`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`META PLATFORMS, INC.,
`Petitioner,
`
`v.
`
`ANGEL TECHNOLOGIES LLC,
`Patent Owner.
`
`––––––––––
`
`Case IPR2023-00057
`Patent 8,954,432
`Case IPR2023-00058
`Patent 9,959,291
`Case IPR2023-00059
`Patent 10,417,275
`Case IPR2023-00060
`Patent 10,628,480
`
`––––––––––
`
`DECLARATION OF LISA LARSON
`UNDER 37 C.F.R. § 1.131
`
`Angel Tech Exhibit 2018
`Meta v. Angel Tech
`IPR2023-00057
`
`
`
`I, Lisa Larson, declare:
`
`1.
`I am a citizen of the United States and am over 21 years of age and in all respects
`fully competent to make this Declaration. I make this Declaration based on facts within my
`personal knowledge, and if called as a witness, I could and would competently testify to the matters
`set forth herein.
`
`2.
`From have been acquainted with Mark Frigon since January 1999. From this time
`through September 2000, I was aware that he was developing his photo-tagging invention, and
`that he created a computer-based application that could be accessed via the internet. I understand
`that he also filed patent applications intended to cover his inventions.
`
`3.
`Mark’s progress with the technology was a frequent topic of conversation over the
`course of the year 2000 and beyond. I recall him telling me about how excited he was over his idea
`for a photo tagging technology and database that was searchable by users present.
`
`4.
`I witnessed him devote the majority of his free time outside of work developing the
`technology in the early 2000s, until he eventually left his employment summer 2000 to pursue it
`full time. He was frequently working on the design of his system on his computer when I visited
`and his work on the system was continuous during the early 2000 time frame.
`
`5.
`I recall Mark having a patent textbook which he was using to draft his patent
`application in the August and September 2000 timeframe.
`
`6.
`Mark demonstrated the functionality of the invention and his website to me,
`including by having me register on his functional website as referenced in the emails submitted as
`Exhibit 2015 from September 28, 2000.
`
`7.
`In summary, throughout the course of the year 2000, Mark Frigon had demonstrated
`to me his invention and its functionality.
`
`
`
`
`
`
`
`
`
`
`8.
`I declare under penalty of perjury under the laws of the United States that the
`foregoing is true and correct.
`
`
`Executed on 02/15/2023
`
`Lisa Larson
`
`
`
`
`
`
`
`
`
`
`
`
`
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