Paper No. ________
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`GREENE’S ENERGY GROUP, LLC
`Petitioner
`v.
`
`OIL STATES ENERGY SERVICE, L.L.C.
`Patent Owner
`
`
`
`Patent No. 6,179,053
`Issue Date: January 30, 2001
`Title: LOCKDOWN MECHANISM FOR WELL TOOLS REQUIRING FIXED-
`POINT PACKOFF
`_______________
`
`Inter Partes Review No. Unassigned
`
`
`
`
`
`____________________________________________________________
`
`DECLARATION OF DON W. SHACKELFORD
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`1.
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`I, Don W. Shackelford, a resident of Houston, Texas, hereby declare
`
`as follows:
`
`2.
`
`I have been retained by Foley & Lardner LLP to provide my opinion
`
`concerning the validity of U.S. Pat. No. 6,179,053 (“the '053 patent") (Ex. 1001). I
`
`am being compensated for my time at the rate of $400 per hour.
`
`3.
`
`My declaration contains the following sections:
`
`I.
`
`II.
`
`III.
`
`IV.
`
`V.
`
`Introduction And Qualifications ..........................................................................................4
`
`Understanding of the Governing Law ..................................................................................5
`A.
`Types Of Claims – Independent And Dependent ....................................................5
`B.
`Invalidity By Anticipation Or Obviousness .............................................................5
`C.
`Secondary Or Objective Evidence Of Obviousness Or Nonobviousness ................6
`D.
`Interpreting Claims Before The Patent Office .........................................................7
`E.
`Relevant Time Period For The Obviousness Analysis ............................................8
`F.
`Basis For My Opinion ..............................................................................................9
`G.
`Level Of Ordinary Skill In The Art In The Relevant Timeframe ............................9
`H.
`Perspective Applied In This Declaration ...............................................................10
`
`Introduction To The ‘053 Patent ........................................................................................10
`
`Introduction To The Claims And Structures ‘053 Patent ..................................................15
`A.
`Overview of Claim 1 ..............................................................................................16
`B.
`Fig. 1 Embodiment: Corresponding Structures for “first lockdown mechanism”
`and “second lockdown mechanism” ......................................................................17
`Fig. 5 Embodiment: Corresponding Structures for “first lockdown mechanism”
`and “second lockdown mechanism” ......................................................................19
`Claim term “fixed-point packoff” ..........................................................................21
`
`D.
`
`C.
`
`Detailed Explanation of Claim Terms ...............................................................................22
`A.
`“Operative Position”: (Claims 1 and 22) ...............................................................22
`B.
`“Fixed-Point Packoff” (Claim 1) “Fixed-Point For Packoff” / “Fixed-Point In The
`Well”/ “Fixed-Point” (Claim 22) ...........................................................................23
`“First Lockdown Mechanism”: (Claims 1 and 22) ................................................24
`“Second Lockdown Mechanism”: (Claims 1 and 22) ............................................25
`Order of Certain Steps in Method Claim 22 ..........................................................27
`Patent Owner Potential Interpretation ....................................................................27
`
`C.
`D.
`E.
`F.
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`VI.
`
`Introduction to Canadian Patent Application 2,195,118 - “Dallas” ..................................28
`
`VII.
`
`Introduction to U.S. Patent 4,632,183 – “McLeod” ..........................................................31
`A.
`Background of McLeod .........................................................................................31
`B.
`Use of McLeod’s Adapter with Dallas’ Tool ........................................................34
`
`B.
`
`VIII. Ground 1 of Invalidity – Dallas and McLeod ....................................................................36
`A.
`Dallas and McLeod: Independent Apparatus Claim 1 ...........................................37
`1.
`Claim 1: Preamble: ....................................................................................37
`2.
`Claim 1: First Body Limitation (a): ...........................................................37
`3.
`Claim 1: Second Body Limitation (b): .......................................................40
`4.
`Claim 1: Third Body Limitation (c): ..........................................................43
`Dallas and McLeod: Independent Method Claim 22 .............................................46
`1.
`Claim 22: Preamble: ..................................................................................46
`2.
`Claim 22: First Body Limitation (a.1): ......................................................46
`3.
`Claim 22: Second Body Limitation (a.2): ..................................................47
`4.
`Claim 22: Third Body Limitation (a.3): .....................................................48
`5.
`Claim 22: Fourth Body Limitation (b): ......................................................49
`6.
`Claim 22: Fifth Body Limitation (c): .........................................................50
`7.
`Claim 22: Sixth Body Limitation (d): ........................................................51
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`IX.
`
`X.
`
`XI.
`
`Ground 2 of Invalidity – Dallas Alone ..............................................................................51
`A.
`Dallas: Independent Apparatus Claim 1 ................................................................52
`1.
`Claim 1: Second Body Limitation (b): .......................................................53
`2.
`Claim 1: Third Body Limitation (c): ..........................................................54
`Dallas: Independent Method Claim 22 ..................................................................54
`1.
`Claim 22: Second Body Limitation (a.2): ..................................................55
`2.
`Claim 22: Third Body Limitation (a.3): .....................................................55
`3.
`Claim 22: Fourth Body Limitation (b): ......................................................56
`4.
`Claim 22: Fifth and Sixth Body Limitations (c) and (d) ............................58
`
`B.
`
`Introduction to U.S. Pat. 4,076,079 - “Herricks” ..............................................................58
`A.
`Background of Herricks .........................................................................................58
`B.
`Herricks Discloses a Wellhead Isolation Tool for Securing a Mandrel That Allows
`for Fixed Point Packoff ..........................................................................................59
`Herricks Does Not Disclose Adjusting the Position of the Mandrel Relative to the
`Wellhead Components ...........................................................................................61
`
`C.
`
`Introduction to U.S. Pat. 2,927,643 – Dellinger ................................................................62
`A.
`Dellinger Background ............................................................................................62
`B.
`Dellinger Describes the Same Basic Mandrel as Herricks ....................................63
`C.
`Dellinger’s Mandrel Movement and Securement Structure ..................................64
`D.
`Use of Dellinger’s Mandrel Movement and Securement Structure to Move and
`Secure Herricks Mandrel .......................................................................................66
`
`XII. Ground 3 of Invalidity – Herricks and Dellinger ...............................................................69
`A.
`Herricks and Dellinger: Independent Apparatus Claim 1 ......................................69
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`B.
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`Claim 1: Preamble: ....................................................................................69
`1.
`Claim 1: First Body Limitation (a): ...........................................................70
`2.
`Claim 1: Second Body Limitation (b): .......................................................71
`3.
`Claim 1: Third Body Limitation (c): ..........................................................73
`4.
`Herricks and Dellinger: Independent Method Claim 22 ........................................76
`1.
`Claim 22: Preamble: ..................................................................................76
`2.
`Claim 22: First Body Limitation (a.1): ......................................................76
`3.
`Claim 22: Second Body Limitation (a.2): ..................................................77
`4.
`Claim 22: Third Body Limitation (a.3): .....................................................78
`5.
`Claim 22: Fourth Body Limitation (b): ......................................................78
`6.
`Claim 22: Fifth Body Limitation (c): .........................................................79
`7.
`Claim 22: Sixth Body Limitation (d): ........................................................79
`
`XIII. Overall Conclusion ............................................................................................................80
`
`I.
`
`Introduction And Qualifications
`
`4.
`
`I am a retired Senior Well Control Engineer with Boots and Coots
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`(International Well Control)(now a division of Halliburton Services). I received
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`my Bachelor’s and Master’s degrees in Mechanical Engineering from Texas Tech
`
`University in 1969 and 1972, respectively. I have over 40 years of experience in
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`the oil and gas well industry, starting with my first position as an engineer with
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`Halliburton Services following conferral of my undergraduate engineering degree.
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`During that time, I have accrued significant engineering experience in the field
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`including jobs with Domestic General Services that involved well fracturing and
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`the use of wellhead isolation tools, as explained in more detail by my resume,
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`which is appended to this declaration.
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`5.
`
`In addition to my practical engineering experience, I have been the
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`recipient of a number of achievement awards throughout my career, all of which
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`are listed in my attached resume. I have also authored or co-authored a number of
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`published technical papers directed to engineering aspects of the oil and gas
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`industry. Additionally, I am the named inventor named on two issued U.S. patents
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`relating to oil and gas well technology (U.S. Pat. Nos. 5,209,108 and 4,850,108).
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`Lastly, I am also a distinguished member of a variety of professional organizations
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`including the Society of Petroleum Engineers of which I have been a member for
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`over 10 years.
`
`II.
`
`Understanding of the Governing Law
`
`A. Types Of Claims – Independent And Dependent
`
`6.
`
`I understand that there are two types of U.S. patent claims: 1)
`
`independent claims and 2) dependent claims. I understand that independent claims
`
`only include the aspects stated in the independent claim. I further understand that
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`dependent claims include the aspects stated in that dependent claim, and any other
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`aspects stated in any claim from which that dependent claim depends.
`
`B.
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`Invalidity By Anticipation Or Obviousness
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`7.
`
`I understand that a claim is invalid if it is anticipated or obvious. I
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`understand that anticipation of a claim requires that every element of a claim is
`
`disclosed expressly or inherently in a single prior art reference, arranged as in the
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`claim.
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`8.
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`I further understand that obviousness of a claim requires that the claim
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`be obvious from the perspective of a person of ordinary skill in the relevant art, at
`
`the time the invention was made. In analyzing obviousness, I understand that it is
`
`important to understand the scope of the claims, the level of skill in the relevant
`
`art, the scope and content of the prior art, the differences between the prior art and
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`the claims, and any secondary considerations. I also understand that if a technique
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`has been used to improve one device, and a person of ordinary skill in the art
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`would recognize that it would improve similar devices in the same way, using the
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`technique is obvious unless its actual application is beyond his or her skill. There
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`may also be a specific “teaching, suggestion or motivation” to combine any first
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`prior art reference with a second prior art reference. Such a “teaching, suggestion,
`
`or motivation” to combine the first prior art reference with the second prior art
`
`reference can be explicit or implicit.
`
`C.
`Secondary Or Objective Evidence Of Obviousness Or
`Nonobviousness
`
`9.
`
`I understand that secondary (or objective) considerations are relevant
`
`to the determination of whether a claim is obvious. Such secondary (or objective)
`
`considerations can include evidence of commercial success caused by an invention,
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`evidence of a long-felt need that was solved by an invention, evidence that others
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`copied an invention, or evidence that an invention achieved a surprising result. I
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`understand that such evidence must have a nexus, or causal relationship to the
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`elements of a claim, in order to be relevant to the obviousness or non-obviousness
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`of the claim. I am unaware of any such secondary considerations in relation to
`
`claims 1 and 22 of the '053 patent.
`
`D.
`
`Interpreting Claims Before The Patent Office
`
`10.
`
`I understand that “inter partes review” is a proceeding before the
`
`United States Patent & Trademark Office (“Patent Office”) for evaluating the
`
`validity of an issued patent claim. Claims in an inter partes review are given their
`
`broadest reasonable interpretation that is consistent with the patent specification. I
`
`understand that a patent’s “specification” includes all the figures, discussion, and
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`claims within the patent document. I understand that the Patent Office will look to
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`the specification to see if there is a definition for a claim term, and if not, will
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`apply the broadest reasonable ordinary meaning from the perspective of a person
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`of ordinary skill in the art. However, I also understand that if a term has no
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`previous meaning to those of ordinary skill in the prior art, its meaning, then, must
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`be found in the patent. I present a more detailed explanation of the broadest
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`reasonable interpretation of certain of the terms in the '053 patent in the section
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`entitled “Detailed Explanation of Claim Terms” below.
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`11.
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`I further understand that certain patent claim terms may be interpreted
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`as “means-plus-function” claim terms. My understanding is that terminology is
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`part of the U.S. Patent Law in 35 USC § 112(f) (post-AIA), which states the
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`following (with emphasis): “An element in a claim for a combination may be
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`expressed as a means or step for performing a specified function without the recital
`
`of structure, material, or acts in support thereof, and such claim shall be construed
`
`to cover the corresponding structure, material, or acts described in the specification
`
`and equivalents thereof.” As explained in more detail below, a person of ordinary
`
`skill in the art reading certain terms of claims 1 and 22 of the ‘053 patent would
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`consider those terms are stated “without the recital of structure, material, or acts in
`
`support thereof.”
`
`E. Relevant Time Period For The Obviousness Analysis
`
`12.
`
`I also understand that the earliest patent application filing leading to
`
`U.S. Pat. No. 6,179,053 ("the '053 patent") (Ex. 1001) was made on August 12,
`
`1999. I have therefore analyzed obviousness as of that day or somewhat before
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`(approximately 1998 –August 12, 1999), understanding that as time passes; the
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`knowledge of a person of ordinary skill in the art will increase. I understand that
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`under certain circumstances the owner of the '053 patent (Oil States Energy
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`Services, L.L.C.) might try to prove an earlier date of invention. If this occurs, I
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`reserve the right to revise my opinion. I may refer to the relevant time period as
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`1998-1999 in this declaration, with the understanding that this does not include the
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`time period on or after the filing date of the first application (August 12, 1999).
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`F.
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`Basis For My Opinion
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`13.
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`In forming my opinion, I have relied on the '053 patent claims and
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`disclosure, the prior art exhibits to the Petition for inter partes review of the '053
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`patent, and my own experience and expertise of the knowledge of the person of
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`ordinary skill in the relevant art in the 1998-1999 timeframe.
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`G. Level Of Ordinary Skill In The Art In The Relevant Timeframe
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`14.
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`In 1998-1999, I believe that a relevant person of ordinary skill in the
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`art of the ‘053 patent would have had a Bachelor-level degree in a recognized
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`engineering discipline, and practical job exposure of several years with oil and gas
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`well operations, or equivalent experience or knowledge. This description is
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`approximate, and a higher level of education or skill might make up for less
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`experience, and vice-versa.
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`15.
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`I believe that I would qualify as at least a person of ordinary skill in
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`the art in 1998-1999, and that I have a sufficient level of knowledge, experience
`
`and education to provide an expert opinion in the field of the '053 patent.
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`H.
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`Perspective Applied In This Declaration
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`16.
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`My testimony in this declaration is given from the perspective of a
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`person of ordinary skill in the art at the time of the August 12, 1999 filing, and for
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`some time before then, unless otherwise specifically indicated. This is true even if
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`the testimony is given in the present tense.
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`III.
`
`Introduction To The ‘053 Patent
`
`17.
`
`The ‘053 patent is directed to wellhead isolation tools used during
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`“stimulation to enhance hydrocarbon flow and make or keep [oil and gas wells]
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`economically viable” (See Ex. 1001, col. 1, ll. 15-16.) Such stimulation is more
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`commonly referred to as oil and gas well “fracking”, or “fracturing”. The
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`“fracking” process involves pumping fluids, sometimes corrosive and abrasive,
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`under high pressure through a well to enhance hydrocarbon flow. (See Ex. 1001,
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`col. 1, ll. 14-20). The fracking fluids pass through the well into hydrocarbon
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`bearing formations around the well. The fluid pressure and fluid properties cause
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`the release of hydrocarbons in those formations. The fluids “can cause irreparable
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`damage to wellhead equipment if they are pumped directly through the spool and
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`the various valves that make up the wellhead.” (See Ex. 1001, col. 1, ll. 21-23).
`
`18.
`
`As further explained in the ‘053 patent, wellhead isolation tools were
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`known that could be used to avoid the potential damage to the wellhead. The ‘053
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`patent describes that such tools include a “mandrel” inserted through the valves
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`and spools of the wellhead into a casing or production tubing below the wellhead
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`to isolate the wellhead components from fracking fluids. (See Ex. 1001, col. 1, ll.
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`26-30). The bottom of the “mandrel” has a “packoff” assembly that forms a fluid
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`tight seal between the mandrel and the production tubing or casing so that
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`stimulation fluids passed through the mandrel into the tubing or casing are
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`completely isolated from the wellhead components. (See Ex. 1001, col. 1, ll. 32-
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`36).
`
`19.
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`The ‘053 patent explains that the mandrel and packoff assembly of
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`prior wellhead isolation tools limited the flow rate of stimulation fluids because the
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`mandrel had a reduced inner diameter to permit the mandrel to be packed off inside
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`the tubing or casing. (See Ex. 1001, col. 1, ll. 43-47). The ‘053 patent describes a
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`solution allegedly developed by the Applicant in which the mandrel is sealed
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`against an annular step such as a “bit guide” mounted to the top of a casing or an
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`annular step above the back pressure valve threads of a tubing hanger, which forms
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`a “fixed-point” for packoff of the mandrel. (See e.g., Ex. 1001, col. 1, ll. 47-67
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`(explaining advantage of avoiding internal packoff); col. 2, ll. 34-45 (explaining
`
`“bit guide” embodiment)). According to the ‘053 patent, this arrangement may
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`permit the internal diameter of the mandrel to be the same as that of the tubing or
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`casing. (See e.g., Ex. 1001, col. 1, ll. 62-67). The ‘053 patent does not describe or
`
`identify any prior art tool or disclosure with such a “fixed point” packoff
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`20.
`
`Fig. 8 of the ‘053 patent, reproduced below, shows a typical well with
`
`an embodiment of the ‘053 wellhead isolation tool attached to the top of the well.
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`Before discussing the ‘053 tool embodiments and example independent claim 1, I
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`will provide some background on the structure and operation of the well shown in
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`the figure.
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`21.
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`For ease of reference, I have reproduced below the portion of Fig. 8
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`showing the well components only (annotations in blue).
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`
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`22.
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`The blowout preventer is a device to shut-in the annulus of the well or
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`the well itself.
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`23.
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`The tubing head spool is identified in the ‘053 patent as the adapter
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`from the drilling assembly including the blowout preventers to the casing.
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`Although this component is identified as a “tubing head spool,” I would call this
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`component a “casing spool.” The casing spool is generally bolted to the wellhead
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`and serves to mount other components such as the blowout preventer stack.
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`24.
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`The bit guide is generally referred to as a “wear bushing.” The bit
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`guide is located at the top of the casing and serves as a guide for drilling
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`components to protect the casing.
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`25.
`
`Turning now to the ‘053 patent’s disclosed wellhead isolation tool, it
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`has a mandrel with a seal on its axial end to packoff, i.e. seal, against the top of an
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`annular step in a wellhead (“fixed-point” packoff). An annotated version of Fig. 8
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`is provided below to demonstrate the ‘053 patent’s wellhead isolation tool used in
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`a “fracking” process of an oil or gas well (annotations in blue and red).
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`
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`26.
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`As seen above, the wellhead isolation tool is mounted to the top of the
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`wellhead (in this case to the top flange of the blowout preventer) and has a mandrel
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`72 that extends through the wellhead and seals against the upper surface of the bit
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`guide in the tubing head spool (more properly “casing spool”). The ‘053 patent
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`refers to this type of seal as a “fixed point packoff.” (See e.g., Ex. 1001, col. 5, ll.
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`34-39).
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`IV.
`
`Introduction To The Claims And Structures ‘053 Patent
`
`27.
`
`I have found that a review of claim 1 along with the various figures
`
`and description of the ‘053 patent is helpful in understanding both claims 1 and 22.
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`The text of claim 1 of the ‘053 patent is as follows:
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`1. An apparatus for securing a mandrel of a well tool in an operative position
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`requiring fixed-point packoff in the well, comprising:
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`a first and a second lockdown mechanism arranged so that the mandrel is
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`locked in the operative position only when both the first and the second
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`lockdown mechanism are in respective lockdown positions;
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`the first lockdown mechanism adapted to detachably maintain the mandrel in
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`proximity to the fixed-point packoff when in the lockdown position, the first
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`lockdown mechanism including a base member for connection to a wellhead of
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`the well and a locking member for detachably engaging the base member; and
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`the second lockdown mechanism having a range of adjustment adequate to
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`ensure that the mandrel can be moved into the operative position and locked
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`down in the operative position while the first lockdown mechanism is in the
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`lockdown position.
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`A. Overview of Claim 1
`
`28.
`
`The apparatus of claim 1 includes a mandrel that is to be placed into
`
`“an operative position requiring fixed-point packoff in the well.” My review of the
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`‘053 patent, including its specification and claims indicates that such an “operative
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`position” is a position in which the mandrel is “packed off” or sealed against the
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`“fixed-point” in the well. (See e.g, Ex. 1001, Claim 1, preamble (“operative
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`position requiring fixed-point packoff in the well”) and Claim 22, preamble
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`(“operative position in which the mandrel is packed off against a fixed-point in the
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`well”)).
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`29.
`
`Additionally, the first body limitation of claim 1 includes a “first” and
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`a “second” “lockdown mechanism” that are claimed such that the mandrel is only
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`in the “operative position” when both of those mechanisms are locked down. My
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`understanding of these mechanisms is explained in more detail below.
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`30.
`
`In my opinion, the phrases “first lockdown mechanism” and “second
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`lockdown mechanism” are not structures known in the art and do not indicate any
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`structure the could perform the functions attributed to these mechanisms in claim 1
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`(and likewise claim 22). The same is true of the “base member” and “locking
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`member” that are part of the “first lockdown mechanism” in claim 1 (and likewise
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`claim 22). As a result, based on my understanding of U.S. Patent Law, these
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`phrases should be interpreted as “means plus function” clauses, which requires
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`identification of corresponding structure in the ‘053 patent for each of these
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`clauses. My further understanding is that the identified corresponding structure
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`should perform the claimed function.
`
`B.
`Fig. 1 Embodiment: Corresponding Structures for “first
`lockdown mechanism” and “second lockdown mechanism”
`
`31.
`
`The ‘053 patent shows two versions of its wellhead isolation tool.
`
`The first version is shown in Fig. 1, below, which the ‘053 patent calls “a cross
`
`sectional view of a first lockdown mechanism 20” (Ex. 1001, col. 5, ll, 31-32):
`
`32.
`
`The specification explains that the first lockdown mechanism includes
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`“a mandrel head 26 connected to a top end of the mandrel 22 and a base plate 28
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`mounted to a top of a wellhead, which is indicated by line 30.” (Ex. 1001, col. 5, ll.
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`43-45). The mandrel head is attached to a connector 44 by bolts 56. (See Ex. 1001,
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`col. 6, ll. 14-17). The connector 44 may be attached to the base plate 28 by a
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`lockdown nut 38 that has a top wall 42 for rotatably retaining lower flange 48 of
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`the connector 44. (See Ex. 1001, col. 6, ll. 7-9). Lockdown nut 38 may engage
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`sleeve 32 on the base plate 28 to lock the mandrel head 26 and mandrel 22 to the
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`base plate 28. (See Ex. 1001, col. 6, ll. 1-3 and col. 6, ll. 26-30).
`
`33.
`
`The specification further explains that the distance “D” from the top
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`of the wellhead 30 to the fixed point 24 for packoff, as shown in Fig. 1, may vary.
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`(See Ex. 1001, col. 5, ll. 52-58). In contrast, the distance “d” from the top of the
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`wellhead 30 to a top end of the mandrel 22 is constant when the mandrel is locked
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`down to the base plate 28 by lockdown nut 38, as illustrated in Figure 1. (See also
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`Ex. 1001, col. 5, ll. 58-61). Thus, distance “C”, as illustrated in Fig. 1, is the
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`distance of the gap between the bottom end of the mandrel 22 and fixed point 24
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`for packoff when the lockdown nut 38 is attached to sleeve 32. One of ordinary
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`skill in the art would appreciate that these structures shown in Fig. 1 provide the
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`structure and function of the “first lockdown mechanism” of claim 1 reproduced
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`above.
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`34.
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`Fig. 1 also shows that a range of adjustment “B” greater than the gap
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`“C” is provided by threaded bolts 56, which have fixed ends attached to upper
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`flange 46 of the connector 44 and free ends extending through bores 58 in mandrel
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`18
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`000018
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`

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`head lower flange 54. (See also Ex. 1001, col. 6, ll. 14-17). Fig. 1 illustrates that
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`nuts 60 are attached to the free ends of bolts 56 to secure the mandrel head 26 to
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`connector 44 such that the mandrel can be stroked down against the fixed point for
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`packoff 24. (See Ex. 1001, col. 6, ll. 19-20). The bottom of the mandrel may be
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`moved through the distance “C” by screwing the nuts 60 down on the bolts 56 to
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`move the mandrel down on the fixed point for packoff. (See Ex. 1001, col. 6, ll.
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`26-30). One of ordinary skill in the art would appreciate that this aspect of Fig. 1
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`provides the structure and function of the “second lockdown mechanism” of claim
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`1.
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`C.
`Fig. 5 Embodiment: Corresponding Structures for “first
`lockdown mechanism” and “second lockdown mechanism”
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`35.
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`Fig. 5, reproduced below, shows a second embodiment of the ‘053
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`device:
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`
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`19
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`000019
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`

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`36.
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`In Fig. 5, the base plate 28 attached to the wellhead as indicated by
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`line 30 also includes threaded sleeve 32, which receives lockdown nut 38.
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`However, in Fig. 5, the upper wall 42 of nut 38 rotatably receives a lower flange 92
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`of a hydraulic cylinder 74. (See also Ex. 1001, col. 8, ll. 1-4). A piston 84 is
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`received in the cylinder 74 and is attached to mandrel 72 so that the mandrel moves
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`with the piston. (See also, Ex. 1001, col. 7, ll. 57-62). Hydraulic fluid may be
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`injected into and removed from the cylinder 72 though ports 88 and 90 to move the
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`piston up or down within the cylinder. (See Ex. 1001, col. 7, ll. 58-64). As in Fig.
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`1, the, distance “C” is the distance between the bottom end of the mandrel and
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`fixed point 24 for packoff when the lockdown nut 38 is attached to sleeve 32. (See
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`Ex. 1001, col. 8, ll. 5-18). One of ordinary skill in the art appreciates that these
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`structures shown in Fig. 5 provide another structure and function of the “first
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`lockdown mechanism” of claim 1.
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`37.
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`Fig. 5 shows that a range of adjustment “B,” greater than distance “C”
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`is provided by piston 84 being movable within hydraulic cylinder 74. (See Ex.
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`1001, col. 7, ll. 45-66). Accordingly, the mandrel can be stroked down through the
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`distance “C” by injecting hydraulic fluid into upper port 88 and releasing hydraulic
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`fluid from lower port 90 until the mandrel seals off against the fixed point for
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`packoff in the well. The mandrel is locked down in its operation by the hydraulic
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`force in the cylinder. (See Ex. 1001, col. 8, ll. 30-31). In the Fig. 5 embodiment,
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`20
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`000020
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`

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`threaded bolts 56 along with nuts 60 may be used to provide a measure of safety
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`once the mandrel has been locked in the “operative position” using hydraulic fluid.
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`(See Ex. 1001, col. 8, ll. 30-34); (see also Ex. 1001, col. 4, ll. 52-60 (explaining
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`that a hydraulic mechanism alone may be a “second lockdown mechanism”)). One
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`of ordinary skill in the art appreciates this aspect of Fig. 5 provides another
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`structure and function of a “second lockdown mechanism” as claimed in claim 1.
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`D. Claim term “fixed-point packoff”
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`38.
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`Claim 1 also includes a term “fixed-point packoff,” and claim 22
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`similar terms. The term “fixed-point packoff” has no generally understood
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`meaning in the oil or gas well art. My understanding is that under the U.S. Patent
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`Law, if a specialized term, such as “fixed-point packoff,” has no meaning to one of
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`ordinary skill in the art, one must look towards the patent specification to
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`understand the meaning of the term. Initially, one of ordinary skill in the art would
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`understand that the term “packoff” or “pack off” in connection with a mandrel
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`refers to a fluid tight sealing arrangement between the mandrel and a well. Also,
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`the ‘053 patent explains that “[t]he fixed-point for packoff may be a bit guide
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`mounted to the top of a casing, as shown in FIG. 8, an annular step above back
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`pressure valve threads of a tubing hanger, as shown in FIG. 9, or any other type of
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`fixed-point location used for packoff in a wellhead, a casing, a tubing or a
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`downhole tool.” (Ex. 1001, col. 5, ll. 34-39). An annotated aspect of Fig. 8
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`21
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`000021
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`

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`(annotation in red) is reproduced below, which shows an exemplar “fixed-point
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`packoff” in the form of a bit guide 96. (Ex. 1001, col. 8, ll. 38-43).
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`
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`V. Detailed Explanation of Claim Terms
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`39.
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`As noted above, I understand that claims in an inter partes review are
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`given their broadest reasonable interpretation that is consistent with the patent
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`specification. In my review of claims 1 and 22, I identified a number of terms
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`which a person of ordinary skill in the art in the 1998-1999 timeframe would
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`consider in need of further investigation to understand the broadest reasonable
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`meaning. In the absence of a speci