`
`Civil No. 0:20-cv-00358 ECT/HB
`
`
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`v.
`
`Tennant Company,
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 1 of 15
`
`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MINNESOTA
`
`
`
`Oxygenator Water Technologies, Inc.,
`
`
`
`
`AMENDED EXHIBIT A TO THE JOINT PATENT CASE STATUS
`REPORT AND CLAIM CONSTRUCTION STATEMENT
`
`Pursuant to the Pretrial Case Management Order (ECF No. 43, as modified by
`
`ECF No. 62), Plaintiff Oxygenator Water Technologies, Inc. (“OWT”) hereby provides
`
`Exhibit A to the Parties Joint Patent Case Status Report and Claim Construction
`
`Statement. In this exhibit, OWT identifies: (1) all references from the specification or
`
`prosecution history it intends to use to support its constructions; (2) any extrinsic
`
`evidence it intends to use to support its proposed construction or oppose the other party’s
`
`proposed construction; and (3) every witness, including experts, it proposes to call to
`
`offer testimony relating to claim construction; and for each expert, a summary of the
`
`opinion to be offered in sufficient detail to permit a meaningful deposition of that expert.
`
`In addition to the below identified extrinsic evidence, OWT may offer expert testimony
`
`concerning general principles of electrolysis and the design, structure, and operation of
`
`electrolysis equipment.
`
`
`
`1
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 2 of 15
`
`OWT makes these disclosures based on all of the disclosures Defendant Tennant
`
`Company (“Tennant”) has provided in this lawsuit to date, and in particular based on (1)
`
`Tennant’s Interrogatory Responses; (2) Tennant’s Claim Chart (including all
`
`supplemental charts); (3) Tennant’s Prior Art Chart and Invalidity Statement, and
`
`specifically the charts included with the Prior Art Chart and Invalidity Statement (see
`
`OWT’s Amended Reduction of Asserted Claims and Responsive Prior Art Chart and
`
`Invalidity Statement at 1-2); and (4) Tennant’s Amended Proposed Claim Terms for
`
`Construction and Extrinsic Evidence. OWT reserves the right to modify or supplement
`
`its proposed constructions in connection with any new positions or contentions provided
`
`by Tennant during the course of this litigation, based upon information acquired during
`
`discovery, in response to Tennant’s proposed constructions, as a result of the meet and
`
`confer process, or where good cause otherwise exists.
`
`OWT also reserves the right to propose constructions and identify responsive
`
`intrinsic and extrinsic evidence upon receiving more detail about Tennant’s proposed
`
`constructions and the arguments that support those constructions during claim
`
`construction briefing, in particular if those constructions and argument differ in any way
`
`from the ones identified by Tennant in its previous disclosures or during the meet and
`
`confer process. As one example, Tennant agreed not to request the Court find any claim
`
`terms indefinite during claim construction proceedings. (ECF No. 64 at 3 n. 1.) To the
`
`extent Tennant attempts to renege on that agreement, OWT will need to supplement these
`
`disclosures.
`
`
`
`2
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 3 of 15
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`Finally, to the extent Tennant takes any additional positions in any Inter Partes
`
`Review proceeding that are in any way inconsistent from the positions it advances during
`
`Claim Construction proceedings in this Court, OWT reserves the right to rely on those
`
`inconsistent positions.
`
`Date: June 9, 2021
`
`/s/Nathan D. Louwagie
`Philip P. Caspers (#0192569)
`J. Derek Vandenburgh (#0224145)
`Aaron W. Pederson (#0386953)
`Nathan D. Louwagie (#0397564)
`CARLSON, CASPERS, VANDENBURGH &
`LINDQUIST, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, MN 55402
`Phone: (612) 436-9600
`Facsimile: (612) 436-9605
`pcaspers@carlsoncaspers.com
`dvandenburgh@carlsoncaspers.com
`apederson@carlsoncaspers.com
`nlouwagie@carlsoncaspers.com
`
`Attorneys for Plaintiff Oxygenator Water
`Technologies, Inc.
`
`3
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 4 of 15
`
`Amended Exhibit A
`OWT’s Proposed Constructions and Evidence
`
`1. ‘415 Patent, Claims 13, 18, 19, 20, 21, 25, 29; ‘092 Patent, Claims 13, 27, 60; ‘665 Patent, Claims 13, 55: “water”
`
`OWT’s
`construction
`An aqueous
`medium that can
`support the
`electrolysis of
`water.
`
`Intrinsic Evidence
`
`Extrinsic Evidence1
`
`The intrinsic record for the patents-in-suit,
`including:
`
` The claims, including e.g., claim 13 of the
`’415 patent.
`
` The specification, including e.g.,
`Abstract, col. 12, ll. 20 through col. 2, ll.
`62; col. 3, ll. 20-27, 37-42; col. 4, ll. 9-26;
`col. 5, ll. 21-25; col. 6, ll. 26-31; col. 7, ll.
`20 through col. 10, ll. 17.
`
` The prosecution history, including e.g.,
`OWT0001960, OWT0001981-90,
`OWT0002008, OWT0002027-44,
`OWT0002159.
`
`Dr. Ralph White will testify as to the general
`knowledge in the art of the relationship between total
`dissolved solids, resistance, and conductivity in an
`aqueous medium and how these properties effect
`electrolysis. Dr. White will explain that it was well
`known that pure water has a very high resistance such
`that is would not conduct electricity well and
`therefore would not support electrolysis. Dr. White
`will testify as to how one skilled in the art would
`interpret the language of col. 4, ll. 22-26 of the
`specification within the context of the claims,
`specification, and prosecution history. Dr. White will
`testify that a POSA would understand col. 4, ll. 22-26
`of the specification to generally indicate that the
`aqueous medium that is used should support
`electrolysis of water. Dr. White will testify that a
`POSA would recognize that the value with units
`identified at col. 4, ll. 22-23 (“resistance less than one
`
`1 OWT relies on the disclosures Tennant made in its March 30, 2021 Amended Proposed Claim Terms for Construction and
`Extrinsic Evidence. To the extent Tennant relies on any extrinsic evidence not identified in the chart accompanying that
`disclosure, OWT reserves the right to introduce expert testimony from Dr. White responding to that extrinsic evidence.
`2 The specification for each of the patents-in-suit are the same. Pin cites to the specification are citations to the ’415 patent.
`1
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 5 of 15
`
`ohm per square centimeter”) contains an error. He
`will testify that the POSA would not understand col.
`4, ll. 22-26 to provide any sort of strict numerical
`boundary. Dr. White will discuss references that
`corroborate his understanding of the art. See e.g.
`Fundamentals of Electrochemistry (OWT001789503);
`An Experimental Study on the Effect of Electrolytic
`Concentration (OWT0017879); Investigation of
`electrical conductivity of different water liquids and
`electrolyte solutions (OWT0018617); Electrical
`Conductivity Protocol (ASP_OWT000001); Water
`Cell Functionality (ASP_OWT000012);
`TC00016871; TC00017832; TC00033231; Russ
`Pilkki email of 8/2/2012 (ASP_OWT000015);
`TC00075327; TC00045209; OWT0081879;
`OWT0081896.
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g. -
`602 petition at 29, 34-35, 45, 52 54-57, 60-61; Ex.
`1003 at ¶¶ 36-37, 70-71; -625 petition at 30, 33-34,
`62, 64-65; Ex. 1013 at ¶¶ 36, 89, 104.4
`
`
`
`
`3 OWT identifies the beginning bates number for each item of extrinsic evidence. It intends to rely on the entirety of each
`identified document.
` OWT identifies Tennant’s IPR Petitions and Supporting Declarations but does not take a position at this time about
`whether they should be considered intrinsic or extrinsic evidence.
`2
`
` 4
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 6 of 15
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`2. ‘415 Patent, Claim 13: “conductivity produced by the presence of dissolved solids such that the water supports plant
`or animal life”
`
`OWT’s
`construction
`Plain and ordinary
`meaning.
`
`
`The intrinsic record for the patents-in-suit,
`including:
`
` 
`
`Dr. Ralph White will testify that a POSA would
`understand the plain and ordinary meaning of this
`claim term as it is used in the context of the patent-in-
`suit. Dr. White will testify that a POSA would not
`understand this term to be limited to water with more
`than 2000 ppm for a number of reasons including that
`water with less than 2000 ppm supports plant and
`animal life.
`
`See e.g. Fundamentals of Electrochemistry
`(OWT00178950); An Experimental Study on the
`Effect of Electrolytic Concentration (OWT0017879);
`Investigation of electrical conductivity of different
`water liquids and electrolyte solutions
`(OWT0018617); Electrical Conductivity Protocol
`(ASP_OWT000001); Water Cell Functionality
`(ASP_OWT000012); TC00016871; TC00017832;
`TC00033231; Russ Pilkki email of 8/2/2012
`(ASP_OWT000015); TC00075327; TC00045209;
`OWT0081879; OWT0081896.
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g. -
`602 petition at 29, 34-35, 45, 52 54-57, 60-61; Ex.
`1003 at ¶¶ 36-37, 70-71; -625 petition at 30, 33-34,
`62, 64-65; Ex. 1013 at ¶¶ 36, 89, 104.
`
` The claims, including e.g., claim 13 of the
`’415 patent.
`
` 
`
` The specification, including e.g.,
`Abstract, col. 1, ll. 20 through col. 2, ll.
`62; col. 3, ll. 20-27, 37-43; col. 4, ll. 22-
`26; col. 5, ll. 21-25; col. 6, ll. 26-31; col.
`7, ll. 20 through col. 10, ll. 17.
`
` The prosecution history, including e.g.,
`OWT0001960, OWT0001981-94,
`OWT0002008, OWT0002027-44,
`OWT0002159.
`
`
`
`3
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 7 of 15
`
`
`3. ‘665 Patent, Claim 55: “aqueous medium”
`
`OWT’s
`construction
`Plain and ordinary
`meaning.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for the ’665 patent,
`including:
` The claims
` The specification, including e.g., col. 1, ll.
`34-58; col. 4, ll. 22-26.
` The prosecution history
`
`
`
`4. ‘415 Patent, Claim 13: “oxygenated aqueous composition"
`
`OWT’s
`construction
`Plain and ordinary
`meaning.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`TC00016871; TC00017832; TC00018330;
`TC00043228.
`
`
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., Fig. 8;
`col. 1, ll. 23-col. 2, ll. 62; col. 2, ll. 66-
`col. 3, ll. 43; col. 3, ll. 60; col. 4, ll. 19-
`26; col. 6, ll. 8-43; col. 7, ll. 23 through
`col. 8, ll. 36; col. 9, ll. 7-67; col. 10, ll. 9-
`18.
` The prosecution history, including e.g.,
`OWT0001981-94, OWT0002040-41
`
`4
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 8 of 15
`
`
`
`
`
`
`
`
`
`
`
`
`5. ‘415 Patent, Claims 13, 26: “tubular housing"
`
`OWT’s
`construction
`Plain and ordinary
`meaning. The
`term does not
`require a circular
`cross section.
`
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims, including the claims of the
`related patent e.g. Claim 20 of the ’092
`patent.
` The specification, including e.g., col. 3:25-
`33
` The prosecution history, including e.g.,
`OWT0001910
`
`6. ‘415 Patent, Claim 13: “flowing water … through an electrolysis emitter"
`
`OWT’s
`construction
`Moving water
`through an
`electrolysis emitter
`by means other
`than electrolysis.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g. -
`602 petition at 29, 41; Ex. 1046; Ex. 1012; -625
`petition at 62; Ex. 1105.
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims, including those claims that
`were cancelled during reissue
` The specification, including e.g.,
`Abstract; col. 1, ll. 23-30; col. 2, ll. 60-62;
`col. 3, ll. 25-43; col. 3, ll. 46-59; col. 9, ll.
`5 through col. 10, ll. 5; Figs. 7A, 7B
`
`5
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 9 of 15
`
` The prosecution history, including e.g.,
`OWT0001902-1916, OWT0001988,
`OWT0002038-42, OWT0002190
`
`7. ‘092 Patent, Claim 13: “a flow-through oxygenator"
`
`OWT’s
`construction
`An oxygenator
`configured to
`connect to a source
`of flowing water.
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims, including those claims that
`were cancelled during reissue
` The specification, including e.g.,
`Abstract; col. 1, ll. 23-30; col. 2, ll. 60-62;
`col. 3, ll. 25-43; col. 3, ll. 46-59; col. 9, ll.
`5 through col. 10, ll. 5; Figs. 7A, 7B
` The prosecution history, including e.g.,
`OWT0001902-1916, OWT0001988,
`OWT0002038-42, OWT0002190
`
`8. ‘665 Patent, Claim 13: “deliver electrical current to the electrodes while water flows through the tubular housing"
`
`OWT’s
`construction
`Deliver electrical
`current to the
`electrodes while
`moving water
`through the
`electrolysis emitter
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for the ’665 patent
`including:
` The claims, including those claims that
`were cancelled during reissue
` The specification, including e.g.,
`Abstract; col. 1, ll. 23-30; col. 2, ll. 60-62;
`
`
`
`6
`
`
`
`
`
`
`
`
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 10 of 15
`
`by means other
`than electrolysis.
`
`col. 3, ll. 25-43; col. 3, ll. 46-59; col. 9, ll.
`5 through col. 10, ll. 5;; Figs. 7A, 7B
` The prosecution history, including e.g.,
`OWT0001902-1916, OWT0001988,
`OWT0002038-42, OWT0002190
`
`9. ‘092 Patent, Claim 13: “passing water through the tubular housing”
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`
`
`
`
`OWT’s
`construction
`Moving water
`through an
`electrolysis emitter
`by means other
`than electrolysis.
`
`
`
`
`The intrinsic record for the ’092 patent,
`including:
` The claims, including those claims that
`were cancelled during reissue
` The specification, including e.g.,
`Abstract; col. 1, ll. 23-30; col. 2, ll. 60-62;
`col. 3, ll. 25-43; col. 3, ll. 46-59; col. 9, ll.
`5 through col. 10, ll. 5; Figs. 7A, 7B
` The prosecution history, including e.g.,
`OWT0001902-1916, OWT0001988,
`OWT0002038-42, OWT0002190
`
`
` 10a. ‘415 Patent, Claim 13: “an electrical power source”
` 10b. ‘092 Patent, Claims 13, 27; ‘665 Patent, Claim 13: “a power source”
`
`
`OWT’s
`construction
`Electrical and
`mechanical
`equipment and
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for the patents-in-suit,
`including:
` The claims,
`
`Dr. Ralph White will testify that the terms “electrical
`power source” and “power source” in the context of
`electrolysis are understood by a POSA to encompass
`
`
`
`7
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 11 of 15
`
`their
`interconnections
`used to generate
`and/or convert
`power.
`
`
` The specification, including e.g., col. 2, ll.
`3-9; col. 3, ll. 25-36, col. 5, ll. 35-38; col.
`10, ll. 20-45.
` The prosecution history, including e.g.,
`OWT0001908
`
`the combination of components that provide electrical
`power to an electrode, and that this term would not be
`limited to the battery. He will testify that line power,
`batteries, and electrical power supplies are all used to
`provide electrical power for electrolysis.
`
`The New IEEE Standard Dictionary of Electrical and
`Electronics Terms (OWT0018615)
`McGraw-Hill Electronics Dictionary
`(OWT0018623); TC00016871; TC00043582;
`Gensys Brochure (OWT81871).
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g.
`Ex. 1103 at ¶¶ 50, 119, 123; Ex. 1003 at ¶ 50.
`
`
`
`
`
`
`
`
`
`11. ’415 Patent, Claims 13, 19, 20, 21, 22, 25; ’092 Patent, Claim 26: “nanobubble”
`
`OWT’s
`construction
`A bubble with a
`diameter less than
`that necessary to
`break the surface
`tension of water.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`TC00017832; TC00016871.
`
`The intrinsic record for the patents-in-suit,
`including:
` The claims,
` The specification, including e.g., col. 3, ll.
`1-3; col. 4, ll. 12-15; col. 4, ll. 4:30-38;
`col. 5:44-6:2
` The prosecution history, including e.g.
`OWT0002040-41
`
`8
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 12 of 15
`
`12. ’415 Patent, Claim 25: “incapable of breaking the surface tension of the water”
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`TC00017832; TC00016871
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., col. 3, ll.
`1-3; col. 4, ll. 30-38
` The prosecution history, including e.g.,
`OWT0001991-92, OWT0002040-41
`
`OWT’s
`construction
`Plain and ordinary
`meaning.
`
`
`
`13. ’415 Patent, Claim 19: “the microbubbles and nanobubbles remain in the water at least in part for a period up to
`several hours”
`
`OWT’s
`construction
`The microbubbles
`and nanobubbles
`remain in the water
`at least in part for
`at least several
`hours.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`Merriam Webster (OWT0081903)
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., col. 3, 1-
`3; col. 4, ll. 30-41; col. 5, ll. 8-10
` The prosecution history, including e.g.,
`OWT0001981-94, OWT0002040-41
`
`9
`
`
`
`
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 13 of 15
`
`14. ’415 Patent, Claim 20: “wherein the period for which the microbubbles and nanobubbles at least in part remain in the
`water is determined by containing the water with microbubbles and nanobubbles in a two and one half gallon
`aquarium reservoir container”
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., col. 3, 1-
`3; col. 4, ll. 30-41; col. 5, ll. 8-10
` The prosecution history, including e.g.,
`OWT0002040-41
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g. -
`602 petition at 37, 48-50, Ex. 1003 at ¶ 69; -625
`petition at 35-36, 67; Ex. 1103 at ¶ 35, 91, 106.
`
`OWT’s
`construction
`Plain and ordinary
`meaning. This
`claim identifies
`physical properties
`of the
`microbubbles and
`nanobubbles and
`identifies a test
`methodology for
`determining
`whether the
`microbubbles and
`nanobubbles have
`that physical
`property.
`
`
`15. ‘665 Patent, Claim 61: “a first anode electrode portion that is non parallel to a second anode electrode portion”
`
`OWT’s
`construction
`Plain and ordinary
`meaning.
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for the ’665 patent,
`including:
`
`
`
`10
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 14 of 15
`
`
`
` The claims, including those of other
`patents in the patent family such as e.g.
`claims 25, 34, 46, 58, 66, 75, and 83 of
`the ’092 patent
` The specification,
` The prosecution history
`
`
`
`16. ‘415 Patent, Claim 13: “tubular flow axis from the inlet to the outlet”
`
`OWT’s
`construction
`Plain and ordinary
`meaning, which is:
`a main line of flow
`through the tubular
`housing from the
`inlet to the outlet.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., col.
`3:25-33
` The prosecution history, including e.g.
`OWT0002016
`
`
`
`Dr. Ralph White will testify that a POSA would
`understand the term tubular flow axis from the inlet
`to the outlet and would understand that the phrase
`does not require that the water flow in a straight line.
`Dr. White will testify that a POSA would understand
`that water flowing through an electrolytic system
`rarely flows in a completely straight line because the
`electrodes distort the direction of the flow. Dr. White
`will further testify that a POSA would understand
`that the tubular flow axis was the main line of flow
`through the tubular housing. Dr. White will rely on
`Webster’s Third New International Dictionary, cited
`by Tennant.
`
`Tennant’s IPR Petitions and the Declarations of Dr.
`Tremblay supporting those petitions, including e.g.
`IPR2021-00602, Paper 1 at 44; Ex. 1003 at ¶ 63.
`
`11
`
`
`
`
`
`

`

`CASE 0:20-cv-00358-ECT-HB Doc. 75-1 Filed 06/09/21 Page 15 of 15
`
`17. ‘415 Patent, Claim 18: “the water temperature is a factor for formation of the suspension”
`
`OWT’s
`construction
`Plain and ordinary
`meaning. The term
`does not require the
`temperature be
`measured or
`evaluated.
`
`
`Intrinsic Evidence
`
`Extrinsic Evidence
`
`Tennant’s IPR Petitions and the declarations of Dr.
`Tremblay supporting those petitions, including e.g. -
`602 petition at 35-36, 47; Ex. 1003 at ¶¶ 37, 71; -625
`petition at 34, 66; Ex. 1103 at ¶¶ 36, 92, 107.
`
`The intrinsic record for U.S. Patent No.
`RE45,415, including:
` The claims
` The specification, including e.g., Fig. 3,
`col. 5, lines 25-37, col. 9, lines 32-34
` The prosecution history, including e.g.
`OWT0000446, OWT0000459,
`OWT0000486, OWT0000500,
`OWT0001960, OWT0001965,
`OWT0001990, OWT0002009,
`OWT0002011, OWT0002089-2090
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`12
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