`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF MINNESOTA
`
`
`OXYGENATOR WATER
`TECHNOLOGIES, INC.
`
`
`
`v.
`
`TENNANT COMPANY
`
`
`
`
`
`
`
`
` Civil Action No. 0:20-cv-00358 (ECT/HB)
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`DECLARATION OF NATHAN D. LOUWAGIE
`
`I, Nathan D. Louwagie, an attorney at Carlson, Caspers, Vandenburgh &
`
`Lindquist, P.A., which is counsel for Oxygenator Water Technologies (“OWT”),
`
`hereby declare as follows:
`
`1.
`
`Exhibit 1 is a true and correct copy of Tennant Company’s Petition for
`
`Inter Partes Review from IPR2021-00602.
`
`2.
`
`Exhibit 2 is a true and correct copy of Tennant Company’s Petition for
`
`Inter Partes Review from IPR2021-00625.
`
`3.
`
`Exhibit 3 is a true and correct copy of the Declaration of Dr. Mario
`
`Tremblay from IPR2021-00602.
`
`4.
`
`Exhibit 4 is a true and correct copy of the Declaration of Dr. Mario
`
`Tremblay from IPR2021-00625.
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`
`
`1
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80 Filed 06/10/21 Page 2 of 4
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`5.
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`Exhibit 5 is a true and correct copy of an article produced by Tennant in
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`this lawsuit. Its beginning bates number is TC00045187.
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`6.
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` Exhibit 6 is a true and correct copy of an article titled Analysis of
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`Water Quality for Livestock by Clell V. Bagedly, DVM et al., produced in this case
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`as a document beginning with Bates No. OWT0081896.
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`7.
`
`Exhibit 7 is a true and correct copy of an article titled Investigation of
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`Electrical Conductivity of Different Water Liquids and Electrolyte Solutions by H.
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`Golnabi et al, produced in this case as a document beginning with Bates No.
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`OWT0018617.
`
`8.
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`Exhibit 8 is a true and correct copy of OWT’s First Supplemental
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`Exhibit 3 to its RE45,415 Infringement Claim Chart which was served on October 9,
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`2020. Exhibit 8 is confidential and has been filed under seal.
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`9.
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`Exhibit 9 is a true and correct copy of Tennant’s Supplemental Exhibit 1
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`to its Non-Infringement Contentions, which was served on December 21, 2020.
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`Exhibit 9 is confidential and has been filed under seal.
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`10.
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`Exhibit 10 is a true and correct copy of Tennant’s Amended Proposed
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`Claim Terms for Construction and Extrinsic Evidence dated March 30, 2021.
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`11.
`
`Exhibit 11 is a true and correct copy of US Patent No. 6,251,259, issued
`
`to Satoh et al.
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`
`
`2
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`
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`CASE 0:20-cv-00358-ECT-HB Doc. 80 Filed 06/10/21 Page 3 of 4
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`12.
`
`Exhibit 12 is a true and correct copy of US Patent No. 3,891,535, issued
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`to Wikey.
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`13.
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`Exhibit 13 is a true and correct copy of Tennant’s Invalidity Chart for
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`Reissued Patent US RE45,415.
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`14.
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`Exhibit 14 is a true and correct copy of a document Tennant produced in
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`this lawsuit. Its beginning bates number is TC00000086.
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`15.
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`Exhibit 15 is a true and correct copy of an excerpt from The New IEEE
`
`Standard Dictionary of Electrical and Electronics Terms, dated 1993.
`
`16.
`
`Exhibit 16 is a true and correct copy of an excerpt from the Sixth
`
`Edition of the McGraw-Hill Electronics Dictionary, dated 1997.
`
`17.
`
`18.
`
`19.
`
`Exhibit 17 is a true and correct copy of US 2009/0120460 A1.
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`Exhibit 18 is true and correct copy of US Patent No. 8,025,787.
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`Exhibit 19 is a true and correct copy of the deposition transcript of Dr.
`
`Russell Pylkki that took place on May 27, 2021. Exhibit 19 is confidential and has
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`been filed under seal.
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`20.
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`Exhibit 20 is a true and correct copy of a document Tennant produced in
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`this lawsuit. Its beginning bates number is TC00034810. Exhibit 20 is confidential
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`and has been filed under seal.
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`21.
`
` Exhibit 21 is a true and correct copy of U.S. Patent No. 8,025,787.
`
`
`
`3
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`
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`CASE 0:20-cv-00358-ECT-HB Doc. 80 Filed 06/10/21 Page 4 of 4
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`22.
`
`Exhibit 22 is a true and correct copy of an article titled An Experimental
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`Study on the Effect of Electrolytic Concentration on the Rate of Hydrogen Production
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`by D. Buddhi et al.
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`23.
`
`Exhibit 23 is a true and correct copy of a document Aspen Research
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`Corporation produced in this lawsuit. Its beginning bates number is
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`ASP_OWT0000001.
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`24.
`
`Exhibit 24 is a true and correct copy of a document Aspen Research
`
`Corporation produced in this lawsuit. Its beginning bates number is
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`ASP_OWT0000015. Exhibit 24 is confidential and has been filed under seal.
`
`25.
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`Exhibit 25 is a true and correct copy of a document Tennant produced in
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`this lawsuit. Its beginning bates number is TC00033231. Exhibit 25 is confidential
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`and has been filed under seal.
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`I state under penalty of perjury that the foregoing is true and correct.
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`Dated: June 10, 2021
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`
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`
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`s/ Nathan D. Louwagie
` Nathan D. Louwagie
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`4
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