51/51.
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`Explanation: RC has not proven authenticity. RC has not filed a declaration of
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`any person purporting to have personal knowledge of Ex. 2039, nor presented any
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`other evidence of Ex. 2039’s authenticity Therefore, Ex. 2039 should be excluded
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`under FRE 901.
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`
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`In addition, whatever portions2 of Ex. 2039 RC relies on are offered to prove
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`the truth of each matter asserted. On page 23 of its POR, RC cites Ex. 2039 to
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`support its assertion that Weatherford sells and markets a competing system using
`
`an open hole ball drop system. Similarly, on pages 28-29 of its POR, RC cites Ex.
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`1 This is Paper 57 of IPR2016-00596 (as are all papers cited in this motion)
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`2 RC does not provide pinpoint cites in its POR, though it does reproduce a figure
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`on page 33/53 of Ex. 2039.
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`2039 to support its assertion that Weatherford’s advertising and marketing
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`documentation establishes a nexus between the Challenged claims and its alleged
`
`commercial success. However, RC has not shown that any hearsay exception
`
`applies, and has not presented the testimony of anyone with first-hand knowledge
`
`of the information from Ex. 2039 on which it relies. Therefore, Ex. 2039 (and,
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`more specifically, whatever information from Ex. 2039 RC (through its POR or its
`
`expert’s declaration) relies on) should be excluded under FRE 801(c) and 802.
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`Ex. 2047 (Rystad Energy report)
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`Objections: (1) Authentication – FRE 901(a); (2) Hearsay – FRE 801(c), 802; and
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`(3) Relevance – FRE 401, 402, and 403.
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`Location of prior objections: Paper 57 at 5-6.
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`Locations exhibit is relied upon by RC: POR at 17, 26-27; and, to the extent
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`considered, Exs. 2050/2051 at 45:25-29 and Exs. 2081/2084 at 26:15-27:5.
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`Explanation: RC has not proven authenticity. RC filed a declaration by its
`
`paralegal (Ex. 2082 at ¶¶ 1, 2), purporting to authenticate Ex. 2047 (Ex. 2082 at
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`¶ 11), but failed to establish a foundation that would enable Mr. Delaney to
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`competently testify about the exhibit’s authenticity. The fact that Petitioners
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`produced Ex. 2047 in litigation is irrelevant. See POR at 17. Furthermore, Mr.
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`McGowen also took no steps to authenticate or otherwise verify the Ex. 2047
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`information on which he relied. Ex. 1134 at 142:7-145:17.3 Therefore, Ex. 2047
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`should be excluded under FRE 901.
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`In addition, whatever portions4 of Ex. 2047 RC relies on are offered to prove
`
`the truth of each matter asserted. On page 17 of its POR, RC cites Ex. 2047 to
`
`support its assertion that its system was the first in the industry. See also Ex. 1134
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`at 151:5-24. Similarly, on pages 26-27 of its POR, RC cites Ex. 2047 to support its
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`assertion that “the market for this technology … has overtaken competing
`
`fracturing methods” in one formation and grown in other formations. See also Ex.
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`1134 at 143:1-144:21 and 148:16-151:4. However, RC has not shown that any
`
`hearsay exception applies, and has not presented the testimony of anyone with
`
`first-hand knowledge of the information from Ex. 2047 on which it relies.
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`Therefore, Ex. 2047 (and, more specifically, whatever information from Ex. 2047
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`RC (through its POR or its expert’s declarations) relies on) should be excluded
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`under FRE 801(c) and 802.
`
`
`3 The exhibit discussed during this deposition – Ex. 2021 of IPR2016-00598 – is
`
`identical to Ex. 2047. Likewise, the declaration referenced by Mr. McGowen
`
`during this deposition (Ex. 2034) is identical to Ex. 2050.
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`4 RC does not provide pin cites in its POR, though its expert asserted that pages
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`2/14 and 10/14 were the source of his testimony. See Ex. 1134 at 142:7-151:24.
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`Finally, RC has not shown in its POR that any system or technology (or use
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`of same) from Ex. 2047 on which it relies is covered by any Challenged Claim.
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`See also Ex. 1134 at 146:4-149:14. Therefore, Ex. 2047 (and, more specifically,
`
`whatever information from Ex. 2047 RC (through its POR or its expert’s
`
`declarations) relies on) is irrelevant under FRE 401 and inadmissible under FRE
`
`402. Exhibit 2047 should also be excluded under FRE 403 because allowing RC to
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`rely on Ex. 2047, despite RC not showing that the relied-on aspects are covered by
`
`a Challenged Claim, would be unfairly prejudicial to Petitioners.
`
`Exs. 2050 and 2051 (unredacted and redacted McGowen Declarations)
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`Objections: Hearsay as to (i) each sliding sleeve, packer, and fluid conveyed
`
`sealing device name and number referenced in the claim charts of Exhibit B (to
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`Exs. 2050/2051) that supports RC’s contentions about claims 24 and 27: EX
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`Sleeve, H80915, H80916, H80987, H80990, EX-C, H80940, H80949, EXPress,
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`H80908, H81006, H81008, H81045, H81070, OH MP, H81027, and H81029 for
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`sliding sleeves; OH Packers, H40936, RE Packers, H30187, H30192, and H30407
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`for packers; and “Balls,” H81020, H81021, and H81022 for fluid conveyed
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`sealing devices; and (ii) each of BH00001776, BH00125568, BH00188257,
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`BH00125568, BH00188257, BH00001986, and BH00000949 – FRE 801(c), 802;
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`Lack of Foundation as to (i) each sliding sleeve, packer, and fluid conveyed
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`sealing device name and number referenced in the claim charts of Exhibit B (to
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`Exs. 2050/2051) that supports RC’s contentions about claims 24 and 27: EX
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`Sleeve, H80915, H80916, H80987, H80990, EX-C, H80940, H80949, EXPress,
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`H80908, H81006, H81008, H81045, H81070, OH MP, H81027, and H81029 for
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`sliding sleeves; OH Packers, H40936, RE Packers, H30187, H30192, and H30407
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`for packers; and “Balls,” H81020, H81021, and H81022 for fluid conveyed
`
`sealing devices; and (ii) each of BH00001776, BH00125568, BH00188257,
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`BH00125568, BH00188257, BH00001986, and BH00000949 – 37 C.F.R. § 42.65;
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`and Relevance as to detailed opinions set forth in Sections 6, 7.2, 7.5, 7.6, 9.1, 9.2,
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`9.3, 10, 11.2, 11.4, 11.6, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 14.1, 14.2, 14.3, 14.4,
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`and 14.5 of Exs. 2050/2051 and Exhibits A and B of Exs. 2050/2051 – FRE 401
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`and 402.
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`Location of prior objections: Paper 57 at 7-13.
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`Locations exhibit is relied upon by RC: for Hearsay: to the extent considered,
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`Ex. 2050 (McGowen, unredacted) and Ex. 2051 (McGowen, redacted) at pages
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`2/15, 3/15, 4/15, and 6/15 of Ex. B (discussing ’774 patent claim 1, which is a
`
`predicate for RC’s mapping of ’505 patent claim 24), and pages 9-12/15 of Ex. B
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`(discussing ’505 patent claims 24 and 27); for Lack of Foundation: to the extent
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`considered, Ex. 2050 (McGowen, unredacted) and Ex. 2051 (McGowen, redacted)
`
`at pages 2/15, 3/15, 4/15, and 6/15 of Ex. B (discussing ’774 patent claim 1, which
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`is a predicate for RC’s mapping of ’505 patent claim 24), and pages 9-12/15 of Ex.
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`B (discussing ’505 patent claims 24 and 27); and for Relevance: POR at 10-11
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`(citing Ex. 2050 at 40-41 (Section 14.3)), POR at 13 (citing Ex. 2050 at 7 (Section
`
`6) and Ex. B), POR at 21 (citing Ex. 2050 at 43 (Section 14.5) and Exs. A, B), and
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`POR at 26 (citing Ex. 2050 at 42 (Section 14.4)).
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`Explanation: The sliding sleeve, packer, and fluid conveyed sealing device
`
`names/numbers and “BH” documents identified above are hearsay because RC
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`relies on them for the truth of the matters asserted – namely, that they establish that
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`Petitioners’ products meet certain claim limitations. However, RC has not shown
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`that any hearsay exception applies, and did not submit as exhibits any documents
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`corresponding to the names/numbers or “BH” document on which they (and/or Mr.
`
`McGowen) relied. Therefore, such portions of Exs. 2050/2051 should be excluded
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`under FRE 801(c) and 802.
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`RC also did not meet the requirement of 37 C.F.R. § 42.65 to disclose the
`
`underlying facts or data on which the opinion is based by failing to submit as
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`exhibits any documents corresponding to the names/numbers or “BH” document
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`on which they (and/or Mr. McGowen) relied. Therefore, such portions of Exs.
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`2050/2051 should be excluded under 37 C.F.R. § 42.65.
`
`Finally, the above-cited Sections of Exs. 2050/2051 are irrelevant because
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`they are directed to the invention of the ’774 Patent, which claims fracturing (see
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`claim elements 1a and 1f on pages 1/14 and 7/14 of Exhibit B of Exs. 2050/2051),
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`rather than the invention of the ’505 Patent, which does not claim fracturing (see
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`claims 24 and 27 of Ex. 1001; Ex. 1134 at 20:11-21:11) or even a particular fluid
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`pressure level (Ex. 1134 at 21:12-14). Mr. McGowen includes footnote 8 on page
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`47 of Exs. 2050/2051, which recites: “To the extent Petitioners rely on the same
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`theories and opinions with regard to ‘505 claims 2[4] and 27 . . ., my criticisms of
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`those theories are applicable in that context as well.” However, RC does not cite
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`this footnote or even this page of Mr. McGowen’s declaration in its POR.
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`Moreover, Mr. McGowen not explain what he means by “criticisms” or how his
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`opinions in the above-cited Sections—which are focused on fracturing—“are
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`applicable” to contentions and opinions by Petitioners directed to claims that do
`
`not require fracturing. Therefore, the above-cited Sections of Exs. 2050/2051
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`should be excluded under FRE 401 and 402.
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`Ex. 2052 (Baker Hughes Design Documents)
`
`Objection: Relevance – FRE 401 and 402.
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`Location of prior objection: Paper 57 at 13-14.
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`Locations exhibit is relied upon by RC: POR at 18-20; and, to the extent
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`considered, Exs. 2081/2084 at section 11.2 on pages 24-26.
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`Explanation: RC has not shown that anything in Ex. 2052 makes it more probable
`
`that Petitioners copied the claimed technology. RC relies on only two pages of this
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`exhibit (BH00363833 and BH00363820) to assert that Petitioners obtained “a
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`confidential Packers Plus document while [Petitioners] were designing their own
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`competing system” (POR at 18-19 (emphasis added)) and “actually developed their
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`own system by copying Packers Plus” (POR at 21). But RC offers no evidence of
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`when Petitioners were in possession of BH00363820 or when Petitioners were
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`“designing their own competing system.” Moreover, neither Petitioners’ FracPoint
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`system on which RC relies or Packers Plus’s StackFRAC system allegedly shown
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`in Exs. 2052 and 2053 is more similar to the system recited in any of the
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`challenged method claims than is the Lane Wells-Ellsworth prior art system. See
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`Petition (Paper 1 in IPR2016-01496) at 30-57 (addressing claims 1-7, 11, and
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`14-27); compare Exs. 2050/2051 claim 24 and 27 charts for StackFRAC and
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`FracPoint systems; see also Ex. 1132 at 121:11-124:1 (agreeing that the Lane
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`Wells-Ellsworth system meets structural limitations of ’505 Patent claims).
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`Therefore, Ex. 2052 should be excluded under FRE 401 and 402.
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`Ex. 2053 (Packers Plus Design Document)
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`Objections: Authentication – FRE 901(a); Relevance – FRE 401 and 402.
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`Location of prior objections: Paper 57 at 14-15.
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`Locations exhibit is relied upon by RC: POR at 20.
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`Explanation: RC has not proven authenticity. RC filed a declaration by its
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`paralegal (Ex. 2082 at ¶¶ 1, 2), purporting to authenticate Ex. 2053 (Ex. 2082 at
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`¶ 13), but failed to establish a foundation that would enable Mr. Delaney to
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`competently testify about the exhibit’s authenticity. Therefore, Ex. 2053 should be
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`excluded under FRE 901.
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`Furthermore, RC has not shown that anything in Ex. 2053 makes it more
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`probable that Petitioners copied the claimed technology. RC compares Ex. 2053 to
`
`page BH00363820 of Ex. 2052 to support its assertions that Petitioners obtained “a
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`confidential Packers Plus document while [Petitioners] were designing their own
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`competing system” (POR at 18-19 (emphasis added)) and “actually developed their
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`own system by copying Packers Plus” (POR at 21). But RC offers no evidence of
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`when Petitioners were in possession of BH00363820, or of when Petitioners were
`
`“designing their own competing system.” Moreover, neither Petitioners’ FracPoint
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`system on which RC relies or Packers Plus’s StackFRAC system allegedly shown
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`in Exs. 2052 and 2053 is more similar to the system recited in any of the
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`challenged method claims than is the Lane Wells-Ellsworth prior art system. See
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`Petition (Paper 1 in IPR2016-01496) at 30-57 (addressing claims 1-7, 11, and
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`14-27); compare Exs. 2050/2051 claim 24 and 27 charts for StackFRAC and
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`FracPoint systems; see also Ex. 1132 at 121:11-124:1 (agreeing that the Lane
`
`Wells-Ellsworth system meets structural limitations of ’505 Patent claims).
`
`Therefore, Ex. 2053 should be excluded under FRE 401 and 402.
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`Ex. 2054 (Article Regarding Schlumberger)
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`Objections: (1) Authentication as to entire document – FRE 901(a); (2) Hearsay
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`as to: (i) the portion(s) of the document on which RC relies to establish that “the
`
`largest oil and gas service company in the world—Schlumberger—opted to work
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`with Packers Plus to provide this technology” (POR at 17); and (ii) the portion(s)
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`of the document on which RC relies to establish that Schlumberger “desire[d] to
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`obtain rights to the technology” (id. at 17-18) – FRE 801(c), 802.
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`Location of prior objections: Paper 57 at 15-16.
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`Locations exhibit is relied upon by RC: POR at 17-18; and, to the extent
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`considered, Exs. 2050/2051 at section 14.7 on page 46.
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`Explanation: RC has not proven authenticity. RC filed a declaration by its
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`paralegal (Ex. 2082 at ¶¶ 1, 2), purporting to authenticate Ex. 2054 (Ex. 2082 at
`
`¶ 14), but failed to establish a foundation that would enable Mr. Delaney to
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`competently testify about the exhibit’s authenticity. Therefore, Ex. 2054 should be
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`excluded under FRE 901.
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`In addition, the portion(s) of the document on which RC relies to establish
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`that “the largest oil and gas service company in the world—Schlumberger—opted
`
`to work with Packers Plus to provide this technology” (POR at 17) are hearsay
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`because they are offered for the truth of the matter asserted – namely, that
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`Schlumberger opted to work with Packers Plus to provide the Packers Plus
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`technology that RC contends is relevant to industry praise. Similarly, the
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`portion(s) of the document on which RC relies to establish that Schlumberger
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`“desire[d] to obtain rights to the technology” (id. at 17-18) are also hearsay
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`because they are offered for the truth of the matter asserted – namely, that
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`Schlumberger desired to obtain rights to the technology, which RC asserts supports
`
`its industry praise argument. However, RC has not shown that any hearsay
`
`exception applies, and has not presented the testimony of anyone with first-hand
`
`knowledge of any agreement between Schlumberger and Packers Plus or of any
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`Schlumberger “desire” relating to any such agreement. Therefore, such portion(s)
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`of Ex. 2054 should be excluded under FRE 801(c) and 802.
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`Exs. 2081 and 2084 (unredacted and redacted McGowen Supp. Declarations)
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`Objections: Relevance as to opinions set forth in Sections 8.1-8.3 and 10
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`(directed claims that require fracturing), Section 9 on pages 11-19/29 (discussing
`
`invalidity theories proposed by a third party in different proceeding), in subsection
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`11.1 on page 22/29 (discussing Weatherford’s ZoneSelect system), and in
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`subsection 11.2 at 22:23-24:7 of pages 22-24/29 (discussing success of Baker
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`Hughes FracPoint system) of Exs. 2081/2084, and in pages 33-51/51 of Exs.
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`2081/2084– FRE 401 and 402. Lack of Foundation as to opinions set forth in
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`pages 33-51/51 of Exs. 2081/2084 – 37 C.F.R. § 42.65.
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`Location of prior objections: Paper 57 at 29-37.
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`Locations exhibit is relied upon by RC: POR at 26 (referencing only “§ 11” of
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`Ex. 2081), POR at 42 (citing Ex. 2081 at Section 8.1).
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`Explanation: The above-cited Sections of Ex. 2081 are irrelevant because they
`
`are directed to the invention of the ’774 Patent, which claims fracturing (see claim
`
`elements 1a and 1f on pages 1/14 and 7/14 of Exhibit B of Exs. 2050/2051), rather
`
`than the invention of the ’505 Patent, which does not claim fracturing (see claims
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`24 and 27 of Ex. 1001; Ex. 1134 at 20:11-21:11) or even a particular fluid pressure
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`level (Ex. 1134 at 21:12-14). Mr. McGowen includes footnote 1 on page 3 of Exs.
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`2081/2084, which recites: “To the extent Petitioners assert that the same art
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`directed to the ’774 patent also renders obvious the open hole claims of the ’505 . .
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`. patent because they would motivate a POSITA to perform open hole multi-stage
`
`fracturing, my opinions expressed herein apply to those claims as well.” However,
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`RC does not cite this footnote or even this page of Mr. McGowen’s supplemental
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`declaration in its POR. Moreover, Mr. McGowen not explain how his opinions in
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`the above-cited Sections—which are
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`focused on
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`fracturing—“apply”
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`to
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`contentions and opinions by Petitioners directed to claims that do not require
`
`fracturing. The opinions set forth in Section 9 are also irrelevant to this proceeding
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`because they address invalidity theories presented by a party that is not a party to
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`this proceeding. They are therefore inadmissible under FRE 401 and 402. The
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`above-described opinions set forth in subsections 11.1 and 11.2 and pages 33-
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`51/51 of Exs. 2081/2084 are also irrelevant under FRE 401 and 402 because they
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`address only two systems (Weatherford’s ZoneSelect and Petitioners FracPoint
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`systems) that Mr. McGowen did not show were used in the performance of the
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`challenged method claims. See Ex. 1132/1133 at 124:2-17 (ZoneSelect) and
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`124:18-128:15 (FracPoint). Mr. McGowen’s purported mapping of claim 1 of the
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`Challenged Claims to the ZoneSelect system (Exs. 2081/2084 at 33-51/51)
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`provides no evidence of any actual use of that system (as required by each
`
`Challenged Claim) nor attempts to tie the single image cropped from Ex. 2039
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`therein to any of his market share allegations at 22:16-22 (on page 22/29 of Exs.
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`2081/2084). See Ex. 1132/1133 at 124:2-17. RC also did not disclose the
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`underlying facts or data on which the above-described opinions set forth in pages
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`33-51/51 of Exs. 2081/2084 are based because it did not submit as exhibits any
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`documents corresponding to any of the Weatherford components specified.
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`Therefore, such opinions should be excluded under 37 C.F.R. § 42.65.
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`Ex. 2082 (Delaney Declaration)
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`Objections: Relevance – FRE 401, 402, and 403; Foundation – FRE 601.
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`Location of prior objections: Paper 57 at 37.
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`Locations exhibit is relied upon by RC: None.
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`Explanation: RC does not rely on Ex. 2082 in its POR or in any expert
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`declaration submitted with its POR. Ex. 2082 should therefore be excluded as
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`irrelevant under FRE 401 and 402 and otherwise unfairly prejudicial under FRE
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`403. Moreover, Ex. 2082 is a declaration from a paralegal for counsel for RC (Ex.
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`2082 at ¶¶ 1, 2) purporting that 37 different third-party documents upon which RC
`
`relies are “true and correct copies” of what Mr. Delaney described them to be. Ex.
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`2082 at ¶¶ 3-39. However, RC has not provided any evidence (such as within Ex.
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`2082 itself) that demonstrates the bases for Mr. Delaney’s contentions that Exs.
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`2047, 2053, and 2054 are true and correct copies of what he describes them to be,
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`including whether and how Mr. Delaney has personal knowledge that Ex. 2047
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`“was produced by Baker Hughes in the litigation” (2082 at ¶ 11), that Ex. 2053 is a
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`“Packers Plus Design Document” (2082 at ¶ 13), and that Ex. 2054 was “accessed
`
`from the URL identified in the exhibit on the date noted on the exhibit” (2082 at ¶
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`14). Ex. 2082, and at least the paragraphs 11, 13, and 14 thereof, should therefore
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`also be excluded under FRE 601.
`
`Exs. 2074 (Yuan), 2078 (Abass), 2079 (Damgaard), 2098 (Austin), and 2099
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`(Owens)
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`Objections: Hearsay – FRE 801(c), 802.
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`Location of prior objections: Paper 57 at 26-29 and 41-42.
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`Locations exhibit is relied upon by RC: POR at 7-8 (citing Ex. 2078 at 2, Ex.
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`2079, Ex. 2098 at 1, 2099 at 2), 25 and 28-29 (citing Ex. 2074); and, to the extent
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`considered, Ex. 2081/2084 at 20:8-21:3, 21:4-22:2, and 29:2-9.
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`Explanation: The portions of these exhibits cited above in the POR are offered to
`
`prove the truth of each matter asserted. On pages 25 and 28-29 of its POR, RC
`
`cites to Ex. 2074 to support its assertion that Weatherford’s ZoneSelect system
`
`accounts for twelve percent of its fracture system sales. On pages 7-8 of its POR,
`
`RC cited to Exs. 2078, 2079, 2098 and 2099 to support its assertions that pre-
`
`invention wisdom was, in fact, that effective fracturing required cementing casing.
`
`However, RC has not shown that any hearsay exception applies, and has not
`
`presented the testimony of anyone with first-hand knowledge of the information
`
`from Exs. 2074, 2078, 2079, 2098, and 2099 on which it relies. Therefore, these
`
`exhibits should be excluded under FRE 801(c) and 802.
`
`Exs. 2092 (Rao 2007), 2093 (Rao 2005), and 2100 (Murray)
`
`Objections: Relevance – FRE 401, 402, and 403.
`
`Location of prior objections: Paper 57 at 39-40, 42-43.
`
`Locations exhibit is relied upon by RC: None.
`
`Explanation: Exs. 2092, 2093, and 2100 are not cited in the POR and is therefore
`
`inadmissible and should be excluded as irrelevant under FRE 401 and 402 and/or
`
`as unfairly prejudicial (given its absence from the POR) under FRE 403.
`
`September 28, 2017
`
`/Mark T. Garrett/
`Mark T. Garrett
`
`
`28743210.1
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`15
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`
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`
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on September
`
`28, 2017, a complete copy of PETITIONERS’ MOTION TO EXCLUDE was
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`served on Patent Owner’s Exclusive Licensee via email (by consent), as follows:
`
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`gonsalves@gonsalveslawfirm.com
`rapid@caldwellcc.com
`
`
`
`/Mark T. Garrett/
`Mark T. Garrett(Reg. No. 44,699)
`
`
`
`28743210.1
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`
`
`
`
`
`
`
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