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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`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 CHRIS MALONE
`UNDER 37 C.F.R. § 1.131
`
`Angel Tech Exhibit 2016
`Meta v. Angel Tech
`IPR2023-00059
`
`

`

`I, Chris Malone, 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 October 1998 to August 2000, I lived with Mark Frigon, while he was
`
`developing his photo-tagging invention, and 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.
`
`While I was living with Mr. Frigon, he developed a personal website for me,
`
`Cmalone.com. At the same time, I was aware he was working on developing a photo-tagging
`
`technology during the 1999-2000 period. Throughout the time we lived together, he would always
`
`be downstairs working on code and demonstrating the developments he was making.
`
`4.
`
`For example, I recall him first demonstrating that he could load images into the
`
`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
`
`all the photos that they had been identified in.
`
`5.
`
`Although I did not have a technical background to understand the code, I recall
`
`seeing voluminous code that he had developed and the finished product in practice as he
`
`demonstrated his website and capabilities to me during the development.
`
`6.
`
`This was something I witnessed him working on pretty much daily throughout the
`
`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—
`
`he never stopped working on the software during the entire time we lived together.
`
`

`

`a
`
`In summary, by the time I had movedout of our apartment in August 2000, Mark
`
`Frigon had demonstrated to me his invention andits functionality.
`
`8.
`
`I declare under penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
`
`at
`
`Executed on 1 IV
`
`Z
`
`Chin Malar
`
`Chris Malone
`
`

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