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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`META PLATFORMS, INC.,
`Petitioner,
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`v.
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`ANGEL TECHNOLOGIES LLC,
`Patent Owner.
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`––––––––––
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`Case IPR2023-00057
`Patent 8,954,432
`
`Case IPR2023-00058
`Patent 9,959,291
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`Case IPR2023-00059
`Patent 10,417,275
`
`Case IPR2023-00060
`Patent 10,628,480
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`DECLARATION OF CHRIS MALONE
`UNDER 37 C.F.R. § 1.131
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`Angel Tech Exhibit 2016
`Meta v. Angel Tech
`IPR2023-00058
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`
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`I, Chris Malone, declare:
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`1.
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`I am a citizen of the United States and am over 21 years of age and in all respects
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`fully competent to make this Declaration. I make this Declaration based on facts within my
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`personal knowledge, and if called as a witness, I could and would competently testify to the matters
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`set forth herein.
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`2.
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`From October 1998 to August 2000, I lived with Mark Frigon, while he was
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`developing his photo-tagging invention, and he created a computer-based application that could
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`be accessed via the internet. I understand that he also filed patent applications intended to cover
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`his inventions.
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`3.
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`While I was living with Mr. Frigon, he developed a personal website for me,
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`Cmalone.com. At the same time, I was aware he was working on developing a photo-tagging
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`technology during the 1999-2000 period. Throughout the time we lived together, he would always
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`be downstairs working on code and demonstrating the developments he was making.
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`4.
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`For example, I recall him first demonstrating that he could load images into the
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`website he had developed and identify individuals in the photo by labeling their faces. As he
`continued working on the software code, he could later enter individuals’ names and then pull up
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`all the photos that they had been identified in.
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`5.
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`Although I did not have a technical background to understand the code, I recall
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`seeing voluminous code that he had developed and the finished product in practice as he
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`demonstrated his website and capabilities to me during the development.
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`6.
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`This was something I witnessed him working on pretty much daily throughout the
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`time we lived together (from 1998 to 2000), and I recall him later leaving his full time employment
`so that he could devote his time fully to developing the technology. It was a continuous process—
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`he never stopped working on the software during the entire time we lived together.
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`
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`a
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`In summary, by the time I had movedout of our apartment in August 2000, Mark
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`Frigon had demonstrated to me his invention andits functionality.
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`8.
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`I declare under penalty of perjury under the laws of the United States that the
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`foregoing is true and correct.
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`at
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`Executed on 1 IV
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`Z
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`Chin Malar
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`Chris Malone
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`