IPR2024-00084
`U.S. Patent 11,168,484
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`STRUCTURAL WRAP, LLC,
`Petitioner
`
`v.
`
`
`SYSTEM STORMSEAL PTY LTD, STORMSEAL USA, LLC,
`Patent Owner
`______________________
`Case IPR2024-00084
`Patent 11,168,484
`______________________
`
`DECLARATION OF SAYEM OSMAN
`
`
`
`
`
`
`Structural Wrap Exhibit 1024, Page 1
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`U.S. Patent 11,168,484
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`STRUCTURAL WRAP, LLC,
`Petitioner
`
`v.
`
`
`SYSTEM STORMSEAL PTY LTD, STORMSEAL USA, LLC,
`Patent Owner
`______________________
`Case IPR2024-00084
`Patent 11,168,484
`______________________
`
`DECLARATION OF SAYEM OSMAN
`
`
`
`
`
`
`Structural Wrap Exhibit 1024, Page 1
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`I, Sayem Osman, make the following Declaration pursuant to 28 U.S.C. § 1746:
`
`1.
`
`I am a paralegal at the law firm of Groombridge, Wu, Baughman & Stone
`
`LLP.
`
`2.
`
`I provide this Declaration in connection with the Petition for Inter Partes
`
`Review of U.S. Patent No. 11,168,484 in the above-captioned Inter Partes Review
`
`proceeding that is being requested at the U.S. Patent and Trademark Office by
`
`Petitioners under 35 U.S.C. §§ 311-319, 37 C.F.R. § 42. Unless otherwise stated,
`
`the facts stated in this Declaration are based on my personal knowledge.
`
`3.
`
`EX1001 hereto is a true and correct copy of United States Patent No.
`
`11,168,484, which I retrieved on October 20, 2023, from the United States Patent
`
`& Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/11168484).
`
`An exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1001 but no other alterations have been made.
`
`4.
`
`EX1002 hereto is a true and correct copy of the File History for United States
`
`Patent No. 11,168,484, which I retrieved on October 20, 2023, from the United
`
`States Patent & Trademark Office’s Patent Center website
`
`(https://patentcenter.uspto.gov/applications/15783813/ifw/docs?application=). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1002 but no other alterations have been made.
`
`Structural Wrap Exhibit 1024, Page 2
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`EX1004 hereto is a true and correct copy of United States Patent Pub. No.
`
`5.
`
`2005/0217202, which I retrieved on October 20, 2023, from the United States
`
`Patent & Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/20050217202).
`
`An exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1004 but no other alterations have been made.
`
`6.
`
`EX1005 hereto is a true and correct copy of United States Patent No.
`
`8,407,958, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/8407958). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1005 but no other alterations have been made.
`
`7.
`
`EX1006 hereto is a true and correct copy of United States Patent No.
`
`6,851,229, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/6851229). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1006 but no other alterations have been made.
`
`8.
`
`EX1007 hereto is a true and correct copy of United States Patent No.
`
`7,951,873, which I retrieved on October 20, 2023, from the United States Patent &
`
`Structural Wrap Exhibit 1024, Page 3
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/7951873). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1007 but no other alterations have been made.
`
`9.
`
`EX1008 hereto is a true and correct copy of United States Patent No.
`
`6,206,991, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/6206991). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1008 but no other alterations have been made.
`
`10. EX1009 hereto is a true and correct copy of United States Patent No.
`
`6,425,213, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/6425213). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1009 but no other alterations have been made.
`
`11. EX1010 hereto is a true and correct copy of United States Patent No.
`
`7,517,941, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/7517941). An
`
`Structural Wrap Exhibit 1024, Page 4
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1010 but no other alterations have been made.
`
`12. EX1011 hereto is a true and correct copy of the File History for United States
`
`Application No. 17/519,787, which I retrieved on October 26, 2023, from the
`
`United States Patent & Trademark Office’s Patent Center website
`
`(https://patentcenter.uspto.gov/applications/17519787/ifw/docs?application=). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1011 but no other alterations have been made.
`
`13. EX1012 hereto is a true and correct copy of the File History for United States
`
`Application No. 17/977,136, which I retrieved on October 20, 2023, from the
`
`United States Patent & Trademark Office’s Patent Center website
`
`(https://patentcenter.uspto.gov/applications/17977136/ifw/docs?application=). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1012 but no other alterations have been made.
`
`14. EX1013 hereto is a true and correct copy of United States Patent No.
`
`9,822,536, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/9822536). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1013 but no other alterations have been made.
`
`Structural Wrap Exhibit 1024, Page 5
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`15. EX1014 hereto is a true and correct copy of the File History for United States
`
`Patent No. 9,822,536, which I retrieved on October 20, 2023, from the United
`
`States Patent & Trademark Office’s Patent Center website
`
`(https://patentcenter.uspto.gov/applications/12995966/ifw/docs?application=). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1014 but no other alterations have been made.
`
`16. EX1015 hereto is a true and correct copy of United States Patent Pub. No.
`
`2005/0279040, which I retrieved on October 20, 2023, from the United States
`
`Patent & Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/20050279040).
`
`An exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1015 but no other alterations have been made.
`
`17. EX1017 hereto is an excerpt of a true copy of the March 2005 issue of “This
`
`Old House” magazine, which I retrieved on October 25, 2023, from
`
`https://archive.org/details/This-Old-House-Magazine-2005-03/page/n17/mode/2up.
`
`Other than excerpting the pages and adding an exhibit label and page numbers to
`
`the bottom of all pages of EX1017, no other alterations have been made.
`
`18. EX1018 hereto is a true copy of an excerpted page from Nathaniel E. Frank-
`
`White's affidavit dated September 9, 2023, in reference to a Tarp Country’s
`
`webpage titled, “Blue Roof Tarps.” Other than excerpting the page and adding an
`
`Structural Wrap Exhibit 1024, Page 6
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`exhibit label and page numbers to the bottom of all pages of EX1018, no other
`
`alterations have been made.
`
`19. EX1019 hereto is a true and correct copy of Oxfam’s guide titled “Plastic
`
`Sheeting,” which I retrieved on October 20, 2023 from https://policy-
`
`practice.oxfam.org/resources/plastic-sheeting-a-guide-to-the-specification-and-use-
`
`of-plastic-sheeting-in-hu-126734/. An exhibit label and page numbers have been
`
`added to the bottom of all pages of EX1019 but no other alterations have been
`
`made.
`
`20. EX1020 hereto is a true copy of an excerpted pages from Nathaniel E. Frank-
`
`White's affidavit dated September 9, 2023, in reference to Emergency Management
`
`Australia’s manual titled, “Storm and Water Damage Operations,” Third Edition
`
`(2007). Other than excerpting the pages and adding an exhibit label and page
`
`numbers to the bottom of all pages of EX1020, no other alterations have been
`
`made.
`
`21. EX1021 hereto is a true copy of an excerpted page from Nathaniel E. Frank-
`
`White's affidavit dated September 9, 2023, in reference to Americover’s webpage
`
`titled, “Heat Shrink Wrap.” Other than excerpting the page and adding an exhibit
`
`label and page numbers to the bottom of all pages of EX1021, no other alterations
`
`have been made.
`
`Structural Wrap Exhibit 1024, Page 7
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`22. EX1031 hereto is a true and correct copy of the File History for United States
`
`Application Publication No. 2002/0095898, which I retrieved on October 20, 2023,
`
`from the United States Patent & Trademark Office’s Patent Public Search Basic
`
`(PPUBS Basic) website (https://image-ppubs.uspto.gov/dirsearch-
`
`public/print/downloadPdf/20020095898). An exhibit label and page numbers have
`
`been added to the bottom of all pages of EX1031 but no other alterations have been
`
`made.
`
`23. EX1032 hereto is a true and correct copy of WO2004/022646 which I
`
`retrieved on October 20, 2023, from
`
`https://patentscope.wipo.int/search/docs2/pct/WO2004022646/pdf/qbcPuzDtCgg_F
`
`5QRLgTgXPyYLfBPpK_mCddle1G2Dp4. An exhibit label and page numbers
`
`have been added to the bottom of all pages of EX1032 but no other alterations have
`
`been made.
`
`24. EX1033 hereto is a true and correct copy of United States Patent No.
`
`4,247,509, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/4247509). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1033 but no other alterations have been made.
`
`Structural Wrap Exhibit 1024, Page 8
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`25. EX1034 hereto is a true and correct copy of United States Patent No.
`
`4,763,783, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/4763783). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1034 but no other alterations have been made.
`
`26. EX1035 hereto is a true and correct copy of United States Patent No.
`
`4,715,915, which I retrieved on October 20, 2023, from the United States Patent &
`
`Trademark Office’s Patent Public Search Basic (PPUBS Basic) website
`
`(https://image-ppubs.uspto.gov/dirsearch-public/print/downloadPdf/4715915). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1035 but no other alterations have been made.
`
`27. EX1036 hereto is a true and correct copy of the Complaint (Dkt. 1, Nov. 04,
`
`2022), in Stormseal USA, LLC v. ABC Supply Co. Inc., et al. No. 9:22-cv-81726-
`
`AHS. I retrieved this exhibit on October 20, 2023, from
`
`https://www.docketalarm.com/cases/Florida_Southern_District_Court/9--22-cv-
`
`81726/Stormseal_USA_LLC_et_al_v._ABC_Supply_Co._Inc._et_al/1/. An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1036 but no other alterations have been made.
`
`Structural Wrap Exhibit 1024, Page 9
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`28. EX1038 hereto is a true and correct excerpted copy of the book Handbook of
`
`Plastic Films, Rapra Technology Limited (2003). I requested a copy of the book
`
`from the Library of Congress through third-party vendor BEADOX LLC on
`
`October 10, 2023, and received the book on October 11, 2023. I sent the copy of
`
`the book via FedEx on October 11, 2023 to Chieh-Ming Hsu.
`
`29. EX1039 hereto is a true and correct excerpted copy of the book Plastics
`
`Films by John H. Briston, Third Edition (1989). I requested a copy of the book
`
`from the Library of Congress through third-party vendor BEADOX LLC on
`
`October 10, 2023, and received the book on October 11, 2023. I sent the copy of
`
`the book via FedEx on October 11, 2023 to Chieh-Ming Hsu.
`
`30. EX1040 hereto is a true copy of an excerpted page from Nathaniel E. Frank-
`
`White's affidavit dated September 9, 2023, in reference to Americover’s webpage
`
`titled, “Heat Shrink Wrap FAQ.” Other than excerpting the page and adding an
`
`exhibit label and page numbers to the bottom of all pages of EX1040, no other
`
`alterations have been made.
`
`31. EX1041 hereto is a true copy of the Catalog Record and MARC Record
`
`from the Library of Congress for Rapra Technology Ltd.’s book titled "Handbook
`
`of Plastic Films" (2003) (EX1038), available at
`
`https://catalog.loc.gov/vwebv/holdingsInfo?searchId=16736&recPointer=0&recCo
`
`unt=25&searchType=1&bibId=14728615, and
`
`Structural Wrap Exhibit 1024, Page 10
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`https://catalog.loc.gov/vwebv/staffView?searchId=16736&recPointer=0&recCount
`
`=25&searchType=1&bibId=14728615 which I retrieved on October 24, 2023.
`
`An exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1041 but no other alterations have been made.
`
`32. EX1042 hereto is a true copy of the Catalog Record and MARC Record
`
`from the Library of Congress John H. Briston’s book titled "Plastics Films" Third
`
`Edition (1989) (EX1039), available at
`
`https://catalog.loc.gov/vwebv/holdingsInfo?searchId=472&recPointer=0&recCoun
`
`t=25&searchType=1&bibId=4801995, and
`
`https://catalog.loc.gov/vwebv/staffView?searchId=472&recPointer=0&recCount=2
`
`5&searchType=1&bibId=4801995 which I retrieved on October 24, 2023.
`
`An exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1042 but no other alterations have been made.
`
`33. EX1044 hereto is a true and correct copy of Fine Homebuilding’s
`
`Discussion Forum, which I retrieved on October 21, 2023 from
`
`https://www.finehomebuilding.com/forum/temporary-12-month-roof-covering. An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1044 but no other alterations have been made.
`
`34. EX1045 hereto is a true and correct copy of Library of Congress borrow
`
`record for the book Handbook of Plastic Films, Rapra Technology Limited (2003)
`
`Structural Wrap Exhibit 1024, Page 11
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`(EX1038). The borrow record was included when I received the book on October
`
`11, 2023, which I had requested from the Library of Congress through third-party
`
`vendor BEADOX LLC on October 10, 2023. I sent the borrow record and the copy
`
`of the book via FedEx on October 11, 2023 to Chieh-Ming Hsu.
`
`35. EX1046 hereto is a true and correct copy of Library of Congress borrow
`
`record for the book Plastics Films by John H. Briston, Third Edition (1989)
`
`(EX1039). The borrow record was included when I received the book on October
`
`11, 2023, which I had requested from the Library of Congress through third-party
`
`vendor BEADOX LLC on October 10, 2023. I sent the borrow record and the copy
`
`of the book via FedEx on October 11, 2023 to Chieh-Ming Hsu.
`
`36. EX1048 hereto is a true and correct copy of the File History for United
`
`States Patent No. 10,472,827, which I retrieved on October 25, 2023, from the
`
`United States Patent & Trademark Office’s Patent Center website
`
`(https://patentcenter.uspto.gov/applications/16294554/ifw/docs?application=). An
`
`exhibit label and page numbers have been added to the bottom of all pages of
`
`EX1048 but no other alterations have been made.
`
`37.
`
`I have been warned that willful false statements and the like are punishable
`
`by fine or imprisonment, or both. I make this declaration of my own personal
`
`knowledge, and all statements are true. If called to testify as to the truth of the
`
`matters stated herein, I could and would testify competently.
`
`Structural Wrap Exhibit 1024, Page 12
`Structural Wrap v Stormseal, IPR2024-00084
`
`
`
`IPR2024-00084
`U.S. Patent 11,168,484
`I declare under penalty of perjury that the foregoing is true and correct.
`
`38.
`
`Executed on this 28th day of October, 2023, at Washington, D.C.
`
`
`
` /Sayem Osman/
`
` Sayem Osman
`
`Structural Wrap Exhibit 1024, Page 13
`Structural Wrap v Stormseal, IPR2024-00084
`
`
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