`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`DYNAENERGETICS EUROPE GMBH and
`DYNAENERGETICS US, INC.
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`Petitioner
`
`v.
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`QINETIQ LIMITED
`
`Patent Owner
`____________
`
`
`Case: PGR2023-00003
`Patent No. 11,215,039
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`____________
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`DECLARATION OF ELIZABETH FULLER
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`DynaEnergetics Europe GmbH
`Ex. 1017
`Page 1 of 4
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`PGR2022-
`U.S. Patent No. 11,215,039
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`I, Elizabeth Fuller, being over the age of 18 and competent to make the
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`
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`declarations herein, do hereby declare that:
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`1.
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`I am a paralegal in the law firm of Moyles IP, LLC, working under
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`supervision of Lisa J. Moyles, lead counsel for Petitioners DynaEnergetics Europe
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`GmbH and DynaEnergetics US, Inc., in the matter of this post-grant review of U.S.
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`Patent 11,215,039. I have personal knowledge of the facts set forth herein and could
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`competently testify to the statements made herein.
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`2.
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`Exhibit 1007 is an accurate copy of an article by Clinton C.
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`Quattlebaum, Kenneth Lee Borgen, Zhenyu Xue, and Peter B. Wilkinson entitled
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`Optimizing Perforating Charge Design for Stimulation and dated October 2012 that
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`I
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`obtained
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`at
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`https://www.researchgate.net/publication/267461122_
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`Optimizing_Perforating_Charge_Design_for_Stimulation on August 31, 2022.
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`3.
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`Exhibit 1009 is an accurate copy of a presentation by David Davison
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`and Dan Pratt entitled A Hydrocode-Designed well Perforator with Exceptional
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`Performance from the 17th International Symposium on Ballistics in Midrand, South
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`Africa
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`and
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`dated
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`March
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`1998
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`that
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`I
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`obtained
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`at
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`http://www.shocktrans.com/DownloadableFiles/STI.BlastingSymposium.1998.pdf
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`on August 31, 2022.
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`DynaEnergetics Europe GmbH
`Ex. 1017
`Page 2 of 4
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`
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`PGR2022-
`U.S. Patent No. 11,215,039
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`Exhibit 1014 is an accurate copy of a book by William P. Walters and
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`4.
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`Jonas A. Zukas entitled Fundamentals of Shaped Charges and dated October 2012
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`that I reviewed in hard copy on August 31, 2022.
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`5.
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`Exhibit 1015 is an accurate copy of a paper presented at the SPE
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`European Formation Damage Conference, The Hague, Netherlands by P.S. Smith,
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`L.A. Behrmann, and Wenbo Yang entitled Improvements
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`in Perforating
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`Performance in High Compressive Strength Rocks and dated June 2, 1997 that I
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`obtained
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`at
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`https://onepetro.org/SPEEFDC/proceedings-abstract/97EFDC/All-
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`97EFDC/SPE-38141-MS/188624 on August 31, 2022.
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`6.
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`Exhibit 1016 is an accurate copy of a published thesis submitted for the
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`degree of Doctor of Philosophy entitled Penetration of a Shaped Charge by Chris
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`Poole
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`that
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`I obtained at https://core.ac.uk/download/pdf/40087594.pdf on
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`September 30, 2022.
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`DynaEnergetics Europe GmbH
`Ex. 1017
`Page 3 of 4
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`PGR2022-
`U.S. Patent No. 11,215,039
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`I hereby declare that all statements of my knowledge made in this declaration are
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`true and that these statements were made with the knowledge that willful false
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`statements and the like are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`Dated: October 4, 2022
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`Elizabeth Fuller
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`DynaEnergetics Europe GmbH
`Ex. 1017
`Page 4 of 4
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