UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`WEATHERFORD INTERNATIONAL, LLC; WEATHERFORD/LAMB,
`INC.; WEATHERFORD US, LP; and WEATHERFORD ARTIFICIAL
`LIFT SYSTEMS, LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01509
`Patent 7,861,774
`___________________
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`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`RESPONSE TO PETITIONERS’ MOTION TO EXCLUDE
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`WEATHERFORD INTERNATIONAL, LLC; WEATHERFORD/LAMB,
`INC.; WEATHERFORD US, LP; and WEATHERFORD ARTIFICIAL
`LIFT SYSTEMS, LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01509
`Patent 7,861,774
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`RESPONSE TO PETITIONERS’ MOTION TO EXCLUDE
`
`
`
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`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`“The party moving to exclude evidence bears the burden of proving that it is
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`entitled to the relief requested—namely, that the material sought to be excluded is
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`inadmissible under the Federal Rules of Evidence.” Petroleum Geo-Services Inc.
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`v. Ion Geophysical Corp., IPR2014-00688, Paper 101 at 53 (PTAB Dec. 15, 2015)
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`(citing 37 C.F.R. §§ 42.20(c), 42.62(a)). Petitioners’ motion appears to disregard
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`this requirement as it seeks exclusion of dozens of exhibits by merely referring to a
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`portion of the exhibit and stating a rule of evidence. Moreover, with regard to
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`several objections, including to the testimony from Mr. McGowen, Dr. Daneshy,
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`and representatives of Baker Hughes and Packers Plus, Petitioners fail to recognize
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`the applicable procedures and evidentiary rules for submitting this type of evidence
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`in IPRs. In short, Weatherford has failed to meet its burden, and its arguments
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`relate at most to weight not admissibility.
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`Objections to McGowen Testimony
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`Petitioners sole basis for objecting to Mr. McGowen’s testimony is that it is
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`based on undisclosed information controlled by Baker Hughes. This objection is
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`untimely as it was raised for the first time well after Rapid Completions served
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`exhibits 2051 and 2081. See Paper 40. Regardless, unlike in district court, this
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`objection goes only to weight not admissibility. Moreover, even if Weatherford
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`had raised a timely, legally cognizable objection, the only portion of Mr.
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`McGowen’s testimony that is actually based on confidential Baker Hughes
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`1
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`
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`information is a specific calculation of Baker Hughes’ revenue from sales of its
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`FracPoint service. This calculation is redacted in Exhibit 2051 and it is not even
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`included in Exhibit 2081. Thus, Petitioners’ objection is moot.
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`Factual Background
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`In response to Baker Hughes’ first set of IPRs, Mr. McGowen compiled a
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`database of FracPoint jobs performed by Baker Hughes in the United States. He
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`used that database to estimate the amount of revenue that Baker Hughes had earned
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`from practicing the claimed invention during the limited damages window at issue
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`in litigation. This database contained confidential information produced by Baker
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`Hughes in the parties’ underlying litigation. Ex. 2051 at 46. Baker Hughes
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`consented to use of the information in its IPRs, but it did not authorize Rapid
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`Completions to share that information with Weatherford. Ex. 2081 at 25. Thus,
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`Rapid Completions redacted that calculation when it filed the McGowen
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`declaration in the present proceeding. The remainder of the declaration is based on
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`publicly available information to which Weatherford has not objected.
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`
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`Because commercial success is relevant to the present proceeding, and Baker
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`Hughes has refused to allow Rapid Completions to share its confidential
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`information with Weatherford, Mr. McGowen prepared a separate revenue
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`calculation for this proceeding—he estimated Baker Hughes’ revenue based only
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`on publicly available information. Ex. 2081 at 27. Respondent relied on that
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`2
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`
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`testimony in this proceeding to provide the Board with the relevant information
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`regarding commercial success without the need for motion practice before the
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`Board or before the district court to seek relief from the protective order. As it
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`turned out though, after Rapid Completions served its patent owner response,
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`Weatherford did not object to Mr. McGowen’s public revenue calculation in
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`exhibit 2081, or the fact that his confidential calculation was redacted from exhibit
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`2051. Paper 34. Thus, the issue appeared to be moot.
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`
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`Over a month later, during the deposition of Mr. McGowen, Weatherford
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`asked Mr. McGowen about facts he was aware of. He answered truthfully that he
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`was also aware of confidential Baker Hughes data. Ex. 1038 at 161:15-163:25. Of
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`course, it is not as if Weatherford learned that Mr. McGowen had access to this
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`information for the first time in his deposition. Exhibit 2051 contains a redaction
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`for this very reason, and exhibit 2081 states: “In my original declaration, I also
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`analyzed the success of Baker Hughes’s FracPoint system. Because this analysis
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`was based in part on confidential Baker Hughes information, I understand that
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`Baker Hughes has objected to sharing that information with Weatherford.
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`Nonetheless, public information provides a good indication of the success of Baker
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`Hughes’s system.” Ex. 2081 at 25.
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`Even if Weatherford had learned of this issue for the first time in the
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`deposition, it expressly chose not to raise an objection during the deposition as
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`3
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`
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`required by 37 CFR 42.64(a) (“An objection to the admissibility of deposition
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`evidence must be made during the deposition.”).1 See Ex. 1038 at 164:1-3
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`(Weatherford counsel: “Okay. So, I mean, we can take this up later, but here an
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`expert is relying on information that we can't cross-examine him on.”). Even after
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`the deposition ended, Weatherford provided no indication that it intended to raise
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`an objection on this basis until the day after it served its reply—months after it was
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`served with Mr. McGowen’s declaration, and weeks after it took his deposition.
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`This is too late. Cf. 37 CFR 42.64(b) (“Once a trial has been instituted, any
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`objection must be filed within five business days of service of evidence to which
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`the objection is directed.”).
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`Once Weatherford finally did provide an objection, Rapid Completions
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`emailed litigation and IPR counsel for Baker Hughes and Weatherford to remind
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`them that the litigation protective order states:
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`DESIGNATED MATERIAL produced by one defendant shall not be
`disclosed to counsel for any other defendant without written consent of
`the producing party. Defendants will not object to the admission of
`evidence based on the grounds that Plaintiffs could not share the
`documents with a Defendant or Defendants’ witness, although all other
`objections to admissibility and/or relevance are reserved. Nothing in
`this section shall relieve Plaintiff from timely disclosing and/or
`producing evidence on which they intend to rely. The Defendants will
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`1 37 CFR 42.64(a) is not strictly applicable because Weatherford is only
`objecting to Mr. McGowen’s declaration. Weatherford submitted Mr. McGowen’s
`deposition testimony into evidence without objection.
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`4
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`
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`work together to obtain access to evidence from other Defendants
`that may be identified by Rapid Completions.”
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`Case 6:15-cv-724, Dkt. 248 at ¶ 6 (emphasis added). While this provision is not
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`directly applicable in an IPR, the fact that a mechanism exists for resolving
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`precisely this sort of dispute shows that, while Rapid Completions cannot provide
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`confidential Baker Hughes information to Weatherford, Weatherford need only ask
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`for the information if it really needed it. Weatherford responded that it would not
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`attempt to obtain the information because it had already been prejudiced by served
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`its reply without the information. Of course, Weatherford manufactured that
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`prejudice by withholding its objection until after it served its reply—when it could
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`claim that any attempt to cure the alleged prejudice is futile.
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`Argument
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`According to Weatherford, it was unable to adequately cross examine Mr.
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`McGowen because Rapid Completions failed to produce confidential Baker
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`Hughes information. This is wrong. Weatherford knew that Mr. McGowen had
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`access to that information well before his deposition, and it also knew that his more
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`recent declaration (Ex. 2081) did not rely on that information. Weatherford
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`decided to lay behind the log and only disclose its objection to that fact after the
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`objection deadline and after Mr. McGowen’s deposition. Had it raised this
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`objection earlier, the parties could have presented this dispute to the Board or the
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`district court for resolution, or Weatherford could have simply obtained the
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`5
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`
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`information from Baker Hughes—something that it could do but Rapid
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`Completions could not. Its decision to withhold its objection until after it could
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`claim to have been prejudiced by a lack of adequate cross examination is pure
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`gamesmanship. Accordingly, it should be overruled as untimely.
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`In addition, even if its objection were timely, Weatherford has failed to
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`provide a legally cognizable theory for exclusion of evidence. Its objection is
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`based on Trial Practice Guide § II(A)(4). But this provision states: “Opinions
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`expressed without disclosing the underlying facts or data may be given little or no
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`weight.” See also 37 C.F.R. § 42.65(a) (same). Unlike in district court, these
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`provisions confirm that, in an IPR, an expert’s failure to disclose underlying facts
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`or data is an issue of weight not admissibility. Corning Inc. v. DSM IP Assets BV,
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`IPR2013-0048, Paper 94 at 74 (PTAB May 9, 2014) (“Whether a witness’s
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`testimony fails to include underlying facts or data on which an opinion is based
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`goes to the weight that should be accorded the testimony, and not its
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`admissibility.”). Thus, even if Rapid Completions were required to violate a
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`district court protective order by producing confidential information from Baker
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`Hughes to its joint defense partner Weatherford, the fact that it abided by the
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`protective order would go to the weight afforded Mr. McGowen’s testimony, not
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`
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`6
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`
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`its admissibility.2 If Weatherford is entitled to any relief, it is an order from the
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`Board compelling Baker Hughes to produce its sales information to Weatherford’s
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`outside counsel.
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`
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`Of course, such an order is not necessary because Rapid Completions
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`specifically developed evidence to avoid a protective order dispute. Contrary to
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`Weatherford’s assertion that “[Mr.] McGowen offered no evidence in response to
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`questions about the bases for his commercial success opinions,” Mot. at 6, Exhibits
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`2051 (e.g., pages 41-50) and 2081 (e.g., pages 25-30) contain substantial evidence
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`of commercial success without disclosing confidential Baker Hughes information.
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`Indeed, objected to section 11.2 of exhibit 2081 begins: “In my original
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`declaration, I also analyzed the success of Baker Hughes’s FracPoint system.
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`Because this analysis was based in part on confidential Baker Hughes information,
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`I understand that Baker Hughes has objected to sharing that information with
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`Weatherford. Nonetheless, public information provides a good indication of the
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`success of Baker Hughes’s system.” The Board may admit these exhibits without
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`admitting Mr. McGowen’s confidential revenue calculation because it is already
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`2 The fact that Weatherford did not have Mr. McGowen’s confidential
`revenue calculation before his deposition should not cause the Board to discount
`the weight afforded his testimony because Weatherford’s own gamesmanship is
`responsible for any prejudice it suffered. Moreover, Mr. McGowen provided his
`public calculation to avoid any such prejudice or discounting of his opinions.
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`
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`7
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`
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`redacted from exhibit 2051. Thus, this objection is also moot.
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`Authenticity, Relevance, and Timeliness Objections
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`Petitioners object to exhibits 2004-2010, 2012, and 2020 as inauthentic
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`because they were submitted with the preliminary response, but authentication
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`declarations for the exhibits (exhibits 2083 and 2091) were submitted with the
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`formal patent owner response. However, this is the proper procedure for
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`submitting this type of evidence. See Nuvasive, Inc. v. Warsaw Orthopedic, Inc.,
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`IPR2013-00206, Paper 22 at 3 (PTAB Oct. 15, 2013) (ruling that a patent owner
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`served with an objection to preliminary response evidence need not provide new
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`evidence to rebut the objection until the patent owner response deadline). Even if
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`Petitioners’ timeliness objection were technically accurate—which it is not—
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`Respondent would have good cause to submit exhibits 2083 and 2091 after the
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`alleged deadline. As explained in Nuvasive, a petitioner suffers no prejudice from
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`receiving new testimonial evidence with a patent owner response, and respondent
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`should not be faulted for following the procedure outlined in existing precedent.
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`Because Petitioners do not dispute that exhibits 2083 and 2091 authenticate these
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`exhibits, this objection fails.
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`
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`Exhibit 2014 is a portion of a book written by Ali Daneshy. He testified that
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`it is authentic. Ex. 2016 at 15:1-21. Moreover, all of exhibits 2004-2012, 2014
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`and 2020 are authentic under Rule 901(b)(4) and 902(6). The requirement of
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`8
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`
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`authenticity requires only that a proponent demonstrate that a document is what the
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`proponent claims it to be. Respondent merely asserts that these exhibits are
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`industry publications, and the distinctive markings of each document establish that
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`to be the case. See, e.g., Ciampi v. City of Palo Alto, 790 F. Supp. 2d 1077, 1091
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`(N.D. Cal. 2011) (admitting Internet printouts that “contain sufficient indicia of
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`authenticity, including distinctive newspaper and website designs, dates of
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`publication, page numbers, and web addresses”); Liberty Mutual Ins. Co. v.
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`Progressive Casualty Ins. Co., CBM2012-00010, Paper 59 at 37 (PTAB Feb. 24,
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`2014) (admitting various articles under Rule 902(6)). The exhibits are also
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`admissible under Rule 703 to the extent they have been relied upon by Mr.
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`McGowen. See Ex. 2051 at 48-50.
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`
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`Petitioners object to exhibits 2004-2012, 2014, 2020, 2045-2047, 2054,
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`2061, and 2086-2089 as irrelevant because they are insufficiently tied to the
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`claimed invention. In particular, Petitioners note that various of these exhibits fail
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`to “mention[] the long list of steps recited in claim 1 of the ’774 patent.” Mot. at 8.
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`But the fact that various industry publications and news footage fails to analyze
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`specific claim language does not mean that this evidence is irrelevant to the issue
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`of praise for the invention. Indeed, it is an artifact of the fact that Mr. Themig
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`invented something new to the industry. See Ex. 2013 (describing open hole multi-
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`stage fracturing as having been introduced in 2001, but not having “a unique
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`9
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`
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`industry accepted name”). These exhibits nonetheless describe the operation of
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`open hole multi-stage fracturing, which, as explained by Mr. McGowen, fits the
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`requirements of the claim language. See, e.g., Ex. 2051 at 47-50, 64-77
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`(explaining that StackFRAC and FracPoint “simply are the invention disclosed
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`and claimed in the invention”).
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`While Petitioners may disagree that these exhibits specifically praise the
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`invention covered by claim 1, they certainly meet the minimum threshold for
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`relevance under Rule 401. If an article praises StackFRAC without explaining
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`why it is praising StackFRAC, it may be entitled to less weight than, for example,
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`exhibit 2045 which states: “StackFRAC was the first ball drop system created for
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`open hole horizontal wells” that is “partly responsible for creating access to vast
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`reservoirs of oil and natural gas in North America that were previously considered
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`uneconomic to produce.” Nonetheless, all of these exhibits are at least probative of
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`praise for the invention.
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`Hearsay Objections
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`Ghiselin Study. Exhibit 2010 is a market report on market share of open
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`hole multistage systems versus plug and perf systems. Petitioners object to the
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`report as hearsay. However, this report falls under hearsay exceptions (17) and
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`(18). It is a market report relied upon by an expert in the field—Mr. McGowen.
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`At any rate, even if this market share information does not fall under those
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`10
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`
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`exceptions, the exhibit is still admissible for a purpose other than proving the truth
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`of the matter asserted. Namely, that persons in the field expected the patented
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`technology to have had a significant market share. Even if the actual market share
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`for this technology differed from the reported amount, the fact that practitioners
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`expected the technology to be increasingly competitive against traditional plug and
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`perf demonstrates that the technology has received praise and success.
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`Moreover, even if the Board deems this exhibit inadmissible for any reason,
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`it may still be considered under Rule 703. See, e.g., SK Innovation Co. v. Celgard
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`LLC, IPR2014-00680, Paper 57 at 28 (PTAB Sept. 25, 2015) (admitting evidence
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`of commercial success under Rule 703). Respondent’s expert Mr. McGowen
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`offered testimony based on this exhibit. See Ex. 2081 at 25; Ex. 2051 at 46.
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`Petitioners have not moved to exclude this testimony, and thus the substantive
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`information from the exhibit has already been admitted. Under Rule 703, the
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`evidence underlying that testimony is also admissible subject only to concerns
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`related to jury trials that are inapplicable in IPRs.3
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`3 In district court, Rule 703, requires a proponent to show that any otherwise
`inadmissible evidence underlying an expert’s testimony has “probative value in
`helping the jury evaluate the opinion [that] substantially outweighs [its] prejudicial
`effect.” This provision is inapplicable in IPRs. 37 C.F.R. § 42.62(b) (portions of
`the Federal Rules of Evidence relating to juries do not apply). Regardless, this
`exhibit is probative of commercial success as it corroborates the testimony of Mr.
`McGowen and the other evidence relied upon by Mr. McGowen. Petitioners
`identify no prejudicial effect from admitting it, and it is difficult to imagine how
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`11
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`
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`Industry Publications. Exhibits 2013, 2015, 2017, 2045, 2047, and 2055
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`are various industry publications that provide evidence of the knowledge of a
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`person of skill in the art during the relevant time and provide objective evidence of
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`non-obviousness. Petitioners object to these exhibits as hearsay because specific
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`quotes from these articles indicate, for example, open hole multi-stage fracturing
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`was met with skepticism, Packers Plus is recognized as introducing this form of
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`fracturing, Packers Plus’s reported results with the technology were surprising, etc.
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`As an initial matter, these exhibits are offered as evidence of the state of mind or
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`knowledge of a hypothetical person of ordinary skill in the art in 2001. None of
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`the alleged hearsay statements purport to describe such a hypothetical person.
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`Thus, Respondent is not relying on those statements for the truth of the matter.
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`Stated differently, the fact that industry publications made these statements
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`at all is admissible. Liberty Mutual Ins. Co., CBM2012-00010, Paper 59 at 37
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`(overruling hearsay objection to industry publications because “[w]e have
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`considered the statements therein not for the truth of the matter asserted, but for the
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`fact that such statements were made at all.”); EMC Corp. v. Personal Web
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`this type of market report could be prejudicial at all, especially since it is being
`presented to the Board rather than a jury. See SK Innovation Co., IPR2014-00680,
`Paper 57 at 28. Indeed, Petitioners do not even raise a Rule 403 objection, which
`sets a much lower bar for establishing prejudicial effect. For all of these reasons,
`this exhibit is admissible under Rule 807 as well.
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`
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`12
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`
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`Technologies, LLC, IPR2013-00085, Paper 73 at 66 (PTAB May 15, 2014); see
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`also Fed. R. Evid. 801(c) 1997 Adv. Comm. Note (“If the significance of an
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`offered statement lies solely in the fact that it was made, no issue is raised as to the
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`truth of anything asserted, and the statement is not hearsay.”). Indeed, the
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`evidence of industry skepticism is not merely that Mr. Casero said that the
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`technology was met with skepticism (Ex. 2013), but rather, the fact that his article
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`provides technical comparisons between plug and perf and open hole multi-stage
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`fracturing is itself evidence of industry skepticism. Similarly, the fact that Packers
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`Plus felt it necessary to justify the viability of the patented technology is evidence
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`of skepticism and surprising results regardless of whether its articles actually use
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`the phrases “skepticism” or “surprising” (Exs. 2015, 2017). And the fact that Mr.
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`Britt treated Packers Plus’s StackFRAC system and Baker Hughes’s FracPoint
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`system as similar in an industry publication is evidence of similarity (Ex. 2055).
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`As to all of these exhibits, it is relevant that the cited statements were made at all.
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`Moreover, as explained above with regard to the Ghiselin Study, even if the
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`Board deems this exhibit inadmissible for any reason, they may still be considered
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`under Rule 703. Mr. McGowen offered testimony based on these exhibits that has
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`already been admitted. See Ex. 2081 at 25; Ex. 2051 at 46.
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`Deposition and Trial Testimony. Petitioners object to the testimony of Ali
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`Daneshy (Exs. 2016 and 2085) and a Baker Hughes corporate representative (Ex.
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`13
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`
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`2097) as hearsay. However, prior deposition and trial testimony is not considered
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`hearsay in IPRs. Petroleum Geo-Services Inc. v. WesternGeco LLC, IPR2014-
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`01475, Paper 71 at 61 (PTAB July 11, 2016) (ruling prior deposition and trial
`
`testimony admissible for IPR purposes). In an inter partes review, direct testimony
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`is typically provided via affidavit, with cross examination taken via deposition. 37
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`C.F.R. § 42.53(a). In this respect, testimony via affidavit is considered in court
`
`testimony before the Board, in contrast to affidavit testimony in district court cases
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`where it is considered out of court testimony. See Polaris Wireless, Inc. v.
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`TruePosition, Inc., Case IPR2013-00323, slip op. at 41 (PTAB Nov. 3, 2014)
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`(Paper 62). Testimony submitted via deposition or trial transcript is no different
`
`from testimony submitted in a written affidavit. Petroleum Geo-Services Inc.,
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`IPR2014-01475, Paper 71 at 61. Petitioners had an opportunity to cross examine
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`these witnesses by seeking to depose them in this proceeding. The fact that they
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`chose not to do so does not render their testimony inadmissible. Id.
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`Moreover, the testimony would be admissible as testimony from unavailable
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`witnesses given that the witnesses are located more than 100 miles from
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`Washington D.C. and because the Board typically does not allow live testimony.
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`Fed. R. Ev. 804(b)(1); Fed. R. Civ. Proc. 32(a)(4)(B),(E). This testimony is also
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`admissible under Rule 807. It is already admitted in the IPRs filed by
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`Weatherford’s joint defense partner. Thus, it is trustworthy and evidence of
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`14
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`
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`material facts. Moreover, given that these witnesses are incentivized to give
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`testimony favorable to Weatherford, the fact that they did no do so is more
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`probative than any other evidence Rapid Completions could reasonably obtain.
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`Finally, admitting these exhibits serves the interests of justice by preventing
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`inconsistent rulings on the same patents being challenged by joint defense partners.
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`Packers Plus and Baker Hughes Design Drawings and Videos. Exhibits
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`2018-2019 and 2052-2053, 2058-2059 are drawings, technical documents, and
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`videos that illustrate the operation of Baker Hughes’ FracPoint system and Packers
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`Plus’s StackFRAC system. The Packers Plus employees Tess McLeod and Ken
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`Paltzat testified to the accuracy of several of these documents or their status as
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`business records, thus, they are not hearsay. Ex. 2091, 2101. They are also
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`admissible for the non-hearsay purpose of showing similarities between the two
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`systems. For example, Rapid Completions need not rely on the truth of a statement
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`in these documents to show that Baker Hughes’ technical design documents
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`included a Packers Plus design drawing. For example, Weatherford identifies no
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`“statement” in the design drawings that is being asserted for the truth of the matter.
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`Rather, the Baker Hughes drawing is relevant because it is a modified Packers Plus
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`drawing that found in the possession of Baker Hughes. See, e.g., Ex. 2082 at ¶¶
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`12, 13. This evidence is also admissible under Rule 703 as Weatherford has not
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`objected to Mr. McGowen’s analysis. Ex. 2081 at 27-30; Ex. 2051 at 46, 64-93.
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`
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`15
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`
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`Dated: October 12, 2017
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`
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`
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`Respectfully submitted,
`
`Rapid Completions LLC
`
`By /Justin T. Nemunaitis/
`
`Hamad M. Hamad, Reg. No. 64,641
`Bradley W. Caldwell (pro hac vice)
`Justin T. Nemunaitis (pro hac vice)
`CALDWELL CASSADY CURRY,
`P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
`
`Dr. Gregory Gonsalves, Re. No.
`43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
`
`
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`The undersigned hereby certifies that the foregoing document was served
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`via electronic mail, as previously consented to by Petitioner upon the following
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`counsel of record:
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`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL,SHAPIRO & FINNAN,
`LLC
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
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`Date: October 12, 2017
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`/Hamad M. Hamad/
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`Hamad M. Hamad, Reg. No. 64,641
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`17
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