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CONTAINS POSSIBLE MATERIAL TO BE DESIGNATED AS CONFIDENTIAL - ATTORNEYS' EYES ONLY
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`Page 1
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` 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
`
` CONTAINS CONFIDENTIAL
` ATTORNEYS' EYES ONLY INFORMATION
` VIDEOTAPED ORAL DEPOSITION OF
` THOMAS W. BRITVEN
` Houston, Texas
` Tuesday, November 11, 2014
`
`Reported by:
`MICHAEL E. MILLER, FAPR, RDR, CRR
`Notary Public
`JOB NO. 87045
`
`TSG Reporting - Worldwide 877-702-9580
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`00001
`
`GREENE'S ENERGY 1013
`Greene's Energy v. Oil States IPR2014-216
`
`

`

`CONTAINS POSSIBLE MATERIAL TO BE DESIGNATED AS CONFIDENTIAL - ATTORNEYS' EYES ONLY
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`Page 2
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` November 11, 2014
` 9:03 a.m.
`
` VIDEOTAPED ORAL DEPOSITION OF THOMAS W.
`BRITVEN, held at the offices of Morgan Lewis &
`Bockius LLP, 1000 Louisiana Street, Suite 4000,
`Houston, Texas, pursuant to the Federal Rules of
`Civil Procedure before Michael E. Miller, Fellow
`of the Academy of Professional Reporters,
`Registered Diplomate Reporter, Certified Realtime
`Reporter and Notary Public in and for the State
`of Texas.
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`GREENE'S ENERGY 1013
`Greene's Energy v. Oil States IPR2014-216
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`

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`CONTAINS POSSIBLE MATERIAL TO BE DESIGNATED AS CONFIDENTIAL - ATTORNEYS' EYES ONLY
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`Page 3
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` T. BRITVEN
`A P P E A R A N C E S:
` FOLEY & LARDNER
` BY: JOHN FELDHAUS, ESQUIRE
` BRADLEY ROUSH, ESQUIRE
` 3000 K Street, NW
` Washington, D.C. 20007
` Counsel for Petitioner
`
` MORGAN LEWIS & BOCKIUS
` BY: CRYSTAL AXELROD, ESQUIRE
` 1000 Louisiana Street
` Houston, Texas 77002
` Counsel for Patent Owner
`
`ALSO PRESENT:
` Pam Longoria, Videographer
`
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`00003
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`GREENE'S ENERGY 1013
`Greene's Energy v. Oil States IPR2014-216
`
`

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`CONTAINS POSSIBLE MATERIAL TO BE DESIGNATED AS CONFIDENTIAL - ATTORNEYS' EYES ONLY
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` T. BRITVEN
` PROCEEDINGS
` (November 11, 2014 at 9:03 a.m.)
` THE VIDEOGRAPHER: This is the start
`of tape labeled number 1 of the videotaped
`deposition of Thomas Britven in the matter
`Greene's Energy Group LLC v. Oil States Energy
`Services LLC.
` This deposition is being held at
`1000 Louisiana Street, Suite 4000, Houston,
`Texas, 77002, on November 11th, 2014, at
`approximately 9:03 a.m.
` My name is Pam Longoria. I'm the
`Legal Video Specialist from TSG Reporting Inc.,
`headquartered at 747 Third Avenue, New York,
`New York. The court reporter is Mike Miller in
`association with TSG Reporting.
` Will counsel please introduce
`yourselves.
` MR. FELDHAUS: John Feldhaus of
`Foley & Lardner for petitioner Greene's Energy
`Group.
` MR. ROUSH: Brad Roush of Foley &
`Lardner for petitioner Greene's Energy Group.
` MS. AXELROD: Crystal Axelrod, Morgan
`
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`Greene's Energy v. Oil States IPR2014-216
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`Page 5
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` T. BRITVEN
`Lewis & Bockius, for respondent Oil States Energy
`Services.
` THE VIDEOGRAPHER: Will the court
`reporter please swear in the witness.
` THOMAS W. BRITVEN,
` having been duly sworn,
` testified as follows:
` EXAMINATION
`BY MR. FELDHAUS:
` Q. Good morning, Mr. Britven.
` A. Good morning.
` Q. And is that correct, should I call
`you "Mr. Britven"? Are you a doctor, or is
`there --
` A. No, no, "mister" is fine.
` Q. Okay. Okay. Fine. Thanks.
` Could you state your full name for
`the record, please?
` A. Thomas William Britven.
` (Deposition Exhibit 1008 marked.)
`BY MR. FELDHAUS:
` Q. And I'll show you what's been marked
`for identification as Exhibit 1008, which is a
`notice of deposition in Case IPR 2014-00216. Are
`
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`Greene's Energy v. Oil States IPR2014-216
`
`

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`Page 6
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` T. BRITVEN
`you appearing today pursuant to this notice, sir?
` A. Yes, sir.
` Q. And I'll give you a copy of what's
`been marked as Exhibit 2018, which is a
`declaration of Thomas Britven. Is Exhibit 2018
`your declaration, sir?
` A. No, I don't believe so.
` Q. May I see it again?
` A. Surely. There appears to be some
`highlighting on page 12.
` Q. Oh, I'm sorry. Here, let me give you
`this one.
` A. Do you have a clean copy?
` Q. I'll give you that one.
` A. Yes, this is my declaration.
` Q. And you submitted this declaration in
`support of a motion to amend claims 1 and 22 of
`U.S. Patent 6,179,053; is that correct?
` A. I think it's with regards to claim
`number 1. I saw the -- I think it's with regards
`to claim 1, and I think the reference to 22 was
`an error.
` Q. All right. So your declaration is
`only in support of an amendment to claim 1; is
`
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`Greene's Energy v. Oil States IPR2014-216
`
`

`

`CONTAINS POSSIBLE MATERIAL TO BE DESIGNATED AS CONFIDENTIAL - ATTORNEYS' EYES ONLY
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`Page 7
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` T. BRITVEN
`that right?
` A. That's correct, sir.
` Q. All right. So when did you first
`become involved in this case, this IPR?
` A. I'm not sure.
` Q. Well, when were you first contacted
`for purpose of preparing this declaration?
` A. I don't remember that either.
` Q. Was it a year ago, less than a year
`ago?
` A. Probably over a year ago. Sometime
`in 2013.
` Q. And what's your current employment,
`sir?
` A. ASQ Consulting.
` Q. What is ASQ Consulting?
` A. It's a consulting firm, much --
`providing many of the same services as my
`predecessor employer, Duff & Phelps.
` Q. Would you turn to Attachment 1 of
`your declaration.
` A. Yes.
` Q. Is that your CV?
` A. That's an older version of my CV,
`
`TSG Reporting - Worldwide 877-702-9580
`
`00007
`
`GREENE'S ENERGY 1013
`Greene's Energy v. Oil States IPR2014-216
`
`

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