`Case IPR2014-00364
`
` Patent Owner’s Objections to Demonstratives
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`
`
`GREENE’S ENERGY GROUP, LLC
`Petitioner
`
`v.
`
`OIL STATES ENERGY SERVICES, LLC
`Patent Owner
`
`____________
`
`Case IPR2014-00216
`Patent 6,179,053
`
`Case IPR2014-00364
`Patent 6,289,993
`________________________________________________
`
`PATENT OWNER’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVES
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`
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`1
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`Case IPR2014-00216
`Case IPR2014-00364
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` Patent Owner’s Objections to Demonstratives
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`Pursuant to the Order regarding Trial Hearing on January 16, 2015, Patent
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`Owner Oil States Energy Services, LLC (“OSES”) timely objects to Petitioner’s
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`demonstrative exhibit submission on February 4, 2015 (Ex. 1029). Patent Owner’s
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`objections are set forth with particularity below.
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`Objections
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`Slides
`
`Argumentative
`characterizations
`
`The following slides contain argumentative
`characterizations:
`
` IPR2014-00216
`o Slides 8, 15, 17, 21, 22, 23, 25-29, 33, 36-39,
`42, 44, 45, 48, 49, 50.
`o For example, slides 17, 23, 33, and 42 each
`contain several argumentative
`characterizations, while other listed slides
`include at least one argumentative
`characterization.
` IPR2014-00364
`o Slides 59-60, 65, 67, 70, 72, 77-79
`o For example, slides 65, 70, and 72 each
`contain several argumentative
`characterizations, while other listed slides
`include at least one argumentative
`characterization.
`
`Mischaracterizes the
`Record
`
`The following slides contain citations or arguments that
`mischaracterize the record.
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` IPR2014-00216
`o Slides 22, 24, 26, 29, 36-40, 42-45, 48
`o For example, slides 38 and 39 are contrary to
`deposition testimony provided by petitioner’s
`expert.
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`2
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`Case IPR2014-00216
`Case IPR2014-00364
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`Objections
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`Slides
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` Patent Owner’s Objections to Demonstratives
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` IPR2014-00364
`o Slides 67-68, 89, 93
`o For example, slide 93 mischaracterizes the
`deposition testimony of Dr. Wooley.
`
`Arguments Not
`Previously Presented
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`The following slides contain arguments that were not
`previously presented or not presented in the original
`respective petition.
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` IPR2014-00216
`o Slides 20, 21, 40, 45, 49
`o For example, slide 45 references that McLeod
`“[t]eaches [a] mechanical lockdown
`mechanism is superior to [a] hydraulic
`lockdown,” which is an assertion not
`previously made in any paper.
` IPR2014-00364
`o Slides 70, 77, 89-93
`o For example, slides 89-93 contain arguments
`not presented in the original Petition.
`
`Unsupported by
`Citations to Evidence
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`The following slides either do not include any citations at
`all or do not include any citations to evidence:
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` IPR2014-00216
`o Slides 6, 8, 11, 12, 17, 22-29, 33, 40, 42, 44
`o For example, slide 17 does not includes any
`cites at all, while other slides do not cite to
`evidence.
` IPR2014-00364
`o Slides 65, 70, 73
`o For example, slide 65 does not includes any
`cites at all, while other slides do not cite to
`evidence.
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`3
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`Case IPR2014-00216
`Case IPR2014-00364
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`Objections
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`Slides
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` Patent Owner’s Objections to Demonstratives
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`Cited Support is
`Inapplicable or
`Overly Ambiguous
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`The following slides cite to support that is inapplicable or
`overly ambiguous:
`
` IPR2014-00216
`o Slides 8, 16, 23, 36-40, 42, 44, 45
`o For example, slides 36 and 37 quote deposition
`testimony from Dr. Wooley that is
`inapplicable to the point being made.
` IPR2014-00364
`o Slides 67-68, 89, 90
`o For example, slide 68 characterizes deposition
`testimony from Dr. Wooley in a manner that
`exceeds what was actually said.
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`
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`Dated: February 9, 2015
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`Respectfully submitted,
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`4
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` /C. Erik Hawes/
`C. Erik Hawes
`Registration No. 63,328
`ehawes@morganlewis.com
`MORGAN, LEWIS & BOCKIUS LLP
`1000 Louisiana Street, Suite 4000
`Houston, Texas 77002
`T. 713.890.5165
`F. 713.890.5001
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`Counsel for Patent Owner
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`Case IPR2014-00216
`Case IPR2014-00364
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` Patent Owner’s Objections to Demonstratives
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a true and correct copy of Patent Owner’s
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`Objections to Petitioner’s Demonstratives have been served via email, as
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`previously agreed, to counsel for Petitioner on the 9th day of February, 2015 at the
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`following email addresses:
`
`John J. Feldhaus
`jfeldhaus@foley.com
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`Andrew R. Cheslock
`acheslock@foley.com
`
`Bradley Roush
`broush@foley.com
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`
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`Dated: February 9, 2015
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`Respectfully submitted,
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`5
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` /C. Erik Hawes/
`C. Erik Hawes
`Registration No. 63,328
`Counsel for Patent Owner
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