`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GREENE'S ENERGY GROUP LLC
`
`Petitioner
`
`v.
`
`OIL STATES ENERGY SERVICES LLC
`
`Patent Owner
`
`Case IPR2014—00216
`
`Patent 6,179,053
`
`VIDEOTAPED ORAL DEPOSITION OF
`
`GREGG S. PERKIN
`
`Kingwood, Texas
`
`Friday, December 19, 2014
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`Reported by:
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`LINDA RAYBURN, CSR, RPR, CLR
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`JOB NO. 88540
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`+ * -( 3 % 3 3 %*
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`Reported by:
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`LINDA RAYBURN, CSR, RPR, CLR
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`JOB NO. 88540
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`+ * -( 3 % 3 3 %*
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`;;;;;;;;;;;;;;;;;;;;;;
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`TSG Reporting — Worldwide — 877—702—9580
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`Greene’s Energy Group, LLC V. Oil States Energy Services, LLC, IPR2014-00216
`
`Oil States Energy Services, LLC, Ex. 2036
`
`
`
`
`
`December 19, 2014
`
`8:56 a.m.
`
`VIDEOTAPED ORAL DEPOSITION OF GREGG
`
`PERKIN, held at the offices of EPI Corporate
`
`'+ 678 3 +
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`the State of Texas.
`'+.'+
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`Offices, 1310 Kingwood Drive, Kingwood, Texas,
`
`pursuant to the Federal Rules of Civil Procedure
`
`before Linda Rayburn, CSR, RPR, CLR in and for
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`
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`the State of Texas.
`'+.'+
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`Offices, 1310 Kingwood Drive, Kingwood, Texas,
`
`pursuant to the Federal Rules of Civil Procedure
`
`before Linda Rayburn, CSR, RPR, CLR in and for
`
`
`
`
`
`TSG Reporting — Worldwide — 877—702—9580
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`
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`
'
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`A P P E A R A N C E S:
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`FOLEY & LARDNER
`
`BY:
`
`JOHN FELDHAUS
`
`BRADLEY ROUSH
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`A P P E A R A N C E S:
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`FOLEY & LARDNER
`
`BY:
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`JOHN FELDHAUS
`
`BRADLEY ROUSH
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`' :
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`PETER JENNINGS
`+.'+
`
`3000 K Street Northwest
`
`Washington, DC 20007
`
`Counsel for Petitioner
`
`MORGAN LEWIS & BOCKIUS
`
`BY:
`
`C. ERIC HAWES
`
`1000 Louisiana Street
`
`Houston, TX 77002
`
`Counsel for Patent Owner
`
`THE VIDEOGRAPHER:
`
`
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`PETER JENNINGS
`+.'+
`
`3000 K Street Northwest
`
`Washington, DC 20007
`
`Counsel for Petitioner
`
`MORGAN LEWIS & BOCKIUS
`
`BY:
`
`C. ERIC HAWES
`
`1000 Louisiana Street
`
`Houston, TX 77002
`
`Counsel for Patent Owner
`
`THE VIDEOGRAPHER:
`
`
`
`
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`TSG Reporting — Worldwide — 877—702—9580
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`
`
`
+
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`EXAMINATION BY:
`
`BY MR.HAWES
`
`BY MR. FELDHAUS
`
`BY MR. HAWES
`
`REPORTER'S CERTIFICATION
`
`ERRATA SHEET
`
`PREVIOUSLY MARKED EXHIBITS
`
` e
`
`
`EXAMINATION BY:
`
`BY MR.HAWES
`
`BY MR. FELDHAUS
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`BY MR. HAWES
`
`REPORTER'S CERTIFICATION
`
`ERRATA SHEET
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`PREVIOUSLY MARKED EXHIBITS
`
` e
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`Description
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`US Patent 6,179,053
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`2,195,118 Application
`US Patent 4,632,183
`
`Declaration of Gregg S. Perkin
`
`INFORMATION REQUESTED
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`Page Line
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`Description
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`US Patent 6,179,053
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`2,195,118 Application
`US Patent 4,632,183
`
`Declaration of Gregg S. Perkin
`
`INFORMATION REQUESTED
`
`Page Line
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*
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`QUESTIONS INSTRUCTED NOT TO ANSWER
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`QUESTIONS INSTRUCTED NOT TO ANSWER
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`TSG Reporting — Worldwide — 877—702—9580
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`
`
`G. PERKIN
`
`
`
`P-R-O-C-E-E-D-I-N-G-S
`
`THE VIDEOGRAPHER: This is the start
`
`of tape labeled number one in the videotape
`
`deposition of Gregg Perkin in the matter Green's
`
`Energy Group, LLC versus Oil States Energy
`
`Services, LLC,
`
`in the United States Patent &
`
`Trademark Office, Number
`
`IPR 2014—00216,
`
`Patent 6,170,053.
`
`This deposition is being held at EPI,
`
`1310 Kingwood Drive, Kingwood, Texas, on
`
`December 19th, 2014, at approximately 9:23 a.m.
`
`I'm the legal video specialist from
`
`TSG Reporting, Inc., headquartered at 747 Third
`
`Avenue, New York, New York.
`
`The court reporter
`
`is Linda Rayburn in association with TSG
`
`Reporting.
`
`Will counsel please introduce
`
`yourself.
`
`MR. HAWES: Erik Hawes, Morgan, Lewis
`
`
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`
`& Bockius for the patent owner Oil States Energy
`
`Services.
`
`MR. FELDHAUS:
`
`John Feldhaus of Foley
`
`& Lardner for petitioner Greene's Energy Group.
`
`MR. ROUSH: Brad Roush of Foley &
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G. PERKIN
`
`
.
`
`Lardner for petitioner Greene's Energy Group.
`
`THE VIDEOGRAPHER: Will the court
`
`reporter please swear in the witness.
`
`MR. HAWES: This is probably
`
`unnecessary, but I'm just going to say the patent
`
`number that the deposition relates to and that
`
`the proceeding relates to is 6,179,053,
`
`just ——
`
`just so that's on the record.
`
`I'm sure there was
`
`a typo somewhere on there.
`
`GREGG PERKIN,
`
`having been first duly sworn, testified as follows:
`
`EXAMINATION
`
`
`
` 0 "
` * b
`
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`
`Lardner for petitioner Greene's Energy Group.
`
`THE VIDEOGRAPHER: Will the court
`
`reporter please swear in the witness.
`
`MR. HAWES: This is probably
`
`unnecessary, but I'm just going to say the patent
`
`number that the deposition relates to and that
`
`the proceeding relates to is 6,179,053,
`
`just ——
`
`just so that's on the record.
`
`I'm sure there was
`
`a typo somewhere on there.
`
`GREGG PERKIN,
`
`having been first duly sworn, testified as follows:
`
`EXAMINATION
`
`
`
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`BY MR.HAWES:
`
`Q. Mr. Perkin, good morning.
`
`A. Hello.
`
`Q.
`
`Can you state your full name for the
`
`record, please.
`
`A. Gregg Steven Perkin.
`
`Q. And, Mr. Perkin,
`
`I understand from
`
`recent discussions that we've had that you've had
`
`your deposition taken previously maybe somewhere
`
`in the neighborhood of 250 times;
`
`is that right?
`
`A. That's correct.
`
`Q.
`
`So you're pretty well familiar with
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`this process?
`
`A.
`
`I am, but each one is a little
`
`different.
`
`Q. Did you meet with anyone to —— well,
`
`let me just more generally. What did you do to
`
`prepare for your deposition today?
`
`A.
`
`I pulled the declarations out over
`
`
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`
`
`
`
`the weekend, started getting refreshed relative
`
`to giving this deposition today. Mr. Feldhaus
`
`and Mr. Roush provided me with some additional
`
`documents that I requested. And we met
`
`yesterday,
`
`talked about the declarations. And we
`
`talked again this morning.
`
`Q.
`
`So how much time do you think you
`
`spent preparing all in all?
`
`A. Oh, maybe in the neighborhood of
`
`twelve —— twelve hours.
`
`Q. Did you look at documents outside of
`
`the items that are discussed in your two
`
`declarations?
`
`A. Not that I recall.
`
`Q.
`
`Do you remember specifically which
`
`documents you did look at?
`
`A.
`
`I
`
`looked —— in terms of getting
`
`TSG Reporting — Worldwide — 877—702—9580
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`
`
`G. PERKIN
`
`
`
`prepared for the deposition?
`
`Q. Correct.
`
`A.
`
`I just revisited some of the patents,
`
`the '118 patent,
`
`the McLeod patents,
`
`the '243
`
`patents.
`
`I just re—familiarized myself with them
`
`and I colorized a few of the diagrams so I can
`
`see them better.
`
`I brought those with me.
`
`I
`
`took the Bullen patent and enlarged those figures
`
`so I could see it better.
`
`So I did —— I did —— there were some
`
`mechanics involved in documents that I had that I
`
`tried to prepare and make more understandable.
`
`Q. Anything else?
`
`A. Not that I recall.
`
`I mean, it was
`
`just taking what
`
`I already had and trying to
`
`better understand it.
`
`(Exhibit 1014, having been previously
`
`marked was referenced.)
`
`
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`
`Q.
`
`(BY MR. HAWES) Mr. Perkin, can you
`
`look at what's been marked already as
`
`Exhibit 1014 in this case.
`
`Is that one of the
`
`declarations that you recently submitted?
`
`A.
`
`It appears to be, yes.
`
`Do you want
`
`to mark it?
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`It's marked already.
`
`Q.
`
`A. Oh,
`
`is it? Okay.
`
`Q.
`
`Can you look at Addendum D —— or,
`
`sorry, addendum B as in boy?
`
`A. That's my resume.
`
`Q.
`
`Is this current?
`
`A.
`
`It appears to be.
`
`I'm looking at the
`
`second page and the date and I think that's the
`
`date of my latest curriculum vitae.
`
`Q.
`
`Now, as I understand it, the —— the
`
`only experience on this CV specifically relating
`
`to wellhead isolation tools was work that you did
`
`as a draftsman at Regan Forge & Engineering?
`
`A. Yes.
`
`You asked me that question and
`
`I think I gave you what I recall about using
`
`isolations tools or protecting tools that would
`
`isolate a portion of the wellhead or subsea.
`
`Q. And I apologize if there are some
`
`questions here that sound familiar.
`
`The
`
`deposition that we had recently was in connection
`
`with the litigation separate proceeding here for
`
`
`
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`
`the IPR.
`
`I'm going to try to streamline this as
`
`much as possible and not re—ask more questions
`
`than necessary,
`
`there's just some basic facts
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`that need to be on the record in both
`
`proceedings.
`
`A.
`
`I see.
`
`I wasn't thinking it was a
`
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`separate proceeding so much as you were.
`
`Q. Hard to keep them straight sometimes.
`
`And the tool that you worked on in
`
`the 1968—69 timeframe as a draftsman,
`
`that was a
`
`tool that was for offshore use;
`
`is that correct?
`
`A. Yeah. Regan was a designer,
`
`manufacturer, original equipment manufacturer of
`
`subsea blowout preventers, wellhead equipment,
`
`casing hangers, risers,
`
`I mean the whole gamut of
`
`offshore equipment.
`
`Q. And that tool was intended to protect
`
`the wellhead from being damaged by the
`
`drillstring; is that right?
`
`A. Most —— what
`
`I recall is that we
`
`had —— there was a need for protecting critical
`
`surfaces within certain wellhead components such
`
`as casing hangers where you had to actually
`
`engage seals from other devices.
`
`So while
`
`drilling operations were going on or anything
`
`that was going on through the —— through the bore
`
`of that equipment,
`
`through the inside diameter of
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`that equipment,
`
`that those critical surfaces had
`
`to be protected. And more often than not, we had
`
`designed special equipment that would be landed
`
`ahead of that operation. And so then we'd secure
`
`them in place and then we'd run those operations
`
`such as drilling, cementing, whatever, whatever
`
`the case may be.
`
`Q.
`
`It wasn't a tool that had anything to
`
`do with hydraulic fracturing, was it?
`
`A. No, not that I recall. Again, it
`
`was —— hydraulic fracturing would take place on a
`
`completed well or in a completion of a well.
`
`This was more or less to protect the equipment
`
`that's sitting on the ocean floor.
`
`Q.
`
`Can you look at Addendum D to your
`
`declaration.
`
`A. Okay.
`
`Q. This is a list of cases in which
`
`you've testified in the last ten years;
`
`is that
`
`right?
`
`A. Correct.
`
`It's —— it's not complete
`
`as of today, but it is complete as of about
`
`
`
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`
`November of this year.
`
`Q. And I understand that there are four
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`cases on this list that were patent cases in the
`
`sense that they involved allegations of
`
`infringement and/or patent invalidity;
`
`is that
`
`right?
`
`A.
`
`I don't recall if the number was
`
`four, but there are matters here in this document
`
`that are intellectual property related.
`
`Q. Okay.
`
`I believe when we spoke a
`
`
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`
`couple of weeks ago, you identified Varco versus
`
`Pason Systems, Fall Protection Systems versus
`
`Azteca Milling, MacLean—Fogg Company versus Eaton
`
`Corp., and Charles Machine Works versus Vermeer
`
`Manufacturing Company. Does that sound familiar?
`
`A.
`
`Those are all familiar, yes.
`
`Q. Are there any other cases on this
`
`list that were patent cases?
`
`A.
`
`I recall going through this list the
`
`last time.
`
`I think on the first page of
`
`Addendum D,
`
`there was a —— a case styled the
`
`Hasha Family Limited Partnership versus Varco
`
`International,
`
`Incorporated.
`
`It's about the
`
`fifth line or sixth line down. That had patents
`
`involved in that litigation, but it wasn't a
`
`patent litigation, per se.
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G. PERKIN
`
`
'
`
`Q. Okay. Of those four cases,
`
`am I
`
`correct that Varco versus Pason Systems was the
`
`one of the four that involves technology directly
`
`related to oil and gas industry?
`
`A. Of the four you just mentioned, yes,
`
`I think so.
`
`Q. Okay. And what was the technology in
`
`that case?
`
`A. Electronic drilling recorders,
`
`the
`
`methods utilized to do —— to record the —— or to
`
`record or assimilate data from the operations of
`
`the drilling rig, rotating hoisting circulating
`
`system.
`
`Varco had a patent on their
`
`electronic drilling system and they alleged that
`
`Pason infringed it. And it was tried in federal
`
`court in Colorado and ultimately Varco got a
`
`ruling.
`
`They —— they prevailed.
`
`Q.
`
`The technology didn't have anything
`
`to do with hydraulic fracturing or wellhead
`
`isolation tools?
`
`
`
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`Q. Okay. Of those four cases,
`
`am I
`
`correct that Varco versus Pason Systems was the
`
`one of the four that involves technology directly
`
`related to oil and gas industry?
`
`A. Of the four you just mentioned, yes,
`
`I think so.
`
`Q. Okay. And what was the technology in
`
`that case?
`
`A. Electronic drilling recorders,
`
`the
`
`methods utilized to do —— to record the —— or to
`
`record or assimilate data from the operations of
`
`the drilling rig, rotating hoisting circulating
`
`system.
`
`Varco had a patent on their
`
`electronic drilling system and they alleged that
`
`Pason infringed it. And it was tried in federal
`
`court in Colorado and ultimately Varco got a
`
`ruling.
`
`They —— they prevailed.
`
`Q.
`
`The technology didn't have anything
`
`to do with hydraulic fracturing or wellhead
`
`isolation tools?
`
`
`
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`
`A. No, not directly, no.
`
`Q. And I believe you said prior to this
`
`case you had previously worked as an expert in
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
+
`
`one other matter involving wellhead isolation
`
`tools;
`
`is that right?
`
`A.
`
`I think what I recall was you asked
`
`
`
` 0 "
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`
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`tools;
`
`is that right?
`
`A.
`
`I think what I recall was you asked
`
`
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`
`
`me about some of the other work that I do where
`
`wellhead isolation tools were involved. As
`
`I
`
`recall, it was an accident that we investigated
`
`up in —— up in Central Texas.
`
`Q. That was back in the mid—90's
`
`timeframe?
`
`A. As
`
`I recall, yeah.
`
`Q. And involved a failure analysis of
`
`the tool?
`
`A. We actually did some —— we —— a
`
`friend of mine is —— what
`
`I recall, since you
`
`brought it up the last time, what I recall is an
`
`associate of mine, Neil Adams, was involved in
`
`that particular accident.
`
`He and I have written
`
`some papers over the years.
`
`He had a facility in —— here in
`
`Houston that we actually did some testing of
`
`certain components, wellhead isolation components
`
`and other components that are associated with
`
`the —— with the process. But, yeah, it was —— it
`
`was something we —— we actually, you know,
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`investigated and we did test equipment.
`
`Q.
`
`Do you remember what kind of tool was
`
`
`
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`
`involved in that case?
`
`A. No,
`
`I don't.
`
`Q. When were you first contacted to work
`
`on this matter?
`
`A. As
`
`I recall, it was in either April
`
`I can go pull our job sheet, if that
`
`or May.
`
`would be helpful, give you the exact date.
`
`Q. That's close enough.
`
`What was the task for which you were
`
`initially retained?
`
`A. Well, before I was retained, we had
`
`some discussions relative to the patent,
`
`the '053
`
`patent itself, and my background and what our
`
`capabilities here were at Engineering Partners
`
`and also some of our other companies.
`
`When I was retained, it was not
`
`unlike some of the other patent cases we've
`
`been —— we've been asked to support or look
`
`into:
`
`Look at the claims;
`
`look at the prior art;
`
`you know,
`
`try to see if there's —— you know, what
`
`the strengths of the patents are, what the
`
`weaknesses of the patents are;
`
`look at the
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G. PERKIN
`
`
.
`
`allegations and so on.
`
`Q. What was your understanding of the
`
`specific opinions you were being retained to
`
`express?
`
`A. Well, at the time we were retained,
`
`my only charge was to look at the '053 patent and
`
`the prior art and to get a —— get a handle on, if
`
`you will, what —— what that invention was all
`
`about and what preceded it.
`
`Q. What about the '993 patent?
`
`A.
`
`The '993 patent was something that I
`
`looked at.
`
`I don't recall if I
`
`looked at it
`
`early on, but
`
`I have looked at it.
`
`Q. When were you first asked to work on
`
`that aspect of these proceedings?
`
`A.
`
`Probably more with regard to these
`
`
`
` 0 "
`
`
`allegations and so on.
`
`Q. What was your understanding of the
`
`specific opinions you were being retained to
`
`express?
`
`A. Well, at the time we were retained,
`
`my only charge was to look at the '053 patent and
`
`the prior art and to get a —— get a handle on, if
`
`you will, what —— what that invention was all
`
`about and what preceded it.
`
`Q. What about the '993 patent?
`
`A.
`
`The '993 patent was something that I
`
`looked at.
`
`I don't recall if I
`
`looked at it
`
`early on, but
`
`I have looked at it.
`
`Q. When were you first asked to work on
`
`that aspect of these proceedings?
`
`A.
`
`Probably more with regard to these
`
`
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`
`declarations as opposed to the invalidity report
`
`that I just did,
`
`the invalidity deposition that
`
`you just took.
`
`Q.
`
`So when —— when did that happen?
`
`When were you asked to prepare a declaration
`
`relating to the '993 patent?
`
`A.
`
`It had to be —— what's the date on
`
`the declaration? August.
`
`It was probably in the
`
`TSG Reporting — Worldwide — 877—702—9580
`
`
`
`G . PERKIN
`
`
`
`July—August
`
`timeframe. Oh, wait,
`
`I'm sorry. Let
`
`me look at —— I looked at the wrong date.
`
`Q.
`
`I can tell you the declarations were
`
`filed on December 1st, if that helps.
`
`A. Well,
`
`I know that we worked on them
`
`in November and October.
`
`Q. Okay.
`
`A. When we started working on them,
`
`I
`
`don't recall.
`
`My apologies.
`
`I
`
`looked at the issue
`
`date for the —— the patent,
`
`the '053 patent.
`
`Q.
`
`How many hours would you say you
`
`spent preparing the declaration that's marked as
`
`Exhibit 1014?
`
`A.
`
`It would be myself and my associate
`
`Michele Hale.
`
`I would say 30 to 50 hours, maybe,
`
`combined.
`
`Q.
`
`How much of that was your time versus
`
`Ms. Hale's time?
`
`A.
`
`Probably about 50/50.
`
`
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`
`Q.
`
`So you spent 15 to 25 hours, maybe?
`
`A.
`
`In the preparation of the
`
`declaration, yeah; as well as she.
`
`Q. What was her role in preparing this
`
`TSG Reporting — Worldwide — 877—702—9580
`
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`
`
`G. PERKIN
`
`
`
`MR. FELDHAUS: Counsel,
`
`just to
`
`is
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