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Case PGR2025-00002
`Patent No. 12,134,952
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`Intelligent Wellhead Systems, Inc.
`Petitioner,
`
`v.
`
`Downing Wellhead Equipment, LLC
`Patent Owner
`____________
`
`PGR2025-00002
`Patent No. 12,134,952
`____________
`
`
`
`DECLARATION OF LISA E. MARGONIS
`
`
`
`
`IWS EXHIBIT 1035
`
`EX_1035_001
`
`

`

`Case PGR2025-00002
`Patent 12,134,952
`
`
`I, Lisa E. Margonis, hereby declare as follows:
`
`1.
`
`I am a Partner at the law firm Osha Bergman Watanabe & Burton LLP.
`
`I have personal knowledge of the facts stated herein and if called as a witness, could
`
`testify thereto.
`
`2.
`
`I am over the age of twenty-one (21) years, of sound mind, and in all
`
`respects competent to testify. The facts stated herein are true, correct and within my
`
`personal knowledge, and my statements are made with the knowledge that willful
`
`false statements and the like so made are punishable by fine or imprisonment, or
`
`both, under Section 1001 of Title 18 of the United States Code.
`
`3.
`
`On August 7, 2024, I opened Downing’s publicly available Facebook
`
`page
`
`titled “Downing – Energy Forward” at https://www.facebook.com/
`
`downing.us/.
`
`4.
`
`On August 7, 2024, Downing’s Facebook page contained a timeline
`
`with multiple posts sorted by date of posting, with the most recent Facebook post at
`
`the time dated July 30, 2024.
`
`5.
`
`On August 7, 2024, I preserved Downing’s Facebook timeline using
`
`the Screen Recorder Google Chrome browser extension.1 The screen recording
`
`captures a view as I scrolled down Downing’s Facebook timeline until arriving at a
`
`
`1 Available at https://chromewebstore.google.com/detail/screen-recorder/hniebljp
`gcogalllopnjokppmgbhaden?hl=en&pli=1
`
`1
`
`
`
`IWS EXHIBIT 1035
`
`EX_1035_002
`
`

`

`Case PGR2025-00002
`Patent 12,134,952
`
`post by Downing dated August 27, 2019, which included a video titled FS
`
`Completion System: How it Works. This screen recording memorializes how
`
`Downing’s Facebook timeline appeared on August 7, 2024, including Downing’s
`
`Facebook post from August 27, 2019, and the video titled FS Completion System:
`
`How it Works, which was published in that August 27, 2019 Facebook post.
`
`6.
`
`Exhibit 1033 is a true and correct copy of the screen recording
`
`described above.
`
`7.
`
`On November 6, 2024, I opened a free YouTube transcript generator,
`
`available at https://tactiq.io/tools/youtube-transcript. I then entered into the “Enter
`
`YouTube URL” box the URL https://www.youtube.com/watch?v=X0m9DcnZczE,
`
`for the YouTube video from Downing’s YouTube channel titled FS Completion
`
`System: How it Works which is dated March 5, 2019. I then clicked “Get Video
`
`Transcript” to obtain a generated transcript.
`
`8.
`
`I confirmed the accuracy of the generated transcript by comparing the
`
`generated transcript to the audio of the YouTube video titled FS Completion System:
`
`How it Works, referenced above.
`
`9.
`
`Exhibit 1034 is a true and correct copy of the generated transcript with
`
`corrections to punctuation, capitalization, and obvious transcription errors based on
`
`my comparison.
`
`2
`
`
`
`IWS EXHIBIT 1035
`
`EX_1035_003
`
`

`

`Case PGR2025-00002
`Patent 12,134,952
`
`I declare under penalty of perjury under the laws of the United States of
`
`America that the foregoing is true and correct.
`
`Date: November 6, 2024
`
`Signed:
`Lisa E. Margonis
`
`3
`
`IWS EXHIBIT 1035
`
`EX_1035_004
`
`

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