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`Paper No. __
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`GREENE’S ENERGY GROUP, LLC
`Petitioner
`v.
`
`OIL STATES ENERGY SERVICE, L.L.C.
`Patent Owner
`
`___________________
`
`Case IPR2014-00216
`Patent No. 6,179,053
`___________________
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`PETITIONER OPPOSITION TO MOTION TO AMEND
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`___________________
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`Inter Partes Review No.: 2014-00216
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`Petitioner Opposition to Motion to Amend
`TABLE OF CONTENTS
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`Introduction ...................................................................................................... 1
`I.
`II. Dallas ’118 Includes a “packoff assembly that seals against the fixed-
`point packoff within the tubing head spool” ................................................... 2
`III. Dallas ’118 Requires a “Setting Tool” ............................................................ 3
`IV. A Mechanical Locking Mechanism Was a Known Substitute for a
`Hydraulic Piston and Cylinder at the time of the ’053 Patent ......................... 6
`V. OSES Failed to Demonstrate Commercial Success of the Claimed
`Device. ............................................................................................................. 9
`A.
`Full-Bore Access is Essential for Multistage Isolation Tools ............. 10
`B.
`The Amended Claims Do Not Require Full-Bore Access .................. 11
`C. OSES Fails to Demonstrate Commercial Success of the Claimed
`Device. ...................................................................................... 13
`VI. Conclusion ..................................................................................................... 15
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`Inter Partes Review No.: 2014-00216
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`Petitioner Opposition to Motion to Amend
`EXHIBIT LIST
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`
`
`
`Exhibit
`Ex. #
`1001 U.S. Patent No. 6,179,053 (“’053 patent”)
`1003 Canadian Patent Application 2,195,118 (“Dallas ’118”)
`1004 U.S. Pat. No. 4,632,183 (“McLeod”)
`1005 U.S. Pat. No. 4,076,079 (“Herricks”)
`1009 October 28, 2014 Deposition of L. Murray Dallas (“10/28/14 Dallas
`Dep.”)
`1011 Deposition of Dr. Gary R. Wooley (Nov. 12, 2014) (“Wooley Dep.”)
`1013 Deposition of Thomas W. Britven (Nov. 11, 2014) (“Britven Dep.”)
`1014 Declaration of Gregg S. Perkin In Support Petitioner Opposition to
`Motion to Amend
`1021 U.S. Patent No. 5,372,202 (“Dallas ’202”)
`1022 U.S. Patent No. 4,867,243 (“’243 patent”)
`2012
`Expert Declaration in IPR2014-00216
`for U.S. Patent No. 6,179,053 by Dallas for
`Lockdown Mechanism for Well Tools Requiring Fixed-Point Packoff by
`Dr. Gary R. Wooley (“Wooley Response Decl.”)
`Expert Declaration for the OSES Motion to Amend
`in IPR2014-00216 for U.S. Patent No. 6,179,053 by Dallas for
`Lockdown Mechanism for Well Tools Requiring Fixed-Point Packoff by
`Dr. Gary R. Wooley (“Wooley MTA Decl.”)
`2018 Declaration of Thomas W. Britven (“Britven Decl.”)
`2020 U.S. Patent 4,241,786 (“Bullen”)
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`2017
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`Inter Partes Review No.: 2014-00216
`Petitioner Opposition to Motion to Amend
`I.
`Introduction
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`
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`Patent Owner, Oil States Energy Services, LLC, has moved to amend
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`challenged claims 1 and 22 by adding three limitations: (1) the mandrel includes a
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`packoff assembly that seals against a fixed-point packoff in a tubing head spool of
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`a wellhead assembly; (2) the apparatus includes a setting tool that is removable
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`from the other portions of the apparatus for inserting a bottom end of the mandrel
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`through the wellhead; and (3) the lockdown mechanisms are mechanical and the
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`second lockdown mechanism locks without the use of hydraulic pressure.
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`As discussed in GEG’s Reply, Canadian Patent Application 2,195,118 (“Dallas
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`’118”) (Ex. 1003) discloses every limitation of unamended claims 1 and 22 and
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`therefore clearly anticipates those claims. Moreover, the additional limitations
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`proposed by OSES are present in Dallas ’118 and/or constitute an obvious
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`modification of Dallas ’118, and therefore fail to distinguish the amended claims
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`over the prior art.
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`Dallas ’118 clearly discloses a mandrel with a packoff assembly that seals
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`against a fixed-point packoff in a tubing head spool of a wellhead assembly and
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`therefore identically meets limitation (1).
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`With respect to limitation (2), the mandrel of Dallas ’118 protrudes from the
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`bottom of the tool and a separate tool is required to insert the bottom end of the
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`mandrel through the wellhead. As used in the ’053 patent, the nonspecific term
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`Inter Partes Review No.: 2014-00216
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`Petitioner Opposition to Motion to Amend
`“setting tool” applies to any tool used for this purpose and therefore limitation (2)
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`is met by Dallas ’118. At the very least, it would have been obvious to use exactly
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`the same prior art separate “setting tool” as disclosed in the ’053 patent to insert
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`the mandrel of Dallas ’118.
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`Finally, the prior art makes clear that use of a well-known wellhead isolation
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`tool mechanical lockdown mechanism in place of a hydraulic locking mechanism
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`as required by limitation (3) was a design choice that would have been obvious to
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`one of ordinary skill at the time of the filing date of the ’053 patent in 1999.
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`OSES also alleges that the tool of amended claim 1 achieved commercial
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`success. However, OSES fails to show any nexus between the alleged commercial
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`success and amended claim 1. In addition to all of the features of amended claim 1
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`being shown in the prior art, OSES admits that full bore access is required for
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`commercial success, but is not a feature of amended claim 1.
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`II. Dallas ’118 Includes a “packoff assembly that seals against the fixed-
`point packoff within the tubing head spool”
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`The first additional feature proposed by OSES in amended claims 1 and 22, a
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`packoff assembly that seals against a fixed-point packoff within a tubing head
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`spool, is identically met in the Dallas ’118.
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`In Figs. 3 and 4 of Dallas ’118, shown below, the mandrel of claims 1 and 22 is
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`met by mandrel 28, mandrel extension 58 and packoff assembly 68, which packs
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`off in tubing head spool 82. Dallas ’118, 00014:9-13, 00014:25-29, 00015:17-31;
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`Inter Partes Review No.: 2014-00216
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`Petitioner Opposition to Motion to Amend
`see also Ex. 1014, Perkin Decl., ¶¶ 38-39. Although Dallas ’118 refers to element
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`82 as a “tubing head,” as Dr. Wooley explained, the terms “tubing head,” “tubing
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`head spool,” and “tubing spool” are used interchangeably in the art to describe the
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`same component. Ex. 1011, Wooley Dep., 20:16-21:8; see also Perkin Decl., ¶ 39.
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`Dallas ’118, Figs. 3-4.
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`Element 68 of Dallas ’118 is a packoff assembly that seals against bit guide 84,
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`which forms a fixed point in the tubing head spool 82. Dallas ’118, 000016:1-12;
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`000016:31-000017:3; see also Perkin Decl., ¶ 39. Accordingly, this addition to the
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`claims proposed by OSES is fully met by Dallas ’118.
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`III. Dallas ’118 Requires a “Setting Tool”
`OSES argues that Dallas ’118 does not disclose a separate “setting tool” as
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`required by the amended claims. However, OSES never defines “setting tool” and
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`never explains the basis of its argument that this feature is not met by Dallas ’118.
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`Petitioner Opposition to Motion to Amend
`As shown in Figs. 7 and 8 of the ’053 patent, the bottom of mandrel 22 extends
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`below the base 28 of the isolation tool. Because of this configuration, a separate
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`“setting tool” is used to insert the bottom end of the mandrel into the well. See
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`Perkin Decl. ¶ 44. After the mandrel is inserted into the well, the “setting tool” is
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`removed and the second lockdown mechanism moves the mandrel downwardly to
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`seal the bottom of the mandrel against the fixed point for packoff 24 in the tubing
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`spool 102. ’053, 8:5-34; see also Perkin Decl. ¶ 45.
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`As shown in Figs. 3 and 4 of Dallas ’118 (above), the mandrel extension 58
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`extends below the base 22 of the isolation tool in part to accommodate wells with
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`different configurations including tubing spools with different diameters (Dallas
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`’118, 00016:1-12). See also Perkin Decl. ¶¶ 48-49. Consequently, a separate tool
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`is needed to insert the mandrel of Dallas ’118 into the wellhead. See Perkin Decl.
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`¶¶ 48-52. A crane truck with additional gear or a specialized tool could be used for
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`this purpose. See Perkin Decl. ¶¶ 53-54, 59. In either case, the term “setting tool”
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`would be an appropriate description for the tool. Perkin Decl. ¶¶ 54, 59.
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`OSES does not define the term “setting tool.” Dr. Wooley’s Patent Owner
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`Response Declaration describes a setting tool as a “mandrel injection mechanism”
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`and he testified that the term “setting tool” is nonspecific, but is “usually the name
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`given to a device for inserting some sort of tool.” Ex. 2012, Wooley Response
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`Petitioner Opposition to Motion to Amend
`Decl., ¶ 36; Wooley Dep., 61:17-21. Dr. Wooley did not provide any limitation on
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`the use of this term.
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`Dr. Wooley agreed that the mandrel extension 58 and packoff assembly 68 of
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`Figs. 3 and 4 of Dallas ’118 must always extend below the base 22 of the BOP
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`protector 10. See Wooley Dep., 55:24-56:14. He also agreed that the mandrel
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`extension 58 must be inserted into the wellhead prior to the ’118 tool being bolted
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`onto the wellhead by a tool which could be called a “setting tool.”
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`Q. Right. So the ’118 patent actually teaches that the extension should
`be protruding below the bottom of the cylinder; isn't that correct?
`A. In Figure 3, yes.
`Q. Yes. So if it’s protruding below the bottom of the cylinder, then
`you do need some other implement to put it into the well in the first
`place; isn’t that correct?
`A. That’s possible.
`Q. Okay. And one could call that implement a setting tool, if one
`desired, couldn’t they?
`A. People can use whatever names they like.
`Wooley Dep., 55:24-56:14.
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`OSES own expert therefore agrees that a separate tool, which can be called a
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`“setting tool” must be used to insert the bottom of the mandrel of Dallas ’118 into
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`the well. Dr. Wooley also agreed that a crane truck or a specialized tool could be
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`used for this purpose. Wooley Dep., 62:4-13.
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`Petitioner Opposition to Motion to Amend
`Even if the newly claimed ’053 “setting tool” referred to a specialized tool, it
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`would have been obvious to a person of ordinary skill in the art in 1999 to use such
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`a specialized tool to insert the mandrel of Dallas ’118 Fig. 3 into a well. See
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`Perkin Decl., ¶¶ 55-59. Indeed, the ’053 patent does not purport to have invented a
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`separate “setting tool.” Rather, the ’053 patent refers to known prior art tools as
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`“setting tools.” ’053 patent, 8:43-48; 9:67-10:12. For example, the separate
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`“setting tool” shown in Figs. 8 and 9 of the ’053 patent is the tool disclosed in
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`another one of Mr. Dallas’s prior art patents, U.S. Patent No. 4,867,243 (the “’243
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`patent”) (Ex. 1022). ’053 patent, 8:43-48.
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`A person of ordinary skill in the art would have known that a separate,
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`specialized “setting tool” such as the ’243 patent could be used to insert the
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`mandrel of Dallas ’118 into the well. See Perkin Decl., ¶ 59. OSES never argues
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`otherwise and failed to meet its burden to demonstrate the patentability of amended
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`claims 1 and 22.
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`IV. A Mechanical Locking Mechanism Was a Known Substitute for a
`Hydraulic Piston and Cylinder at the time of the ’053 Patent
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`OSES argues that Dallas ’118 relies on hydraulic pressure to secure the mandrel
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`in position and therefore cannot meet the newly added limitation requiring the
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`mandrel to be locked without the use of hydraulic pressure. It is correct that the
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`’053 patent suggests a mechanical locking mechanism because a hydraulic
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`lockdown mechanism is considered less secure since “hydraulic pressure may be
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`Petitioner Opposition to Motion to Amend
`lost for a variety of reasons.” ’053 patent, 3:5-9. However, OSES never addresses
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`the obviousness of substituting a mechanical mechanism for the hydraulic
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`mechanism of Dallas ’118 in view of the many prior art teachings of just such a
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`substitution to avoid the possibility of pressure loss in a hydraulic system.
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`The basic teaching of Dallas ’118 is a tool with broad adjustability to force a
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`mandrel downwardly to form a seal against a bit guide in a wellhead. See Dallas
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`’118, 000015:17-000016:12, 000016:31-000017:3; see also Perkin Decl., ¶ 61.
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`Dallas ’118 teaches that a hydraulic cylinder and piston would serve this purpose.
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`Dallas ’118, 000015:23-000016:12; see also Perkin Decl., ¶ 61.
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`During the 1998-99 time frame, several prior art patents in the wellhead
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`isolation tool art specifically disclose that mechanical locking mechanisms can be
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`substituted for or used in addition to hydraulic locking mechanisms to avoid
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`potential problems with hydraulic seals. For example, U.S. Pat. No. 4,632,183
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`(“McLeod”) (Ex. 1004) discloses that drive systems for inserting high pressure
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`tubing using hydraulic cylinders were known in the art. McLeod gives as one
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`example Canadian Pat. No. 1,094,945 (which is equivalent to U.S. Patent
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`4,241,786 (“Bullen”) (Ex. 2020)), which uses one or a pair of hydraulic cylinders
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`to insert and hold the mandrel of a wellhead isolation tool in an operative position.
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`McLeod discloses that hydraulic cylinders generally function in an acceptable
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`manner, but “. . . have seals which can leak and cause movement problems and
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`Petitioner Opposition to Motion to Amend
`sometimes complete failure of the system.” McLeod, 1:19-22. To avoid the
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`potential problems with hydraulic systems, McLeod teaches using a self-locking
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`screw jack in place of the hydraulic cylinder of Bullen for inserting and holding a
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`mandrel of a wellhead isolation tool in position. Based on this teaching, McLeod
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`suggests a system in which the mandrel is held in position with a mechanical
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`mechanism. See also Perkin Decl., ¶¶ 63-65.
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`Dr. Wooley agreed that the screws of McLeod can be used to hold a mandrel in
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`position:
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`Q. Okay. That’s right. And McLeod uses a screw to hold it in
`position?
`A. That’s correct.
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`Wooley Dep., 46:12-14.
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`A person of ordinary skill in the art would have considered it obvious at the
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`time of the ’053 patent to use a mechanical mechanism such as a self-locking
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`screw jack, as taught by McLeod, in place of the hydraulic cylinder of Dallas ’118
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`in order to avoid the drawbacks of hydraulic cylinders. See Perkin Decl., ¶ 65, 71.
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`Further, Bullen itself even teaches that mechanical locking mechanisms, such as
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`latches and screwed unions, can be used to reinforce hydraulic cylinders. Bullen,
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`4:25-37; see also Perkin Decl., ¶ 67.
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`Likewise, U.S. Patent 5,372,202 another patent naming Mr. Dallas as the sole
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`inventor (“Dallas ’202”) (Ex. 1021) also teaches that a mechanical system for
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`Petitioner Opposition to Motion to Amend
`inserting and holding an isolation tool mandrel is more reliable than a purely
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`hydraulic system:
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`In addition, the ball screw 90 can be locked in any position even in the
`event that hydraulic pressure to the drive motor (not illustrated) is lost
`due to a mechanical malfunction or a hydraulic seal rupture. This
`ensures that a mandrel cannot be ejected from a well during a well
`stimulation operation.
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`Dallas ’202, 9:55-61; Perkin Decl., ¶¶ 66, 72.
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`Therefore, although a determination of obviousness based on teachings from
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`multiple references does not require an actual, physical substitution of elements
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`(See In re Mouttet, 686 F.3d 1322, 1332 (Fed. Cir. 2012)), a person of ordinary
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`skill in the art would have recognized that a mechanical locking mechanism, such
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`as a screw, could be used in place of or in addition to Dallas ’118’s hydraulic
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`locking mechanism. See also Perkin Decl., ¶¶ 69-72. OSES failed to consider
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`such prior art teachings and has failed to carry its burden to demonstrate the
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`patentability of amended claims 1 and 22.
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`V. OSES Failed to Demonstrate Commercial Success of the Claimed
`Device.
`OSES argues that the alleged invention of amended claim 1 has achieved
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`commercial success based on revenue data from a “Stage Frac Tool” used by
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`OSES. OSES has not alleged commercial success for amended claim 22:
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`Petitioner Opposition to Motion to Amend
`Q. All right. So your declaration is only in support of an amendment
`to claim 1; is that right?
`A. That’s correct, sir.
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`Ex. 1013, Britven Dep., 6:24-7:3.
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`According to OSES’s own witnesses, the driving factor behind any commercial
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`success of the Stage Frac Tool is that the Stage Frac Tool provides full-bore access
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`to the casing. However, as admitted by OSES own witnesses, although the prior
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`art including Dallas ’118 clearly shows isolation tools with full bore access,
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`amended claim 1 is not limited to wellhead isolation tools that provide full-bore
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`access.
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`Full-Bore Access is Essential for Multistage Isolation Tools
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`A.
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`Full-bore access refers to a wellhead isolation tool that has a mandrel with an
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`inner diameter that is either larger or substantially the same as the inner diameter
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`of the casing of the well. See Perkin Decl. ¶ 77; see also Ex. 2017, Wooley MTA
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`Decl., ¶ 27. By having such a mandrel, the wellhead isolation tool is able to
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`provide access to a casing such that fracking fluids, plugs and perforating guns can
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`be run through the tool without the diameter of the mandrel creating any sort of
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`obstruction. See Perkin Decl., ¶ 78; see also Wooley MTA Decl., ¶ 27. This
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`allows perforating guns and plugs to be inserted into and removed from a well
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`during a multistage fracking operation without the removal of the wellhead
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`isolation tool. See Perkin Decl., ¶ 78; see also Wooley MTA Decl., ¶ 27. Because
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`Petitioner Opposition to Motion to Amend
`the wellhead isolation tool does not need to removed, several stages can be fracked
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`at a time before the wellhead isolation tool needs to be removed, thereby creating
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`significant savings in time. Wooley MTA Decl., ¶ 127; Ex. 1009, 10/28/14 Dallas
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`Dep., 34:15-35:15; see also Perkin Decl., ¶ 79.
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`The Amended Claims Do Not Require Full-Bore Access
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`B.
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`The words “full bore access” are nowhere in the amended claims. Wooley
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`Dep., 66:7-12. Moreover, although Dr. Wooley’s declaration lists as one of the
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`elements of the amended claims “The mandrel having substantially the same inner
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`diameter as the casing of the well, and including a packoff assembly that seals
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`against the fixed-point packoff within the tubing head spool,” on cross examination
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`Dr. Wooley admitted that this feature is not in the amended claims. Wooley MTA
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`Decl., page 52 (between ¶¶ 121 and 122); Wooley Dep., 73:5-12.
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`OSES and Dr. Wooley appear to take the position that a fixed-point packoff in
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`the tubing head spool is sufficient for commercial success. Wooley MTA Decl., ¶
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`126. However, the evidence is clear that an isolation tool with a fixed point
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`packoff in a tubing head spool does not alone provide full-bore access. For
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`example, Fig. 9 of the ’053 patent discloses an isolation tool with a fixed-point
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`packoff that does not provide full-bore access.
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`Fig. 9 of the ’053 patent, below, shows a wellhead isolation tool with a mandrel
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`Petitioner Opposition to Motion to Amend
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`22 sealed in a tubing hanger 122 mounted inside tubing spool 120. ’053 patent,
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`9:31-62; Perkin Decl., ¶¶ 81-82. The mandrel 22 seals against an annular step on
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`the tubing hanger inside the tubing spool. This seal is a fixed point packoff. ’053
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`patent, 9:50-52. However, Fig. 9 shows the mandrel 22 extending into the
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`production tubing 134, thereby precluding full-bore access to the casing because,
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`as is well known, the production tubing has a smaller diameter than the casing and
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`is positioned inside the casing. See Perkin Decl., ¶ 82.
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`Accordingly, Fig. 9 of the ’053 patent shows a wellhead isolation tool with a
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`fixed-point packoff in a tubing head spool that does not provide full-bore access to
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`the casing, yet Fig. 9 still embodies all of the limitations of the amended claims,
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`including a separate setting tool and mechanical first and second lockdown
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`mechanisms. Perkin Decl., ¶ 83. OSES does not and could not argue that the
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`embodiment of Fig. 9 has met with commercial success.
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`Petitioner Opposition to Motion to Amend
`Also, prior art U.S. Patent No. 4,076,079 (“Herricks”) (Ex.1005) discloses in
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`Fig. 1, a wellhead isolation tool with a fixed-point packoff within a tubing head
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`spool, which it describes as “Prior Art.” See Perkin Decl., ¶ 84. This prior art tool
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`uses a mandrel with an inner diameter that is substantially smaller than the inner
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`diameter of the well casing and therefore does not provide full-bore access. See
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`Perkin Decl., ¶ 84. In fact, the very invention of Herricks is an improved apparatus
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`of Fig. 2 that has a fixed-point packoff in a tubing head spool that provides full-
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`bore access to the casing. See Perkin Decl., ¶ 86. Herricks is further evidence that
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`a fixed point packoff inside a tubing spool does not of itself provide full bore
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`access to the casing.
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`It is clear, therefore that the amended claims do not require full-bore access.
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`Perkin Decl., ¶ ¶ 80-85.
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`C. OSES Fails to Demonstrate Commercial Success of the Claimed
`Device.
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`As is apparent from the foregoing, any commercial success that may have been
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`enjoyed by OSES’ Stage Frac Tool was a result of full-bore access, a feature that
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`lacks a nexus to the amended claims, and is thus legally irrelevant. First, any
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`commercial success must be the result of a claimed feature. See Ormco Corp. v.
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`Align Tech., Inc., 463 F.3d 1299, 1312 (Fed. Cir. 2006) (“[I]f the commercial
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`success is due to an unclaimed feature of the device, the commercial success is
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`Petitioner Opposition to Motion to Amend
`irrelevant.”); In re Kao, 639 F.3d 1057, 1068 (Fed. Cir. 2011) (“Where the offered
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`secondary consideration actually results from something other than what is both
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`claimed and novel in the claim, there is no nexus to the merits of the claimed
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`invention.”).
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`Further, even if the amended claims are broad enough to encompass isolation
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`tools with full-bore access, OSES’s alleged commercial success is still irrelevant,
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`because full-bore access is not commensurate with the scope of the amended
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`claims. See Therasense, Inc. v. Becton, Dickinson & Co., 593 F.3d 1325, 1336
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`(Fed. Cir. 2010) (“Because the claims are broad enough to cover devices that either
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`do or do not solve the ‘short fill’ problem, Abbott’s objective evidence of non-
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`obviousness fails because it is not commensurate in scope with the claims which
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`the evidence is offered to support.”).
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`Moreover, every element of the claimed invention is clearly present in the prior
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`art. As discussed in the Petitioner Reply and above, all of the elements of the
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`original claims are found in Dallas ’118 as is the newly claimed packing assembly
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`that seals against a fixed point in the tubing spool. Also, as discussed above, the
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`use of a separate setting tool was either required by Dallas ’118 or was well known
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`in the prior art and clearly would have been obvious to use with the Dallas ’118
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`tool. Finally, mechanical lockdown mechanisms were well known in the prior as a
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`more reliable alternative to hydraulic mechanisms and the use of such mechanical
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`Petitioner Opposition to Motion to Amend
`mechanisms in the Dallas ’118 tool would have been obvious in the 1998-99
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`timeframe. For this reason as well, OSES commercial success evidence is
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`irrelevant. See Galderma Labs., L.P. v. Tolmar, Inc., 737 F.3d 731, 740 (Fed. Cir.
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`2013) (“[I]f the feature that creates the commercial success was known in the prior
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`art, the success is not pertinent.” quoting Ormco, 463 F.3d at 1312; Tokai Corp. v.
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`Easton Enters., 632 F.3d 1358, 1369 (Fed. Cir. 2011) (“If commercial success is
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`due to an element in the prior art, no nexus exists.”).
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`Finally, the unclaimed feature of full-bore access was well known in the art as
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`of 1999 as evidenced by Dallas ’118 (Ex. 1003, 000012:9-16) and Herricks (Ex.
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`1004, 1:49-54). See Perkin Decl., ¶¶ 86-88. Thus, even if this feature had been
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`claimed, the result would be no different.
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`VI. CONCLUSION
`For the foregoing reasons, Petitioner respectfully requests that OSES motion to
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`amend claims 1 and 22 be denied.
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`Dated: December 1, 2014
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`Respectfully submitted,
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`By:
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`/s/ John J. Feldhaus
`John J. Feldhaus
`Reg. No. 28,822
`Counsel for Petitioner
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`15
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`Inter Partes Review No.: 2014-00216
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`Petitioner Opposition to Motion to Amend
`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e)(4)(i), the undersigned certifies that on
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`December 1, 2014, a complete and entire copy of “Petitioner Opposition to Motion
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`to Amend” was provided via email, as previously agreed, to the representatives of
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`the Patent Owner by serving the correspondence email address of record as
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`follows:
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`Erik Hawes
`ehawes@morganlewis.com
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`Archis (Neil) Ozarkar
`nozarkar@morganlewis.com
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`By:
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`/s/ John J. Feldhaus
`John J. Feldhaus
`Reg. No. 28,822
`Counsel for Petitioner
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