`Patent No. 12,134,952
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`Intelligent Wellhead Systems, Inc.
`Petitioner,
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`v.
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`Downing Wellhead Equipment, LLC
`Patent Owner
`____________
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`PGR2025-00002
`Patent No. 12,134,952
`____________
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`DECLARATION OF LISA E. MARGONIS
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`IWS EXHIBIT 1035
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`EX_1035_001
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`Case PGR2025-00002
`Patent 12,134,952
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`I, Lisa E. Margonis, hereby declare as follows:
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`1.
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`I am a Partner at the law firm Osha Bergman Watanabe & Burton LLP.
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`I have personal knowledge of the facts stated herein and if called as a witness, could
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`testify thereto.
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`2.
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`I am over the age of twenty-one (21) years, of sound mind, and in all
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`respects competent to testify. The facts stated herein are true, correct and within my
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`personal knowledge, and my statements are made with the knowledge that willful
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`false statements and the like so made are punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`3.
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`On August 7, 2024, I opened Downing’s publicly available Facebook
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`page
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`titled “Downing – Energy Forward” at https://www.facebook.com/
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`downing.us/.
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`4.
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`On August 7, 2024, Downing’s Facebook page contained a timeline
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`with multiple posts sorted by date of posting, with the most recent Facebook post at
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`the time dated July 30, 2024.
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`5.
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`On August 7, 2024, I preserved Downing’s Facebook timeline using
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`the Screen Recorder Google Chrome browser extension.1 The screen recording
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`captures a view as I scrolled down Downing’s Facebook timeline until arriving at a
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`1 Available at https://chromewebstore.google.com/detail/screen-recorder/hniebljp
`gcogalllopnjokppmgbhaden?hl=en&pli=1
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`1
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`IWS EXHIBIT 1035
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`EX_1035_002
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`Case PGR2025-00002
`Patent 12,134,952
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`post by Downing dated August 27, 2019, which included a video titled FS
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`Completion System: How it Works. This screen recording memorializes how
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`Downing’s Facebook timeline appeared on August 7, 2024, including Downing’s
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`Facebook post from August 27, 2019, and the video titled FS Completion System:
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`How it Works, which was published in that August 27, 2019 Facebook post.
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`6.
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`Exhibit 1033 is a true and correct copy of the screen recording
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`described above.
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`7.
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`On November 6, 2024, I opened a free YouTube transcript generator,
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`available at https://tactiq.io/tools/youtube-transcript. I then entered into the “Enter
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`YouTube URL” box the URL https://www.youtube.com/watch?v=X0m9DcnZczE,
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`for the YouTube video from Downing’s YouTube channel titled FS Completion
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`System: How it Works which is dated March 5, 2019. I then clicked “Get Video
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`Transcript” to obtain a generated transcript.
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`8.
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`I confirmed the accuracy of the generated transcript by comparing the
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`generated transcript to the audio of the YouTube video titled FS Completion System:
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`How it Works, referenced above.
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`9.
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`Exhibit 1034 is a true and correct copy of the generated transcript with
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`corrections to punctuation, capitalization, and obvious transcription errors based on
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`my comparison.
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`IWS EXHIBIT 1035
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`EX_1035_003
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`Case PGR2025-00002
`Patent 12,134,952
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`I declare under penalty of perjury under the laws of the United States of
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`America that the foregoing is true and correct.
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`Date: November 6, 2024
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`Signed:
`Lisa E. Margonis
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`3
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`IWS EXHIBIT 1035
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`EX_1035_004
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