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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`McClinton Energy Group L.L.C.
`Petitioner
`
`v.
`
`Magnum Oil Tools International, Ltd.
`Patent Owner
`_____________
`
`Case No. IPR2013-00231
`Patent 8,079,413
`_____________
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`PETITIONER’S REPLY TO PATENT OWNER’S RESPONSE
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`TABLE OF CONTENTS
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`Page
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`I. Statement of Relief Requested ............................................................................ 1
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`II. Background .......................................................................................................... 1
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`III. Introduction .......................................................................................................... 2
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`IV. Reply to Magnum’s Arguments In Response to The Petition ............................. 3
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`A. Lehr’s Deformable Release Device Is Located On The Inside
`Surface Of The Body ................................................................................. 3
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`B. The Combination of Lehr, Cockrell and Kristiansen Combines Prior
`Art Elements According To Known Methods to Yield the
`Predictable Result of an Insert That Is Screwed Into an Inner
`Surface of The Body of the Frac Plug. ...................................................... 5
`
`1. Magnum Focuses Its Argument On Lehr, And Ignores The
`Clear Teachings Of The Proposed Combination And The Well
`Known Prior Art.......................................................................... 7
`C. One Of Skill In The Art Would Combine Cockrell and Kristiansen
`With Lehr For The Same Reasons One Of Skill In The Art Would
`Combine Cockrell and Kristiansen With Alpha ........................................ 9
`
`1.
`2.
`
`Simple Substitution for Lehr and Alpha ..................................... 9
`The Modifications To Lehr Are Well Known, Interchangeable
`Methods That Are Well Within Reason Of One Of Skill In The
`Art. ............................................................................................ 11
`D. The Response Improperly Attempts To Incorporate The Arguments
`From Magnum’s Preliminary Response By Reference ........................... 12
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`E. Magnum’s Secondary Indicia of Non-Obviousness Arguments Are
`Not Supported by the Record .................................................................. 12
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`F. Magnum Does Not Contest That the Combinations On Review
`Render Claims 2-20 Obvious, If Claim 1 Is Found Obvious. ................. 13
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`G. The Claim Construction Issue Identified By Magnum Is Consistent
`With The Broadest Reasonable Interpretation Standard. ........................ 14
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`V. Conclusion ......................................................................................................... 14
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`ii
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
`KSR 550 U.S. 416 ...................................................................................................... 5
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`Federal Statutes
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`35 U.S.C. § 103(a) ..................................................................................................... 1
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`Regulations
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`37 C.F.R. 42.6(a)(3) ................................................................................................. 11
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`37 C.F.R. 42.63(a) .............................................................................................. 11, 12
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`iii
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`I.
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`Statement of Relief Requested
`McClinton Energy Group L.L.C. (“Petitioner” or “McClinton”) respectfully
`
`requests that claims 1 to 20 of U.S. Patent No. 8,079,413 (“the ’413 Patent,”
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`Exhibit 1001) be canceled on the grounds in the September 23, 2013 Decision
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`instituting inter partes review (“Decision”).
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`II. Background
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`McClinton’s Petition set forth a prima facie case for invalidity of claims 1-
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`20 of the ‘413 Patent under 35 U.S.C. § 103(a) on multiple grounds. The Board
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`found that the Petition likely demonstrates that:
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`(1) claims 1-3, 5-8, 12, and 13 are unpatentable over the combination of
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`Lehr, Cockrell, and Kristiansen;
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`(2) claims 4 and 9-11 are unpatentable over the combination of Lehr,
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`Cockrell, Kristiansen, and Slup;
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`(3) claims 14 and 16 are unpatentable over the combination of Lehr,
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`Cockrell, Kristiansen, and Streich;
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`(4) claim 15 is unpatentable over the combination of Lehr, Cockrell,
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`Kristiansen, Streich, and McKeachnie;
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`(5) claims 17-19 are unpatentable over the combination of Lehr, Cockrell,
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`Kristiansen, Slup, and Streich; and
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`1
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`(6) claim 20 is unpatentable over the combination of Lehr, Cockrell,
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`Kristiansen, Slup, Streich, and McKeachnie.”
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`(See Decision, pp. 25-26).
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`III.
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`Introduction
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`Magnum’s Response attempts to overcome the Petition and the Board’s
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`Decision with three conclusory arguments, each of which was already addressed
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`by the Petition and the Board: (1) Magnum argues that Lehr’s deformable release
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`device is not inside the body of the plug disclosed in Lehr; (2) Magnum argues that
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`Lehr would require modification in order to meet all of the elements of the claims;
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`(3) Magnum argues that the motivation to combine secondary references with Lehr
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`would somehow be different than with Alpha – i.e., the “redundant” reference.
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`(Response at pp. 19-28).
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`Magnum’s arguments are not new and fail to overcome the prima facie
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`showing of the Petition and the analysis set forth in the Board’s Decision.
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`Accordingly, no rebuttal is necessary. Nevertheless, as summarized here and
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`explained in further detail below, each of Magnum’s arguments is flawed. First,
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`Magnum’s expert admitted at his deposition that under the agreed claim
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`construction for “body,” Lehr’s deformable release device “is inside the body.”
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`(Ex. 1026 at 40:17-41:4). His testimony is consistent with the Board’s Decision
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`and directly contradicts Magnum’s lead argument in its Response. (See Board’s
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`Decision at p. 23) (“one with ordinary skill in the art would have appreciated that
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`the deformable release member 30 is capable of being retained against or disposed
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`within the inner surface of the body of the frac plug”). Second, Magnum still fails
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`to acknowledge that “the test [for unpatentability based on obviousness] is what
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`the combined teachings of the references would have suggested to one with
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`ordinary skill in the art.” (See Board’s Decision at p. 21). Magnum again focuses
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`much of its argument on Lehr alone, without due consideration to the combination
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`set forth in the Petition and discussed in the Board’s Decision. (Response at p. 21-
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`25). Where Magnum does address the combination, its assertions are predicated
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`on its erroneous assertion that Lehr’s deformable release is not inside the body of
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`the plug. (Response at pp. 22-27). Third, contrary to Magnum’s argument, the
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`Petition unquestionably set forth the reasons why it would have been obvious to
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`combine Lehr with Cockrell and Kristiansen. Indeed, the Board’s Decision
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`confirmed McClinton’s assertions that one of skill in the art would have the same
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`motivation to modify and would look to the same secondary prior art references
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`regardless of whether the lead reference is Lehr or Alpha. (Decision at pp. 20-21).
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`IV. Reply to Magnum’s Arguments In Response to The Petition
`A. Lehr’s Deformable Release Device Is Located On The Inside
`Surface Of The Body
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`Magnum, at the outset of its Response, argues that “the deformable release
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`member 30 [of Lehr] is not located within an inner surface of the plug body or
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`otherwise made to attach or secure to the inner surface of the plug body.”
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`(Response at p. 21). Magnum relies entirely on Figure 3A in its argument. (Id).
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`Magnum ignores Figures 1, 4A and 4B, all of which show the “deformable release
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`member 30” inside the “body” of the plug. As shown in Figure 4A below, it is
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`undisputed that, under the proper construction of “body,” the entirety of the red
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`shaded area is part of the “body” of Lehr’s plug.
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`(See Ex. 1007 at Figs. 1, 4A, 4B). It is also clear that “the deformable release
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`member 30” of Lehr is attached to an inner surface of the “body”– i.e., the red
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`shaded area–of Lehr. Petitioner stressed this in its Petition. (See Petition at pp. 44-
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`47). Further, in support of the Petition, McClinton’s expert, Dr. Wooley,
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`corroborated Petitioner’s position with citations to the relevant passages and
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`Figures of Lehr. (See Ex. 1020 at pp. 59-60). Finally, the Board already rejected
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`Magnum’s argument. (Decision at p. 23). During cross-examination, Magnum’s
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`expert conceded that the deformable release member 30 is inside the body of Lehr.
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`(Ex. 1026 at 40:17-41:4). Magnum’s argument, therefore, is not supported by the
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`evidence of record including its own expert witness.
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`B.
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`The Combination of Lehr, Cockrell and Kristiansen Combines
`Prior Art Elements According To Known Methods to Yield the
`Predictable Result of an Insert That Is Screwed Into an Inner
`Surface of The Body of the Frac Plug.
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`The Board already acknowledged the Petition’s thorough explanation that
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`“placing Kristiansen’s threads on both the outer surface of Lehr’s deformable
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`release device 30 and the inner surface of the frac plug combines prior art elements
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`according to known methods to yield the predictable result of an insert that is
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`screwed into an inner surface of the body of the frac plug in order to hold it in
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`place for the purpose of simplifying assembly. See id.; see also KSR, 550 U.S. at
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`416.” (See Decision at 24-25).
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`The failure of Magnum’s argument regarding the location of Lehr’s
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`“deformable release member 30” leaves it with little reason to dispute that one of
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`skill in the art would have simply and predictably used the references identified by
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`McClinton to arrive at the claimed invention.
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`For instance, Magnum’s argument that “the proposed modifications to Lehr
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`would require a major redesign of Lehr,” is predicated on the assertion that “[t]he
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`location of the deformable release member 30 is important” and “[s]ince claim 1
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`requires the insert to be screwed in an inner surface of the body, Lehr would have
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`to be substantially redesigned to place the deformable release member 30 inside
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`the body of the plug.” (Response at pp. 24-25). Yet, Magnum’s expert agrees that
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`the deformable release member 30 is already inside the body of Lehr and thus Lehr
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`would not need to be modified to accommodate an insert “inside the body of the
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`plug.” (See Ex. 1026 at 40:17-41:4; see also Response at p. 24).
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`Likewise, Magnum’s argument that “the proposed redesign of Lehr in view
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`of Cockrell and Kristiansen provides no expectation of success” is predicated on
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`the erroneous conclusion that “Lehr provides no guidance or enablement for
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`replacing its release member 30 that deforms against the end of the plug body with
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`an insert that is located instead within the body.” (Response at pp. 25-26). As
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`discussed in the Petition, at Magnum’s expert’s deposition, and above, Lehr’s
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`deformable release member is inside the plug body. (See Petition at pp. 44-47; Ex.
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`1026 at 40:17-41:4).
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`Aside from arguing about the position of the insert of Lehr, Magnum merely
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`regurgitates its argument from its Preliminary Response regarding modifications to
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`Lehr. (See Response pp. 24-25). The Board already contemplated and rejected
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`Magnum’s unpersuasive arguments in its Decision. (See Decision at p. 23).
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`While acknowledging the explicit purpose of Lehr at pp. 26-27 of its
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`Response, Magnum avoids addressing the following passage from Lehr which
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`explains the purpose of its insert: “to provide a release device for an adapter kit
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`that reduces the need to drill holes into the packer assembly and the adapter kit.”
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`(Ex. 1007 at [0013]). Importantly, the shearable thread setting mechanisms of
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`Cockrell and Kristiansen accomplish exactly that in the exact manner suggested by
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`Lehr. Specifically, as identified in the Petition, the insert of Cockrell screws into
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`the body and does not require additional holes to be drilled into the assembly. (See
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`Petition at pp. 29-31). Likewise, as identified in the Petition, the insert of
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`Kristiansen screws into the body and does not require additional holes to be drilled
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`into the assembly. (Id. at 32-33).
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`1. Magnum Focuses Its Argument On Lehr, And Ignores The
`Clear Teachings Of The Proposed Combination And The
`Well Known Prior Art
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`Because Magnum cannot dispute that the Lehr, Cockrell, Kristiansen
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`combination teaches all of the claimed elements, Magnum focuses on the alleged
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`deficiencies of Lehr alone. (Response at pp. 22-28). Importantly, Magnum’s
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`Response ignores the basic argument of the Petition that the shearable or
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`deformable mechanisms by which a setting tool is engaged in a plug were very
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`well known and very well known to be interchangeable. Lehr states that “the
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`geometrical shape of the deformable release device may be one of a various shapes
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`as would be appreciated by one of ordinary skill in the art having the benefit of this
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`disclosure.” (Id. at [0015]). McClinton’s Petition demonstrated, and Magnum does
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`not dispute, that it was well known to one of skill in the art at the time of the
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`invention that “deformable release device” refers to shear rings and shearable
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`threads interchangeably. (Petition at pp. 7-8; Ex. 1020 at ¶ 34; Ex. 1002 at p. 28
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`[Notice of Allowance at p. 7]). As further evidence to rebut Magnum’s assertions
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`that the inserts are not interchangeable, U.S. Patent No. 3,473,609 (“’609 Patent”),
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`which issued on October 21, 1969, makes clear that it was very well known to
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`interchange deformable or shearable elements: “[i]nsofar as the choice of a
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`particular shearable member is concerned, the invention is not restricted to the use
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`of a shear ring 21, and as desired one or more shear pins 37 such as are shown in
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`FIG. 2, or shearable threads 38 as shown in FIG. 3 can be substituted.” (Ex. 1027
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`at 4:33-37). While shear pins may be less desirable than shear rings or shearable
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`threads to achieve the goal of Lehr described above, both rings (as explicitly
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`disclosed in Lehr) and threads (as disclosed by Cockrell and Kristiansen) are
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`interchangeable deformable release elements that allow construction of a plug
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`without drilling extra holes into the plug. (See Ex. 1007 at [0013]). Moreover,
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`contrary to Magnum’s assertions, debris from sheared threads is negligible
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`compared to the debris from large components such as the release studs and shear
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`pins discouraged by Lehr. (See Ex. 1007 at [0010] (no mention of the small
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`amount of debris that would result from the use of threads)).
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`C. One Of Skill In The Art Would Combine Cockrell and
`Kristiansen With Lehr For The Same Reasons One Of Skill In
`The Art Would Combine Cockrell and Kristiansen With Alpha
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`Magnum revisits another issue that was already addressed in the Board’s
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`Decision where it argues that the Petition’s rationale for combining Lehr with other
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`references is not sufficient because the more detailed analysis of the rationale was
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`set forth with respect to Alpha. (Decision at pp. 20-21; Response at pp. 22-24, 25-
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`26). In its decision, the Board stated that not only is the Petition’s rationale
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`sufficient, but that Magnum did not even attempt to address: (1) the simple
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`substitution of shearable threads for the deformable release device or (2) the level
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`of skill required to make such a substitution. (Decision at pp. 20-21). In its
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`response Magnum attempts to address these issues, but offers only conclusory
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`statements that do not come close to rebutting McClinton’s prima facie showing of
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`obviousness. (Response at pp. 22-24, 27-28).
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`Simple Substitution for Lehr and Alpha
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`1.
`As described above in Section V.B., the Petition demonstrates that the Lehr,
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`Cockrell, and Kristiansen combination combines prior art elements according to
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`known methods to yield the predictable result of the claimed invention. As
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`acknowledged by the Board, the Petition, including Dr. Wooley’s declaration in
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`support of the Petition, explains exactly why it would have been obvious to one of
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`skill in the art to combine Lehr, Cockrell, and Kristiansen. (See Petition at pp. 44-
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`47; Decision at pp. 21-25; Ex. 1020 at pp. 53-73).
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`Magnum’s rebuttal points only to Mr. Trahan’s declaration in an effort to
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`demonstrate the differences between Alpha and Lehr. Magnum’s conclusion based
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`on Mr. Trahan’s similarly conclusory statements is that “the insert disclosed by
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`Alpha and the deformable release device member disclosed by Lehr are entirely
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`different in structure and purpose.” Yet, Mr. Trahan’s cross-examination
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`testimony demonstrates that Alpha and Lear both:
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`are frac plugs (Ex. 1026 at 20:22-25);
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`are downhole tools (Id. at 28:6-8);
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`have the claimed “body” (Id. at 20:22-21-2);
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`have the claimed “malleable element” (Id. at 21:3-9);
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`have the claimed “slip” (Id. at 21:10-13);
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`have the claimed “conical member” (Id. at 21:17-21);
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`are bottom-set, i.e., their inserts are at the bottom end of the body (Id.
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`at 21:14-16);
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`have the claimed “passageway” (Id. at 23:5-7);
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`do not need shear pins to hold their inserts in place (Id. at 32:18-33:3);
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`•
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`•
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`have inserts that anchor the setting tool adapter and the insert within
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`the body by having a portion abut the bottom end of the mandrel (Id.
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`at 22:6-23:4, 46:1-47:9); and
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`have inserts that shear or deform to release the setting tool when
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`exposed to a predetermined axial force (Id. at 27:9-18, 49:3-16).
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`Indeed, when questioned about the insert of Alpha, Mr. Trahan stated that it retains
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`the wireline kit (i.e., the setting tool) within the body of the plug “[i]n the same
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`fashion as the Lehr reference.” (Id. at 49:10-21). The Petition’s rationale for
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`combining Lehr, Cockrell, and Kristiansen in the same manner as Alpha, Cockrell,
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`and Kristiansen is supported by Magnum’s own expert witness. One of skill in the
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`art looking at these downhole tool references would have predictably combined the
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`same elements from Cockrell and Kristiansen with either Lehr or Alpha to achieve
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`the same predictable result. (See Petition at 27-33, 44-47).
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`2.
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`The Modifications To Lehr Are Well Known,
`Interchangeable Methods That Are Well Within Reason Of
`One Of Skill In The Art.
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`Magnum’s response includes an argument that the modifications to Lehr
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`would have been “beyond the skill of a person of ordinary skill in the art.”
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`(Response at pp. 27-28). This argument is a reaction to a comment in the Board’s
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`Decision and is entirely circular and conclusory. (Id.) The Petition, on the other
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`hand, documents in detail that the claimed elements not found in Lehr were all well
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`known and well known to be interchangeable to one of skill in the art. (See
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`Petition at pp. 29-31, 46-47).
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`D. The Response Improperly Attempts To Incorporate The
`Arguments From Magnum’s Preliminary Response By Reference
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`On page 19 of its Response, Magnum states “[a]ll of Magnum’s arguments
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`presented in its Preliminary Response are incorporated by reference herein.”
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`Magnum attempts to summarize without support or authority some of those
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`arguments on pages 18-19 of its Response. The Rules explicitly and strictly
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`prohibit the Board from considering Magnum’s arguments from its Preliminary
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`Response. See 37 C.F.R. 42.6(a)(3) (“Arguments must not be incorporated by
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`reference from one document into another document. Combined motions,
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`oppositions, replies, or other combined documents are not permitted.”).
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`Accordingly, only those arguments set forth in the Response should be considered.
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`E. Magnum’s Secondary Indicia of Non-Obviousness Arguments Are
`Not Supported by the Record
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`Pages 29-30 of Magnum’s Response attempt to address “copying.” Yet,
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`there is no record evidence to support Magnum’s argument. See 37 C.F.R.
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`42.63(a) (“All evidence must be filed in the form of an exhibit.”). Magnum merely
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`states “Not only is there evidence of copying Magnum’s patented plug through
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`internal documents, there is evidence of disassembling the patented plugs and
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`efforts to replicate them. Below is a comparison of Magnum’s patented product
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`covered under claims 1-3, 5-8, 12, and 13, and Petitioner’s copied product.”
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`Magnum did not submit any documents as evidence to support its position. There
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`is also no record evidence to support its comparison on page 30 of the Response.
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`The comparison is nothing more than attorney argument and the supporting
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`pictures for the comparison are not evidence in this proceeding. Regardless, what
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`Magnum put in its Response is only a partial view of the plugs that does not show
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`the significant differences between the products. The Board should disregard
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`Magnum’s self-serving, unsupported statements on pages 29-30 of its Response.
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`See 37 C.F.R. 42.63(a).
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`F. Magnum Does Not Contest That the Combinations On Review
`Render Claims 2-20 Obvious, If Claim 1 Is Found Obvious.
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`Aside from claim 1, Magnum provides no reason why the Board should not
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`find its claims obvious. In fact, the only comments related to any of these claims
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`pertain to claims 2 and 5. For claim 2, Magnum merely corrects the record and
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`does not contest McClinton’s challenge to validity of claim 2. For claim 5,
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`Magnum questions the Petition’s and Dr. Wooley’s statements that for Lehr,
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`Cockrell, and Kristiansen, “if the body were to fail before the plug is set, the plug
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`would be inoperable as it would not be set within the wellbore.” (Petition at p. 34;
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`Ex. 1020 at ¶ 45). Magnum does not rebut this statement, it merely questions
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`whether it was Dr. Wooley’s “personal opinion.” Yet, Magnum did not even
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`cross-examine Dr. Wooley. On the other hand, Mr. Trahan–Magnum’s expert–
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`admitted on cross-examination that the Petition is correct regarding claim 5, at
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`least as it pertains to Lehr. (Ex. 1026 at 26:18-27:8, 41:1-9).
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`Accordingly, if claim 1 is found obvious, claims 2-20 should also be found
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`obvious in view of McClinton’s prima facie showing and Magnum’s lack of
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`rebuttal.
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`G. The Claim Construction Issue Identified By Magnum Is
`Consistent With The Broadest Reasonable Interpretation
`Standard.
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`In the District Court, the parties contested the meaning of “setting tool.”
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`The Court sided with Magnum’s broader construction of that term. McClinton
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`encourages the Board to apply that broad construction in this proceeding because,
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`if anything, its breadth makes Claims 1-20 less likely to be patentable. Regardless,
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`neither Magnum nor McClinton argue that the construction of setting tool impacts
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`this proceeding in any meaningful manner.
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`V. Conclusion
`Petitioner hereby requests cancellation of claims 1-20 of the ’413 Patent.
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`Respectfully submitted,
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`
` /Jason A. Engel/
`Reg. No. 51,654
`Jason A. Engel
`Customer No. 24573
`Date: February 24, 2014
`K&L Gates LLP
`e-mail: jason.engel@klgates.com
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`telephone number: 312-807-4236
`fax number: 312-827-8196
`70 W. Madison Street, Suite 3100
`Chicago, IL 60602
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`Dated: February 24, 2014
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`PETITIONER’S REPLY EXHIBIT LIST
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`Ex. 1026
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`February 19, 2014 Deposition Transcript of Kevin Trahan
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`Ex. 1027 U.S. Patent No. 3,473,609
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`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Real Party in Interest: McClinton
`Energy Group L.L.C.
`
`§§§§§§§§§
`
`
`Case No. IPR2013-00231
`Patent 8,079,413
`
`U.S. Patent No. 8,079,413
`
`Issued: December 20, 2011
`
`Title: BOTTOM SET
`
`DOWNHOLE PLUG
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.105, that
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`service was made on the Patent Owner as detailed below.
`
`Date of service February 24, 2014
`
`Manner of service FEDERAL EXPRESS
`
`Documents served Reply in Support of Inter Partes Review
`
`Exhibits 1026-1027
`
`Persons served Robb D. Edmonds
`EDMONDS & NOLTE, P.C.
`2625 Bay Area Blvd, Suite 530
`Houston, TX 77058
`Phone: 281-480-2700
`Fax: 281-480-2701
`redmonds@edmondsnolte.com
`USPTO Reg. No. 46,681
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`N. Alexander Nolte
`EDMONDS & NOLTE, PC
`10411 Westheimer Road, Suite 201
`Houston, TX 77042
`Phone: 281-480-2700
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` /Jason A. Engel/
`Reg. No. 51,654
`Jason A. Engel
`Customer No. 24573
`Date: February 24, 2014
`K&L Gates LLP
`e-mail: jason.engel@klgates.com
`telephone number: 312-807-4236
`fax number: 312-827-8196
`70 W. Madison Street, Suite 3100
`Chicago, IL 60602
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`Fax: 281-480-2701
`anolte@edmondsnolte.com
`USPTO Reg. No. 45,689
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`Dated: February 24, 2014
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