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
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`v.
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`SYSTEM STORMSEAL PTY LTD, STORMSEAL USA, LLC,
`Patent Owner
`______________________
`Case IPR2024-00084
`Patent 11,168,484
`______________________
`
`DECLARATION OF CHIEH-MING HSU
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`Structural Wrap Exhibit 1052, Page 1
`Structural Wrap v Stormseal, IPR2024-00084
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`IPR2024-00084
`U.S. Patent 11,168,484
`I, Chieh-Ming Hsu, make the following Declaration pursuant to 28 U.S.C. § 1746:
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`1.
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`I am an associate at the law firm of Groombridge, Wu, Baughman & Stone
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`LLP.
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`2.
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`I provide this Declaration in connection with the Petition for Inter Partes
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`Review of U.S. Patent No. 11,168,484 in the above-captioned Inter Partes Review
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`proceeding that is being requested at the U.S. Patent and Trademark Office by
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`Petitioners under 35 U.S.C. §§ 311-319, 37 C.F.R. § 42. Unless otherwise stated,
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`the facts stated in this Declaration are based on my personal knowledge.
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`3.
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`EX1037 hereto is a true and correct copy of a transcript of EX1016, a screen
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`recording of a YouTube video entitled “Tarp Your Roof.” I submitted a request to
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`create a transcript to the court reports at Planet Depos on September 11, 2023, and
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`I received the transcript on September 18, 2023. I reviewed the transcript and
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`confirmed that it accurately reflects the content of EX1016. An exhibit label and
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`page numbers have been added to the bottom of all pages of EX1037 but no other
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`alterations have been made.
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`4.
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`EX1038 hereto is a true and correct excerpted copy of the book Handbook of
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`Plastic Films, Rapra Technology Limited (2003). I obtained a copy of the book
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`from Sayem Osman on October 12, 2023 after he mailed the book to me. After
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`receiving the book, I directed Bijan Khaghani, paralegal, to make scanned copies
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`of the book. I reviewed the scanned copy and confirmed that it accurately reflects
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`Structural Wrap Exhibit 1052, Page 2
`Structural Wrap v Stormseal, IPR2024-00084
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`IPR2024-00084
`U.S. Patent 11,168,484
`the original book. An exhibit label and page numbers have been added to the
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`bottom of all pages of EX1038 but no other alterations have been made.
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`5.
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`EX1039 hereto is a true and correct excerpted copy of the book Plastics
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`Films by John H. Briston, Third Edition (1989). I obtained a copy of the book
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`from Sayem Osman on October 12, 2023 after he mailed the book to me. After
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`receiving the book, I directed Bijan Khaghani, paralegal, to make scanned copies
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`of the book. I reviewed the scanned copy and confirmed that it accurately reflects
`
`the original book. An exhibit label and page numbers have been added to the
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`bottom of all pages of EX1039 but no other alterations have been made.
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`6.
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`EX1045 hereto is a true and correct copy of the Library of Congress borrow
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`record for the book Handbook of Plastic Films, Rapra Technology Limited (2003).
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`I obtained a copy of the record from Sayem Osman on October 12, 2023 after he
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`mailed the record to me. After receiving the record, I directed Bijan Khaghani,
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`paralegal, to make scanned copies of the record. I reviewed the scanned copy and
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`confirmed that it accurately reflects the original record. An exhibit label and page
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`numbers have been added to the bottom of all pages of EX1045 but no other
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`alterations have been made.
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`7.
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`EX1046 hereto is a true and correct copy of the Library of Congress borrow
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`record for the book Plastics Films by John H. Briston, Third Edition (1989). I
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`obtained a copy of the record from Sayem Osman on October 12, 2023 after he
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`Structural Wrap Exhibit 1052, Page 3
`Structural Wrap v Stormseal, IPR2024-00084
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`IPR2024-00084
`U.S. Patent 11,168,484
`mailed the record to me. After receiving the record, I directed Bijan Khaghani,
`
`paralegal, to make scanned copies of the record. I reviewed the scanned copy and
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`confirmed that it accurately reflects the original record. An exhibit label and page
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`numbers have been added to the bottom of all pages of EX1046 but no other
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`alterations have been made.
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`8.
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`EX1047 hereto is a true and correct excerpted copy of the book Plastics
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`Films by John H. Briston, Third Edition (1990 Reprint). I obtained a copy of the
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`book from Dr. Yash P. Khanna after he mailed the book to me. After receiving the
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`book, I directed Bijan Khaghani, paralegal, to make scanned copies of the book. I
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`reviewed the scanned copy and confirmed that it accurately reflects the original
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`book. An exhibit label and page numbers have been added to the bottom of all
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`pages of EX1047 but no other alterations have been made.
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`9.
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`I have been warned that willful false statements and the like are punishable
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`by fine or imprisonment, or both. I make this declaration of my own personal
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`knowledge, and all statements are true. If called to testify as to the truth of the
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`matters stated herein, I could and would testify competently.
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`Structural Wrap Exhibit 1052, Page 4
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`IPR2024-00084
`U.S. Patent 11,168,484
`I declare under penalty of perjury that the foregoing is true and correct.
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`10.
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`Executed on this 28th day of October, 2023, at New York, New York.
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`/Chieh-Ming Hsu/
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`Chieh-Ming Hsu
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`Structural Wrap Exhibit 1052, Page 5
`Structural Wrap v Stormseal, IPR2024-00084
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