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 MARK FRIGON
`UNDER 37 C.F.R. § 1.131
`
`
`
`Angel Tech Exhibit 2005
`Meta v. Angel Tech
`IPR2023-00059
`
`

`

`I, Mark Frigon, declare:
`
`1.
`
`I am over eighteen years of age and in all respects fully competent to make this
`
`Declaration. I have personal knowledge of the facts, as stated herein, and all are true and correct.
`
`2.
`
`I am the named inventor of U.S. Patent No. 8,954,432, entitled “Users Tagging
`
`Users in Photos Online,” U.S. Patent No. 9,959,291, entitled “Users Tagging Users in Media
`
`Online” U.S. Patent No. 10,417,275, entitled “Artificial Intelligence Assisted Tagging of Users in
`
`Digital Media Online,” and U.S. Patent No. 10,628,480, entitled “Linking Tags to user Profiles.”
`
`3.
`
`Prior to September 26, 2000, I conceived and reduced to practice my invention as
`
`described and claimed in the provisional application (U.S. Provisional Application No.
`
`60/248,994) filed on November 15, 2000, from which each of the above identified patents claim
`
`priority. The provisional application was drafted in the summer of 2000 and finalized on August
`
`15, 2000 while I was living in New York. I paid for and filed the application upon my relocation
`
`to Colorado on November 15, 2000.
`
`4.
`
`As discussed below, the code developed by April 2000 demonstrate that I had a
`
`tested prototype embodying the elements of the invention claimed, and had seen that it worked for
`
`its intended purpose prior to September 26, 2000. As further evidence of this, and as detailed
`
`below, the functioning www.sacko.com website was developed between April and prior to
`
`September 26, 2000 and was selectively available to users over the internet for testing during that
`
`time period.
`
`5.
`
`What was recoverable of the code, database, and log files demonstrated the claimed
`
`invention had been conceived, coupled with reasonably continuous due diligence to reduce the
`
`invention to practice, on or before April 16, 2000. I personally wrote the code submitted herewith
`
`which embodied the elements of the invention claimed using Microsoft FrontPage, a popular web
`
`

`

`authoring platform at the time, and Microsoft Access as the database. The code was written while
`
`authoring a photo-oriented website “cmalone.com” for a friend and roommate, Chris Malone.
`
`Attached hereto as Exhibits 2006-2012 are what I believe to be true and correct copies of that code.
`
`Each of Exhibits 2006-2012 provide code that was last modified on April 16, 2000, as corroborated
`
`by the code’s metadata for each of Exhibits 2006-2013.
`
`
`
`6.
`
`The code in Exhibit 2006 for inputting a picture (pict_inpt.asp) allows for users to
`
`upload a picture to the website, provide information about the picture, and for a user to identify
`
`which people exist in the photograph. The code along with the database in Exhibit 2007
`
`(picture.mdb) generates a unique image identifier for any images uploaded by a user.
`
`7.
`
`The code in Exhibit 2008 for updating a picture (pict_upd.asp) allows any user, not
`
`just the user uploading the picture, to identify people in the photo.
`
`8.
`
`The code in Exhibit 2009 for displaying a single picture (picture.asp) retrieves from
`
`the database a listing of any people identified within the selected picture and including the unique
`
`user identifiers for each user.
`
`

`

`9.
`
`The code in Exhibit 2010 for showing all tags of users in photos (links.asp) displays
`
`a listing of all user-generated identifications along with each picture identifier (“File_ID”) and
`
`each user’s identifier (“Person_ID”). The code retrieves these relationships between the picture
`
`identifier and the user identifier from a database table (“People_in_Pict”) on line 52 of “links.asp”.
`
`This table embodies the Identifications database detailed in my specifications with a record
`
`mapping a “Person_ID” (line 89 of “links.asp”) and a “File_ID” (line 82 of “links.asp”) for each
`
`identification. The presence of this table discloses the “Identifications database 240 links
`
`information in Users database 230 with information in Images database 250” as disclosed in each
`
`of the above identified patents. It further demonstrates the conception and reduction to practice of
`
`three separate tables detailed in the specification of each of the above identified patents: the users
`
`table, an identifications table, and an images table.
`
`10.
`
`Exhibit 2011 displays a sample log file (ex0006.log, dated June 17, 2000) from the
`
`web server running the cmalone.com website, at IP address 4.22.121.22. The log files
`
`demonstrates the software was accessed by multiple users across a network with each user being
`
`identified by a unique IP address as denoted by the client ip address (the “c-ip” column). Lines 10
`
`and 19 also corroborate this with a 3rd party Alumni network website (www.infophil.com) linking
`
`into the cmalone.com website as is indicated by the user’s referring website via the cs(referrer)
`
`column. Details on Info Phil’s Alumni network at that time can be found on the Internet Archives
`
`snapshot
`
`dated
`
`June
`
`20th,
`
`2000:
`
`https://web.archive.org/web/20000620055601/http://www.alumni.net/.
`
`11.
`
`Exhibit 2012 demonstrates a code file (“messages_post.html”) which receiving
`
`naming information from a user and storing a users database. On Line 25 the code presents a form
`
`to a user comprising an input field (line 38) that allows users to include naming information to the
`
`

`

`system. Upon submission of the form by clicking the submit button (line 64) the information is
`
`sent to web server at “_vti_bin/shtml.dll/messages_post.htm” (line 25) for insertion into a users
`
`database.
`
`12.
`
`Exhibits 2006-2012 provide code which can be mapped to each and every element
`
`of the ‘432 Patent, as evidenced in the table below.
`
`Claim Element
`
`Code
`
`6. In a multi-user
`
`The code files for the web server and the log files in Exhibit
`
`computer network, a method for
`
`2011 shows a multi-user computer network (see log files)
`
`obtaining and displaying
`
`and the display of information relating to a user of the
`
`information relating to existence
`
`network an image. The presence of multiple users is
`
`of at least one user of a computer
`
`demonstrated by the multiple client devices identified by
`
`network in an image comprising:
`
`different IP addresses on line 5, line 10, line 11, line 19, and
`
`line 25.
`
`identifying users of said
`
`The web server log files sample, (“ex0006.log”) also
`
`computer network and assigning
`
`anticipates identifying users by the clients IP address (“c-
`
`a unique user identification to a
`
`ip” field) and the clients username (“c-username” field).
`
`user of said computer network;
`
`Ex-2010.
`
`Additionally, the code on lines 38, 52, and 89 of
`
`“links.asp” demonstrates the presence of an assigned
`
`unique user identifier “Person_ID” in the
`
`“People_in_Pict” table for any identification of a user in a
`
`picture. In the prototype, the “People_in_Pict” table was
`
`the precursor to the Identifications table discussed in the
`
`specification.
`
`

`

`storing said unique user
`
`identifier in an users database
`
`wherein said database is
`
`accessible by other computers of
`
`said computer network;
`
`The Microsoft Access database, “pictures.mdb”,
`
`demonstrates the storage of unique user identifiers in the
`
`“People” column of the “Picts” table:
`
`Line 52 of the “links.asp” code demonstrates unique user
`
`identifiers were also stored in a “People_In_Pict” table.
`
`Lines 82 & 89 demonstrates the “People_In_Pict” table is
`
`comprised of a “Person_ID” field and a “File_ID” field,
`
`corresponding to a user identifier and image identifier in
`
`the specifications Identifications database.
`
`obtaining image data from
`
`The code in “pict_inp.asp” receives image data from an
`
`at least one uploading user of said
`
`uploading user and the database “picture.mdb” assigns a
`
`computer network and assigning
`
`unique image identifier.
`
`a unique image identifier to said
`
`image data;
`
`Line 105 of the code begins “form” presents user interface
`
`to a user which includes a file upload element on line 115.
`
`Upon submitting the form, via a form submission button
`
`(line 138), the form sends the data to be inserted into the
`
`“Picts” table of “pictures.mdb” database (line 108). The
`
`“Picts” table of “pictures.mdb” is configured to
`
`automatically generate an image identifier for any new
`
`records, as is dictated by the “AutoNumber” datatype in
`
`Microsoft Access.
`
`

`

`
`
`
`
`
`
`The database also receives from the form and stores the
`
`name of the uploaded file in the “file_name” field.
`
`“File_name” in other embodiments might alternatively
`
`serve as a unique image identifier for the image.
`
`storing said unique image
`
`Upon insertion into the “Picts” table each image record
`
`identifier in an images database
`
`stores the associated image identifier generated from the
`
`wherein said database is
`
`“AutoNumber” data type in the “ID” field. The table also
`
`accessible by other computers of
`
`stores a unique file name on the server in the “file_name”
`
`said computer network;
`
`field.
`
`
`
`
`
`
`
`obtaining identification
`
`The picture updating code file, “pict_upd.asp”
`
`data from a first tagging user of
`
`demonstrates obtaining from a tagging user a unique
`
`said computer network, wherein
`
`image identifier and a unique user identifier of a pictured
`
`said identification data comprises
`
`user.
`
`said unique image identifier and a
`
`pictured user unique identifier of
`
`a user of said computer network
`
`pictured in said image data;
`
`Line 57 retrieves the information about the selected image
`
`from the database, including the image identifier. Line 79
`
`displays the image.
`
`

`

`Line 124 begins a “form” element for a user to send data
`
`to the server. The form element contains “input” field for
`
`information about the photo that the user can submit. The
`
`form includes a “People” input element (line 139) for a
`
`user to supply user identifiers of users in the selected
`
`image. The image identifier is embedded in the page as
`
`the user has previously selected the image to view.
`
`Upon submitting the form via a “submit” element (line
`
`151) the client sends back to the server, and the server
`
`receives the people identifiers via the “people” input data
`
`and the image identifier.
`
`storing said identification
`
`Once the identification data, including an image identifier
`
`data from said first tagging user in
`
`and a user identifier, is received from the user the code in
`
`an
`
`identifications
`
`database
`
`the related but separate “pict_upd_asp.asp” is executed.
`
`accessible by other computers of
`
`In line 47 of the code a database UPDATE command
`
`said network whereby a user
`
`executed on the “Picts” table to update the image record
`
`identifier may be associated with
`
`matching the supplied image identifier. The update
`
`one or more image identifiers and
`
`command stores user identifiers supplied by the user with
`
`an
`
`image
`
`identifier may be
`
`the image record.
`
`associated with one or more users
`
`
`
`identifiers.
`
`In addition, line 52 of the “links.asp” code demonstrates
`
`unique user identifiers were additionally, or alternatively,
`
`stored in a “People_In_Pict” table. Lines 82 & 89
`
`demonstrates the “People_In_Pict” table is comprised of a
`
`“Person_ID” field and a “File_ID” field, corresponding to
`
`

`

`a user identifier and image identifier in the specifications
`
`Identifications database.
`
`Both of the Exhibits discussed here disclose a “many-to-
`
`many” relationship between users and images: a user may
`
`be associated with many images and likewise, and image
`
`may be associated with many users.
`
`
`
`13.
`
`Exhibit 2013 displays another sample log files (ex0007.log, dated July 1, 2000)
`
`from the same web server continuing to run at the cmalone.com website from the IP address
`
`4.22.121.22 (as previously discussed and shown in the ex0006.log log file). The log files
`
`demonstrates that this was a functioning website. Line 88 of the log file further demonstrates the
`
`site was connected to the Internet as an inbound link from Yahoo’s personal profile website served
`
`as
`
`the
`
`visitors
`
`referrer
`
`as
`
`captured
`
`in
`
`the
`
`“cs(Referrer)”
`
`field:
`
`http://profiles.yahoo.com/chris_malone”.
`
`
`
`14.
`
`Exhibits 2006-2013 provide code which can be mapped to the ‘291 Patent, as
`
`evidenced in the table below.
`
`Claim Element
`
`Code
`
`1. A method implemented
`
`The code files for the web server and the log files in
`
`within a computer system including a
`
`Exhibit 2013 shows a computer system including a
`
`plurality of computing devices
`
`plurality of computing devices connected via a
`
`connected via a communications
`
`communications network, the method associating users
`
`network, the method associating users
`
`of the computer system with digital media accessible to
`
`of the computer system with digital
`
`the computer system.
`
`

`

`media accessible to one or more of the
`
`plurality of computing devices, the
`
`method comprising:
`
`identifying a plurality of users
`
`The web server log files sample in Exhibit 2013
`
`of the computer system, one or more
`
`(“ex0007.log”) shows identifying a plurality users by
`
`of the plurality of users having a
`
`the clients IP address (“c-ip” field) and the clients
`
`unique user identifier stored in
`
`username (“c-username” field). A plurality of users
`
`memory accessible to one or more of
`
`are seen by different IP addresses in line 5, line 10,
`
`the plurality of computing devices, the
`
`line 12, line 17 and subsequent unique IP addresses in
`
`plurality of users including a first user
`
`the file.
`
`and a second user, the first user being
`
`different from the second user;
`
`The Microsoft Access database, “pictures.mdb”,
`
`demonstrates the storage of unique user identifiers in
`
`determining, from memory
`
`the “People” column of the “Picts” table for a plurality
`
`accessible to one or more of the
`
`of users.
`
`plurality of computing devices,
`
`associations between descriptive
`
`information about one or more of the
`
`plurality of users and unique user
`
`Line 52 of the “links.asp” code also demonstrates
`
`unique user identifiers were also stored in a
`
`“People_In_Pict” table via the “Person_ID” field
`
`which would have referenced a unique user identifier
`
`identifiers of the users, the associations
`
`including an association between
`
`in a users table.
`
`descriptive information previously
`
`The code in Exhibit 2012 (“messages_post.html”)
`
`provided by the first user and a unique
`
`demonstrates receiving naming information from a
`
`user identifier of the first user;
`
`user and storing a users database. On Line 25, the
`
`code presents a form to a user comprising an input
`
`field (line 38) that allows users to include naming
`
`

`

`information to the system. Upon submission of the
`
`form by clicking the submit button (line 64) the
`
`information is sent to web server at
`
`“_vti_bin/shtml.dll/messages_post.htm” (line 25) for
`
`insertion into a users database.
`
`This code includes inputs from a user to submit their
`
`name (or any other descriptive information about
`
`identifying the user).
`
`determining, from memory
`
`Both the “pictures.mdb” database and the “links.asp”
`
`accessible to one or more of the
`
`code demonstrate a stored association between users
`
`plurality of computing devices,
`
`who appear in the same photo. The “pictures.mdb”
`
`associations between the plurality of
`
`demonstrates columns of people in pictures that lists IDs
`
`users, the associations including an
`
`of users side by side. Alternatively, the “links.asp”
`
`association between the first user and
`
`demonstrates the relationship between users in the same
`
`the second user;
`
`photo could be stored row by row. Beyond this specific
`
`type of relationship (pictured together), I had conceived
`
`that other forms of relationship between users would
`
`exist, such as relationships between users frequently
`
`pictured together or relationships between a user and
`
`other users whom they frequently share photos with.
`
`providing, via one or more of
`
`Both the “pictures.mdb” database and the “links.asp”
`
`the plurality of computing devices, a
`
`code show a unique user identifier that would have
`
`graphical user interface for
`
`referenced a users table. The “pictures.mdb” database
`
`presentation to the second user, the
`
`does this via a “people” column containing user
`
`graphical user interface operative to
`
`identifiers.
`
`

`

`receive one or more inputs from the
`
`The users table listed all users populated input form
`
`second user indicating a selection of
`
`allowing users to select from other users.
`
`one or more of the plurality of users
`
`
`
`from descriptive information
`
`The “links.asp” also demonstrates the storage of user
`
`associated with unique user identifiers
`
`identifiers from a “People_in_Pict” database.
`
`of the one or more of the plurality of
`
`users, the graphical user interface
`
`configured to display descriptive
`
`information associated with unique
`
`user identifiers of one or more of the
`
`plurality of users with a determined
`
`association with the second user;
`
`Since early testers would not have necessarily known
`
`the identifiers of other users I had developed a
`
`mechanism to select user from a list of other users
`
`present in the database. Additionally, the provisional
`
`application itself discloses that “the server also
`
`retrieves a list of users from the Users database (304)”
`
`and the “user information is transcribed into HTML
`
`receiving, via the
`
`elements that enable the client to select a specific user
`
`communications network, an input
`
`from the list of users (305)” See Ex-2017, pg. 4.
`
`initiated by the second user via the
`
`graphical user interface, the received
`
`input indicating a selection of the first
`
`user from descriptive information
`
`associated with the unique user
`
`identifier of the first user;
`
`The concept of further filtering this input list to users
`
`in a contact list to had been conceived at this point, and
`
`was in development at the time of drafting the
`
`provisional application from which this patent claims
`
`priority. Additionally, the provisional application
`
`itself discloses that “if the list of users is too large, one
`
`determining the unique user
`
`could narrow it down by filtering other field(s), or in
`
`identifier of the first user from the
`
`advanced situations other databases.” See Ex-2017, pg.
`
`received input initiated by the second
`
`4.
`
`user indicating the selection of the first
`
`user; and
`
`

`

`in response to receiving the
`
`Once the identification data, including an image
`
`input initiated by the second user
`
`identifier and a user identifier, is received from the
`
`indicating the selection of the first user
`
`user the code in the related but separate
`
`and to determining the unique user
`
`“pict_upd_asp.asp” is executed. In line 47 of the code
`
`identifier of the first user, storing in
`
`a database UPDATE command executed on the “Picts”
`
`memory accessible to one or more of
`
`table to update the image record matching the supplied
`
`the plurality of computing devices an
`
`image identifier. The update command stores user
`
`association between the unique user
`
`identifiers supplied by the user with the image record.
`
`identifier of the first user and the
`
`
`
`unique digital media identifier
`
`In addition, line 52 of the “links.asp” code
`
`corresponding to the digital media
`
`demonstrates unique user identifiers were additionally,
`
`selection input by the second user.
`
`or alternatively, stored in a “People_In_Pict” table.
`
`Lines 82 & 89 demonstrates the “People_In_Pict”
`
`table is comprised of a “Person_ID” field and a
`
`“File_ID” field, corresponding to a user identifier and
`
`image identifier in the specifications Identifications
`
`database.
`
`
`
`15.
`
`Exhibits 2006-2013 provide code which can be mapped to the ‘275 Patent, as
`
`evidenced in the table below.
`
`Claim Element
`
`Code
`
`1. A method implemented
`
`The code files for the web server and the log files in
`
`within a computer system including a
`
`Exhibit 2013 shows a computer system including a
`
`plurality of computing devices
`
`plurality of computing devices connected via a
`
`connected via a communications
`
`communications network, the method associating users
`
`network, the method associating users
`
`

`

`of the computer system with digital
`
`of the computer system with digital media accessible to
`
`media accessible to the computer
`
`the computer system.
`
`system, the method comprising:
`
`A plurality of users are demonstrated by the different IP
`
`addresses in line 5, line 10, line 12, line 17 and
`
`subsequent unique IP addresses in the file.
`
`distinguishing between users of
`
`The Microsoft Access database, “pictures.mdb”,
`
`the computer system via one or more
`
`demonstrates the storage of unique user identifiers in
`
`unique user identifiers stored in a
`
`the “People” column of the “Picts” table.
`
`computer-readable medium accessible
`
`to the computer system, the users of
`
`the computer system including a
`
`named user and an identifying user, the
`
`named user being different from the
`
`identifying user, the named user
`
`having naming information associated
`
`with a unique user identifier of the
`
`Line 52 of the “links.asp” code demonstrates unique
`
`user identifiers were also stored in a “People_In_Pict”
`
`table. Lines 82 & 89 demonstrates the
`
`“People_In_Pict” table is comprised of a “Person_ID”
`
`field and a “File_ID” field, corresponding to a user
`
`identifier and image identifier in the specifications
`
`Identifications database.
`
`named user;
`
`Exhibit 2012 demonstrates a code file
`
`(“messages_post.html”) which discloses receiving
`
`naming information from a user and storing a users
`
`database. On Line 25, the code presents a form to a
`
`user comprising an input field (line 38) that allows
`
`users to include naming information to the system.
`
`Upon submission of the form by clicking the submit
`
`button (line 64) the information is sent to web server at
`
`

`

`“_vti_bin/shtml.dll/messages_post.htm” (line 25) for
`
`insertion into a users database.
`
`in response to an input from the
`
`The code in “pictures.asp” shows selection of a picture
`
`identifying user indicating a selection
`
`via a hyperlink to a detail page using the image id at
`
`of an image, determining a unique
`
`line 108.
`
`image identifier corresponding to the
`
`image selected;
`
`The database “pictures.mdb” further details the field
`
`containing a hyperlink with an id.
`
`receiving, from the identifying
`
`Both the “pictures.mdb” database and the “links.asp”
`
`user, an input indicating a selection of
`
`code show a unique user identifier that would have
`
`the named user from a list of other
`
`referenced a users table. The “pictures.mdb” database
`
`users of the computer system, the list
`
`does this via a “people” column containing user
`
`of other users including naming
`
`identifiers.
`
`information previously provided by
`
`The users table listed all users populated input form
`
`other users, the list of other users
`
`allowing users to select from other users.
`
`including one or more users in a
`
`
`
`contact list associated with the
`
`The “links.asp” also demonstrates the storage of user
`
`identifying user, the identifying user’s
`
`identifiers from a “People_in_Pict” database.
`
`contact list including the named user;
`
`Since early testers would not have necessarily known
`
`in response to receiving from
`
`the identifiers of other users I had developed a
`
`the identifying user the input
`
`mechanism to select user from a list of other users
`
`indicating the selection of the named
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`present in the database. Additionally, the provisional
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`user from the list of other users,
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`application itself discloses that “the server also
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`determining a unique user identifier of
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`retrieves a list of users from the Users database (304)”
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`the named user;
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`and the “user information is transcribed into HTML
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`elements that enable the client to select a specific user
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`from the list of users (305)” See Ex-2017, pg. 4.
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`The concept of further filtering this input list to users in
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`a contact list to had been conceived at this point, and
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`was in development at the time of drafting the
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`provisional application from which this patent claims
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`priority. Additionally, the provisional application itself
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`discloses that “if the list of users is too large, one could
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`narrow it down by filtering other field(s), or in advanced
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`situations other databases.” See Ex-2017, pg. 4.
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`receiving, from the identifying
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`As demonstrated in Chris Malone’s declaration, I had
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`user, one or more inputs indicating a
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`conceived and been working toward a way to identify
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`set of coordinates corresponding to a
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`the location of users in photos by boxing their face (or
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`location of the named user within the
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`utilizing coordinates to correspond to the location of
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`image; and
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`the user within the photograph).
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`applying artificial intelligence
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`At the time of the invention, it was known in the
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`algorithms to image data of other
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`industry that algorithms could be applied to find
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`images accessible to said computer
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`additional images with matching facial characteristics
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`system to locate images matching
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`of a person once the person’s face had been located
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`characteristics of a subset of image
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`within an image. For example, as stated in the
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`data bound by the set of coordinates
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`specification of each of my patents, artificial
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`corresponding to the location of the
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`intelligence algorithms, or image recognition systems,
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`named user within the image, wherein
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`may be applied against images and utilized to further
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`the set of coordinates corresponding to
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`define characteristics of images, obtain identifying
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`the location of the named user within
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`the image is associated with the unique
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`information, and/or search a database for other
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`user identifier of the named user and
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`possible matches to a named object.
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`the unique image identifier.
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`16.
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`As further evidence of the continued pursuit the invention, Between August 27,
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`2000 and August 31, 2000, I made multiple purchases of web authoring software from
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`Macromedia (now part of Adobe) as shown in the American Express Statement, Exhibit 2014.
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`Macromedia software was a popular the web authoring software at the time and I used it to
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`continue to build upon the technologies I previously had developed the code in April of 2000 using
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`Microsoft FrontPage technologies, as discussed above. The website was operative and accessible
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`to test users (although not published publicly yet) before September 26, 2000. I would grant access
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`to friends and colleagues as test users so that they could register user profiles on the website and
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`assist in testing its functionality.
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`17.
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`On September 28, 2000, the website was up and running for user registration, as
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`demonstrated in Exhibit 2015. My September 28th email with Lisa Larson shows that by going to
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`the website, users could register at “www.sacko.com” (the website for the business that I ultimately
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`showcased the technology on) with a user profile.
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`18.
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`In summary, my statements herein and the documents concurrently submitted show
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`conception and reduction to practice of the claimed invention prior to September 26, 2000.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed on
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`2/15/2023
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`Mark Frigon
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