throbber
Trials@uspto.gov
`571-272-7822
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`
`
`
`
`Paper 30
`Entered: June 3, 2014
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` 1 RECORD OF ORAL HEARING
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` 2 UNITED STATES PATENT AND TRADEMARK OFFICE
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` 3 _______________
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` 4 BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` 5 _______________
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` 6 McClinton Energy Group, LLC
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` 7 Petitioner
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` 8 v.
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` 9 Magnum Oil Tools International, Ltd.
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` 10 Patent Owner
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` 11 __________
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` 12
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` 13 Case IPR2013-00231
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` 14 Patent 8,079,413
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` 15
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` 16
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` 17 Oral Hearing Held: Thursday, May 8, 2014
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` 18
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` 19 Before: SALLY C. MEDLEY, MEREDITH C. PETRAVICK,
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` 20 MICHAEL R. ZECHER, Administrative Patent Judges.
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` 21
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` 22 The above-entitled matter came on for hearing on
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` 23 Thursday, May 8, 2014 at the U.S. Patent and Trademark
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` 24 Office, 600 Dulany Street, Alexandria, Virginia at 10:03 a.m.
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` 25 in Courtroom B.
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`Case IPR2013-00231
`Patent 8,079,413
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` 1
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` 2 APPEARANCES:
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` 3 ON BEHALF OF THE PETITIONER:
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` 4 JASON A. ENGEL, ESQ.
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` 5 K&L Gates LLP
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` 6 70 West Madison Street, Suite 3100
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` 7 Chicago, Illinois 60602-4207
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` 8 312-807-4236
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` 9
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` 10 ON BEHALF OF THE PATENT OWNER:
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` 11 ROBB D. EDMONDS, ESQ.
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` 12 JOHN D. HOLMAN, ESQ.
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` 13 Edmonds & Nolte, PC
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` 14 2625 Bay Area Boulevard, Suite 530
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` 15 Houston, Texas 77058
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` 16 281-480-2700
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` 17
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` 18
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` 19
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`Case IPR2013-00231
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` 1 P R O C E E D I N G S
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` 2 (10:03 a. m.)
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` 3 JUDGE MEDLEY: Please be seated. Good morning.
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` 4 This is the hearing for IPR2013-00231, between Petitioner,
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` 5 McClinton Energy Group, and Patent Owner, Magnum Oil Tools
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` 6 International.
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` 7 Before we proceed we would like to memorialize on
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` 8 the record that a conference call was held on May 7th between
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` 9 counsel for the respective parties and the Panel.
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` 10 The purpose of the conference call was to discuss
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` 11 certain objections that Petitioner had with respect to Patent
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` 12 Owner's demonstratives that were filed May 6.
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` 13 Based on the guidance provided by the Panel,
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` 14 Patent Owner sought authorization to expunge the May 6
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` 15 demonstratives and to replace them with the corrected
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` 16 demonstrative set.
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` 17 That request was granted. And so just to let the
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` 18 parties know, the May 6 demonstratives were expunged this
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` 19 morning.
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` 20 Are there any questions regarding demonstratives
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` 21 before we begin?
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` 22 MR. EDMONDS: No.
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` 23 MR. ENGEL: No.
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` 24 JUDGE MEDLEY: Okay. We will proceed then with
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` 25 the hearing. At this time we would like the parties to
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`1 please introduce counsel, beginning with Petitioner.
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` 2 MR. ENGEL: Good morning, Your Honor. Jason Engel
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` 3 on behalf of the Petitioner.
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` 4 JUDGE MEDLEY: Thank you. And then for Patent
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` 5 Owner.
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` 6 MR. EDMONDS: Good morning, Your Honor. I am Robb
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` 7 Edmonds on behalf of the Patent Owner.
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` 8 JUDGE MEDLEY: And you have with you?
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` 9 MR. HOLMAN: John Holman on behalf of the Patent
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` 10 Owner.
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` 11 JUDGE MEDLEY: And who will be arguing today?
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` 12 MR. EDMONDS: I will, Your Honor.
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` 13 JUDGE MEDLEY: Okay. Great. And do you have
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` 14 anybody else with you? Okay. Great.
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` 15 So each party will have 30 minutes of total time
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` 16 to present arguments. Petitioner will begin with the
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` 17 presentation of its case with regard to the challenged claims
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` 18 on which basis the Board instituted trial.
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` 19 Thereafter, Patent Owner, you will have a chance
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` 20 to respond to Petitioner's presentation. And then,
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` 21 Petitioner, you may reserve rebuttal time to respond to
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` 22 Patent Owner's presentation.
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` 23 Petitioner, you may begin. And would you like to
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` 24 reserve rebuttal time?
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` 25 MR. ENGEL: Yes, Your Honor. I would like to
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` 1 reserve 15 minutes.
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` 2 JUDGE MEDLEY: Okay.
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` 3 MR. ENGEL: And I do have paper copies of the
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` 4 demonstratives.
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` 5 JUDGE MEDLEY: Yes, you may approach the bench,
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` 6 please.
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` 7 MR. ENGEL: I would like to start today with a
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` 8 summary of where we are in the proceedings.
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` 9 The petition as filed by the Petitioner, McClinton
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` 10 Energy, set forth a prima facia case of obviousness with
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` 11 respect to all the challenged claims, claims 1 through 20.
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` 12 That petition was supported by the declaration of
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` 13 Dr. Gary Wooley, an industry expert with decades of
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` 14 experience with downhole tools.
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` 15 Notably, Dr. Wooley was not cross-examined by the
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` 16 Patent Owner. So a lot of his testimony stands largely
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` 17 unchallenged in this proceeding.
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` 18 The Board instituted a review on all of the
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` 19 claims. And the dispute here really centers around the
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` 20 combination of three references, Lehr, Cockrell and
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` 21 Kristiansen. Lehr being the primary reference and Cockrell
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` 22 and Kristiansen being the base reference.
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` 23 One thing to note is that the institution decision
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` 24 here addressed all of the arguments that were made in the
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` 25 preliminary response that the Patent Owner filed. And the
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`Case IPR2013-00231
`Patent 8,079,413
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` 1 Patent Owner response really is a rehash of many of those
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` 2 same arguments.
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` 3 So it is Petitioner's position that many of these
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` 4 arguments were considered and rejected at the time that the
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` 5 trial was instituted.
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` 6 Going to the Patent Owner response, as I
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` 7 discussed, we believe it is, you know, just rehashing a lot
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` 8 of the preliminary response arguments.
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` 9 There is some secondary consideration arguments
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` 10 that are put into the record, but they rely on internal
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` 11 documents that are not of record here.
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` 12 There also is a comparison of the accused product
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` 13 in the District Court litigation to the Patent Owner's
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` 14 product, but there is no declaration supporting that they are
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` 15 the same, that there was copying, so really there is no
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` 16 evidence of secondary considerations here in the record.
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` 17 And even if there were, I think the prima facie
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` 18 case of obviousness here is very, very strong and would
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` 19 overcome those.
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` 20 There are no claim construction issues between the
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` 21 parties, I think is one thing to note. The dispute really
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` 22 comes down to are certain elements present in the prior art
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` 23 and would they be combinable.
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` 24 JUDGE ZECHER: Counsel, a real quick question
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` 25 regarding claim construction. It appears that Patent Owner
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` 1 brought the term setting tool in the Patent Owner response,
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` 2 and they are alleging that you made certain arguments in the
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` 3 related District Court litigation.
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` 4 Can you address those real quick for us? Do you
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` 5 agree with their construction or how do you think the Board
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` 6 should construe that term?
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` 7 MR. ENGEL: I think their construction is the
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` 8 broadest reasonable interpretation for purposes of this
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` 9 proceeding.
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` 10 In the District Court we argued for a narrower
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` 11 claim construction. We did not succeed. The Court adopted
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` 12 the Patent Owner's construction.
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` 13 And one thing to note is their construction
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` 14 includes any attachment attached to what in the industry is
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` 15 called a setting tool. A setting tool typically is something
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` 16 that is outside of the plug, but they argued for any
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` 17 attachments to that, adapters and other things that go into
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` 18 the plug.
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` 19 So I would argue that their construction actually
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` 20 is more favorable for the petition in this case because it
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` 21 includes anything they could arguably attach to a setting
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` 22 tool.
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` 23 JUDGE ZECHER: Okay. So just so we are clear, you
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` 24 agree with their construction?
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` 25 MR. ENGEL: That's correct.
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` 1 JUDGE ZECHER: All right.
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` 2 MR. ENGEL: The Patent Owner did file a
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` 3 declaration of an expert, Mr. Kevin Trahan, in support of its
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` 4 response.
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` 5 Notably, on cross-examination Mr. Trahan admitted
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` 6 something that we believe contradicts the primary argument
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` 7 the Patent Owner makes in this case. And we will go into
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` 8 that in a little bit of detail here.
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` 9 First I want to talk about the basic plug
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` 10 configuration. All plugs have a body. They have what are
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` 11 called slips 240. Those are the members that, when the thing
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` 12 is compressed, they expand and they grip the casing so this
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` 13 plug doesn't move.
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` 14 JUDGE MEDLEY: Could you please refer to your
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` 15 slide deck, the slide number, for the record.
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` 16 MR. ENGEL: Sure. And I am on slide 4 of the
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` 17 demonstratives.
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` 18 As I was saying, the slips are what -- this plug
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` 19 is compressed from top to bottom and so everything in the
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` 20 middle slides along the mandrel and expands out.
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` 21 The slips will expand out and they will hit the
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` 22 casing. That's how the plug stays in place.
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` 23 The conical member 230 is what pushes the slips
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` 24 out. All plugs have that.
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` 25 The malleable element 250, that's the seal. That
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`Case IPR2013-00231
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` 1 seal will expand and that allows you to seal the hole so you
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` 2 can complete the hydraulic fracturing process.
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` 3 There are conical members and slips on the bottom
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` 4 end as well. So it is gripped from the top and the bottom.
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` 5 There also is a bottom set insert in this
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` 6 particular plug, and bottom set inserts were also known. So
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` 7 all of the elements on slide 4 are known. I don't think that
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` 8 is in dispute.
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` 9 So if we go to claim 1, which I believe is
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` 10 probably dispositive based on the way that the petition is
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` 11 set forth and the way that the Patent Owner has responded,
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` 12 all of the elements that are here that are not underlined I
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` 13 don't believe are in dispute.
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` 14 It really centers around that bottom set insert
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` 15 and what makes up that insert.
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` 16 And so the claim requires the insert to be screwed
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` 17 into an inner surface of the body and also have shearable
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` 18 threads on the inner surface of the insert as well.
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` 19 Claim 17, which is broader than claim 1, does not
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` 20 require the insert to be screwed in. It just requires the
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` 21 shearable threads on the inside.
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` 22 Again, we talked about how all these are not in
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` 23 dispute. Everything on slide 6 we don't believe is in
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` 24 dispute. We tried to fade out where we think the dispute
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` 25 lies.
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` 1 And, again, as we said, the disputed elements are
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` 2 the insert, the threads on the outer surface and on the inner
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` 3 surface.
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` 4 Moving on to slide 8, I would like to talk about
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` 5 Lehr for a little bit. Magnum argues that Lehr is not
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` 6 located within the inner surface of the plug body.
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` 7 However, they don't refer to figure 4A and 4B of
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` 8 Lehr, which are illustrated here and were included in the
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` 9 reply to the Patent Owner response.
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` 10 And you will see that the red shaded area there is
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` 11 part of the plug, that is part of the plug body, and the
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` 12 deformable element of the insert is identified as 30. It is
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` 13 inside the plug.
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` 14 At the deposition of Magnum's expert he admitted
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` 15 as much. And he had to because otherwise there would be
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` 16 issues with the District Court litigation. That's what it
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` 17 really boils down to.
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` 18 So he admitted during his deposition that the
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` 19 insert of Lehr is inside the body of the plug. We have the
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` 20 citation. It was Exhibit 1026 at page 40, line 17, to page
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` 21 41, line 4.
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` 22 Moving on to slide 9, there is no dispute
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` 23 regarding the structure of Cockrell and Kristiansen.
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` 24 Cockrell is an insert. It has threads on the outside of the
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` 25 insert and it has threads on the inside of the insert. The
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` 1 threads on the inside of the insert are shearable. There is
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` 2 no dispute.
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` 3 Kristiansen is another example of a plug that has
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` 4 threads on the outside and is threaded into the plug.
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` 5 The reason we relied on Kristiansen was because
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` 6 there was an argument that Cockrell was not inside the body.
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` 7 I think that argument has gone away with Magnum's expert's
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` 8 admission. So I think that we could rely on Cockrell and
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` 9 Lehr alone, but we do have Cockrell, Lehr and Kristiansen in
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` 10 the petition.
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` 11 Dr. Wooley, Petitioner's expert, testified that a
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` 12 person of ordinary skill in the art would screw the system of
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` 13 Lehr and Cockrell into the body, as taught by Kristiansen,
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` 14 because it would be combining prior art elements according to
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` 15 known methods to yield the predictable result of holding the
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` 16 plug in place. I don't think that's in dispute.
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` 17 These elements are being used exactly as taught in
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` 18 the prior art. Cockrell teaches that you can use the setting
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` 19 tool or something attached to the setting tool to set the
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` 20 mechanism by using the shearable threads.
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` 21 That's not in dispute. And screwing an insert
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` 22 into a plug is clearly taught by both Cockrell and
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` 23 Kristiansen.
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` 24 Moving on to slide 10, I think one thing to point
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` 25 out is the Patent Owner does ignore the Board's claim
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` 1 construction of shearable threads.
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` 2 We have underlined "or otherwise deform." So it
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` 3 is well known in the art that there were deformable release
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` 4 devices like Lehr. So we think Lehr is exactly like the
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` 5 shearable threads. It is a deformable element.
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` 6 Now, does it have the spiral ridges? Perhaps not.
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` 7 But it is the exact same element used for the exact same
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` 8 purpose. That's why we rely on Cockrell because it does
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` 9 teach multiple ridges that are sheared or deformed.
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` 10 Moving on to slide 12, I think one thing to point
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` 11 out is there is an argument that in the petition we relied on
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` 12 the Alpha reference and set forth the rationale for combining
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` 13 Alpha with other references and then we referred back to that
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` 14 when we got to our base reference Lehr.
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` 15 I think the Board has addressed Patent Owner's
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` 16 argument and rejected it. But just so there is no dispute,
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` 17 during the deposition of Patent Owner's expert he admitted
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` 18 that Alpha and Lehr are both frac plugs, that they all have
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` 19 the claimed body, they all have the claimed sealing element,
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` 20 the claimed slip, the claimed conical member.
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` 21 They both have bottom-set inserts. They both have
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` 22 the claimed passageway. Neither of them need shear pins to
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` 23 hold their inserts into place. And they have inserts at the
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` 24 bottom that shear or otherwise deform to release the sett ing
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` 25 tool when exposed to a predetermined axial force.
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` 1 We think the rationale set forth in the petition
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` 2 for combining Alpha and the other references is the same
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` 3 reference of combining Lehr and the other references.
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` 4 I know that the Board did find Alpha to be a
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` 5 redundant reference. So it is not as if the Board rejected
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` 6 the Alpha reference and that combination outright.
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` 7 That's all I have right now, Your Honors. I don't
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` 8 know if there are any questions for me.
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` 9 JUDGE MEDLEY: No. Thank you.
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` 10 MR. ENGEL: Thank you very much.
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` 11 JUDGE MEDLEY: Do you have copies of your
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` 12 demonstratives?
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` 13 MR. EDMONDS: Your Honor, we do not. And I
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` 14 apologize for that. As soon as we got off the phone with you
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` 15 yesterday we hit a plane and we got here last night, and we
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` 16 just did not have time to get you copies.
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` 17 JUDGE MEDLEY: Okay.
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` 18 MR. EDMONDS: And I apologize for that.
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` 19 JUDGE MEDLEY: No problem.
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` 20 MR. EDMONDS: But I will assure you I am not going
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` 21 to rely on these very much.
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` 22 JUDGE MEDLEY: Okay.
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` 23 MR. EDMONDS: So hopefully it won't be a problem.
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` 24 If it is, just stop me and I will be happy to go over it.
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` 25 JUDGE MEDLEY: That's fine. Thank you.
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` 1 MR. EDMONDS: And I apologize for the
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` 2 inconvenience there.
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` 3 I guess it is no surprise that we disagree with
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` 4 everything Mr. Engel just said. We still do not know what is
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` 5 the prima facie case of obviousness.
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` 6 We still -- we know 1 plus 1 plus 1 equals 3.
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` 7 Where is the motivation to combine these three references to
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` 8 arrive at our claimed invention? There is just absolutely no
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` 9 evidence in the record, in the prior art itself to suggest
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` 10 taking these individual pieces and put them together as our
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` 11 inventor did.
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` 12 And, yes, their professor, doctor, expert, of
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` 13 course it is obvious to him, but he is not one of ordinary
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` 14 skill in the art. He opined that one of ordinary skill in
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` 15 the art has two years of experience and may have an
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` 16 engineering degree, doesn't have to, but may have.
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` 17 We just don't see how it is possible. We just
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` 18 don't see it at all. And their entire petition is based on
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` 19 the Alpha reference. The Alpha reference doesn't have
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` 20 anything to do with Lehr. It is completely different.
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` 21 And, in fact, Lehr teaches away from what Alpha
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` 22 did. Alpha, if you recall, has that shearable ring that sits
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` 23 at the bottom of the plug. It is designed to break at that
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` 24 ring and that ring falls down the wellbore.
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` 25 Lehr is replete with teaching and saying don't do
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` 1 that. Don't leave remnants in the wellbore. Do what I did.
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` 2 I put a deformable disk, just a little-bitty disk
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` 3 at the end of the mandrel. And I hold it there with that
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` 4 retaining pin 31. And that deformable disk allows that
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` 5 setting tool just to pull right through it. The disk stays
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` 6 intact. It doesn't go anywhere. It doesn't fall anywhere.
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` 7 And it has such a low profile that it is easy to drill out.
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` 8 These plugs, when they have done their purpose,
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` 9 they are just drilled and milled out. They are disposable.
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` 10 They are gone most of the time. Although I think Lehr
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` 11 teaches that its disk is reusable, which would infer that
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` 12 this plug is retrievable.
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` 13 Our plug is not designed to be retrievable. Our
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` 14 plug is designed to be milled up. But, regardless, Lehr in
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` 15 paragraphs 10 through 13 talk about don't leave remnants in
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` 16 the wellbore. It is not a good thing. We don't want to do
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` 17 that. Alpha does.
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` 18 So modifying Alpha -- Lehr is a modification of
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` 19 Alpha, but I don't know how you can take Alpha and say it is
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` 20 obvious to put Kristiansen's inner shear threads, or the
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` 21 Cockrell, sorry, shear threads on Alpha the same way you
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` 22 could do it on Lehr.
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` 23 JUDGE MEDLEY: Why are we talking about Alpha? It
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` 24 is not part of the trial.
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` 25 MR. EDMONDS: Well, is it? Because their whole
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` 1 rationale is all about modifying Alpha and you can modify
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` 2 Alpha or any other downhole tool art. And so I really don't
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` 3 know what the rationale is to arrive at the invention based
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` 4 on Lehr.
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` 5 Because, I am guessing, are they suggesting that
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` 6 you replace the deformable disk with shearable threads? Is
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` 7 that the simple substitution? That's what they say.
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` 8 And, in fact, I think the petition, I'm sorry, the
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` 9 decision says that, that that is just a mere substitution.
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` 10 And I don't disagree. That would be a mere substitution.
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` 11 But that doesn't arrive at the claimed invention.
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` 12 Taking out that deformable disk 31 and putting
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` 13 threads in its place doesn't get to an insert with threads on
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` 14 an inner surface that gets screwed into a body. We don't get
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` 15 there from that.
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` 16 And I think another rationale was as well, if you
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` 17 did this, you put -- take Lehr, I guess you get rid of the
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` 18 deformable disk. Nobody made that clear. I am not sure
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` 19 where we get there.
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` 20 But if you stick Kristiansen into Lehr and you
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` 21 screwed onto Lehr, but you have to put shear threads on
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` 22 Kristiansen, somehow that simplifies assembling and somehow
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` 23 that simplifies manufacturing.
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` 24 It doesn't. Our expert testified to that. It is
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` 25 in his declaration. That complicates manufacturing. And
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` 1 besides that, I am not sure where you could screw anything
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` 2 into Lehr. You have to modify the body of Lehr completely.
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` 3 This is all part of our major redesign argument.
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` 4 You cannot -- there is no simple substitutions here. There
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` 5 is not just take this piece, this piece and just throw it on
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` 6 there.
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` 7 You have to completely redesign Lehr to
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` 8 accommodate all that, because Lehr doesn't have the insert
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` 9 that gets screwed into anything. It has a deformable disk
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` 10 that sits at the bottom of the mandrel. That mandrel holds
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` 11 it so you can pull that setting tool through it, to deform
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` 12 it, and it stays in place.
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` 13 Our insert works completely different. Our insert
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` 14 screws into the mandrel. Our setting tool screws into the
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` 15 insert. Our insert -- our setting tool shears out of that
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` 16 insert. That insert is screwed into the inner surface of the
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` 17 body.
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` 18 That's another claim limitation, that we are not
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` 19 clear how that can be met, because we think there is a
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` 20 dispute -- I'm not sure why my slides aren't working anymore.
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` 21 Here we go.
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` 22 An insert is screwed into the inner surface of the
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` 23 body. Nobody has really determined what the word body means.
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` 24 Well, 77 is the cap on Lehr. It is what Lehr
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` 25 calls the lower cap. I don't know if you can see it because
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` 1 it is kind of small there, but 77 is pointing to that white
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` 2 space. Those are holes, thread holes, bolt holes, to screw
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` 3 that cap onto what I call the body of Lehr.
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` 4 That cap comes off. And, in fact, it is shown in
`
` 5 the drawings of Lehr, figures 3 and 3B, without it
`
` 6 completely. And we mention that in our brief.
`
` 7 That cap, after assembly of all of the plungers
`
` 8 80, and what I call the adapter rod 50, once all that gets
`
` 9 assembled then they put that end cap on there and then they
`
` 10 screw it on.
`
` 11 So I am unclear from the record, I am unclear from
`
` 12 the petition, I am unclear from the decision where do you
`
` 13 screw Kristiansen into? Where does the plug of Kristiansen
`
` 14 get screwed into?
`
` 15 Does it get screwed into just the mandrel? And
`
` 16 may I walk over to the slide just to point to something real
`
` 17 quick? In this mandrel of Lehr, and this mandrel being this
`
` 18 piece right here.
`
` 19 JUDGE MEDLEY: Can you identify the item, is there is a
`
`number there for the record? This is
`
` 21 your slide 9?
`
` 22 MR. EDMONDS: Sorry, yes, this is slide 9. And I
`
`

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