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`UNITED STATES PATENT AND TRADEMARK OFFICE
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`ONE WORLD TECHNOLOGIES, INC.,
`ONE WORLD TECHNOLOGIES, INC.,
`D/B/A TECHTRONIC INDUSTRIES POWER EQUIPMENT,
`D/B/A TECHTRONIC INDUSTRIES POWER EQUIPMENT,
`Petitioner,
`Petitioner,
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`v.
`v.
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`CHERVON (HK) LIMITED,
`CHERVON (HK) LIMITED,
`Patent Owner.
`Patent Owner.
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`Case Nos. IPR2020-00883, IPR2020-00884, IPR2020-00885,
`Case Nos. IPR2020-00883, IPR2020-00884, IPR2020-00885,
`IPR2020-00886, IPR2020-00887, IPR2020-00888,
`IPR2020-00886, IPR2020-00887, IPR2020-00888,
`PGR2020-00059, PGR2020-00060, PGR2020-00061
`PGR2020-00059, PGR2020-00060, PGR2020-00061
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`U.S. Patent Nos. 9,060,463, 9,596,806, 9,648,805, 9,826,686, 9,986,686, and
`U.S. Patent Nos. 9,060,463, 9,596,806, 9,648,805, 9,826,686, 9,986,686, and
`10,070,588; 10,477,772; 10,485,176; 10,524,420
`10,070,588; 10,477,772; 10,485,176; 10,524,420
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`DECLARATION OF LEE SOWELL
`DECLARATION OF LEE SOWELL
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`Mail Stop “PATENT BOARD”
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`United States Patent and Trademark Office
`P.O. Box 1450
`P.O. Box 1450
`Alexandria, VA 22313-1450
`Alexandria, VA 22313-1450
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`WEST\291668183.1
`WEST\291668183.1
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`TTI
`Exhibit 1036 — Page 1
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`TTI
`Exhibit 1036 – Page 1
`IPR2020-00885
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`

`

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`I, Lee Sowell, declare as follows:
`I, Lee Sowell, declare as follows:
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`1. My name is Lee Sowell. I am employed by One World Technologies, Inc.,
`1. My name is Lee Sowell. I am employed by One World Technologies, Inc.,
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`d/b/a Techtronic Industries Power Equipment, the Petitioner in this matter. My
`cVb/a Techtronic Industries Power Equipment, the Petitioner in this matter. My
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`title is Group President – Outdoor Power Equipment.
`title is Group President — Outdoor Power Equipment.
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`2.
`2.
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`I frequently refer to Techtronic Industries Power Equipment by the
`I frequently refer to Techtronic Industries Power Equipment by the
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`shorthand “TTi.” When I used the term “TTi” in my email to Mr. Clancy, I was
`shorthand "TTi." When I used the term "TTi" in my email to Mr. Clancy, I was
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`referring to my employer, One World Technologies, Inc., d/b/a Techtronic
`referring to my employer, One World Technologies, Inc., cVb/a Techtronic
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`Industries Power Equipment.
`Industries Power Equipment.
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`3.
`3.
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`I understand that One World Technologies, Inc. is a wholly owned
`I understand that One World Technologies, Inc. is a wholly owned
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`subsidiary of Techtronic Industries North America, Inc., which is a wholly owned
`subsidiary of Techtronic Industries North America, Inc., which is a wholly owned
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`subsidiary of Techtronic Industries Co. Ltd., a publicly traded company on the
`subsidiary of Techtronic Industries Co. Ltd., a publicly traded company on the
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`Hong Kong Stock Exchange. Homelite Consumer Products, Inc., is a wholly
`Hong Kong Stock Exchange. Homelite Consumer Products, Inc., is a wholly
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`owned subsidiary of Techtronic Industries North America, Inc.
`owned subsidiary of Techtronic Industries North America, Inc.
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`4.
`4.
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`The three companies I identified above—Techtronic Industries North
`The three companies I identified above—Techtronic Industries North
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`America, Inc., Techtronic Industries Co. Ltd., and Homelite Consumer Products,
`America, Inc., Techtronic Industries Co. Ltd., and Homelite Consumer Products,
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`Inc.—do not exercise control over the daily operations of One World
`Inc.—do not exercise control over the daily operations of One World
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`Technologies, Inc. One World Technologies, Inc. had no obligation to consult
`Technologies, Inc. One World Technologies, Inc. had no obligation to consult
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`with any of those three companies or obtain their permission to file the IPR and
`with any of those three companies or obtain their permission to file the IPR and
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`PGR petitions in this matter.
`PGR petitions in this matter.
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`//
`//
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`WEST\291668183.1
`WEST\291668183.1
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`TTI
`Exhibit 1036 — Page 2
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`TTI
`Exhibit 1036 – Page 2
`IPR2020-00885
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`I hereby declare that all statements made herein of my own knowledge are
`I hereby declare that all statements made herein of my own knowledge
` are
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`true and that all statements made on information and belief are believed to be true;
`true and that all statements
` made on information
` and belief
` are believed to be true;
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`and further that these statements are made with the knowledge that willful false
`and further
` that these statements
` are made with the knowledge
` that willful
` false
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`statements and the like so made are punishable by fine or imprisonment, or both,
`statements
` and the like so made are punishable
` by fine or imprisonment,
` or both,
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`under Section 1001 of Title 18 of the United States Code.
`under Section 1001 of Title 18 of the United States Code.
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`Dated:
`Dated:
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`?,/;c[>,,zo
`? 1a-62 402 0
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`Respectfully submitted,
`Respectfully
` submitted,
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`f,
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`Lee Sowell
`Lee Sowell
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`WES11291668183.1
`WESTS291668183.1
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`171
`Exhibit 1036 — Page 3
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`TTI
`Exhibit 1036 – Page 3
`IPR2020-00885
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