`Patent No. 6,431,294
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FLOTEK INDUSTRIES, INC., and TURBECO, INC. (d/b/a SPIDLE TURBECO,
`d/b/a GALLEON TURBECO and d/b/a CAVO DRILLING MOTORS) and
`TELEDRIFT COMPANY (d/b/a SPIDLE TURBECO),
`Petitioner,
`v.
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`NATIONAL OILWELL DHT, L.P.,
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`Patent Owner
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`Case IPR2015-01210
`Patent 6,431,294
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`PATENT OWNER’S LIST OF ANTICIPATED MOTIONS
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`Case IPR2015-01210
`Patent No. 6,431,294
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`Pursuant to the Office Patent Trial Practice Guide, 77 Fed. Reg. 48756,
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`48765-66 (Aug. 14, 2012) and in advance of the initial conference call scheduled
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`for Thursday, December 3 at 2:00pm EST, Patent Owner National Oilwell DHT,
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`L.P. (“NOV”) submits the following list of proposed motions. This listing is
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`without prejudice to NOV’s right to seek authorization to bring additional motions
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`as circumstances warrant. See, Office Patent Trial Practice, Fed. Reg. Vol. 77, No.
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`157 at 48763 (Aug. 14, 2012).
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`Although a first motion to amend claims, motions for observations on cross-
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`examination, and motions to exclude evidence are automatically authorized by the
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`Board, Patent Owner identifies such motions to preserve its right to file them. This
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`list is provided without prejudice to Patent Owner’s right to seek authorization to
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`file additional motions or to decide not to file motions listed.
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`1. Motion for Modification of Scheduling Order. As needed, NOV may contact
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`counsel for Petitioner to potentially seek agreement for a joint motion to extend
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`Due Dates.
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`2. Motion for Discovery. The parties did not agree, prior to institution of the trial,
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`to exchange of the initial disclosures set forth in the Office Patent Trial Practice
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`Guide. Pursuant to 37 C.F.R. § 42.51(a)(2), NOV would move to seek
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`discovery of such information. NOV may also move for additional discovery.
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`3. Motion to Exclude under 37 C.F.R. § 42.64. The need for, and nature of, such a
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`Case IPR2015-01210
`Patent No. 6,431,294
`motion may be impacted by any supplemental evidence Petitioner submits in
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`response to NOV’s Objections to Evidence.
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`4. Motion for Observations on cross-examination testimony of a Petitioner’s reply
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`witness.
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`5. Motion to Amend Claims under 37 C.F.R. § 42.121.
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`6. Motion to Substitute Lead and/or Back-Up Counsel as needed.
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`Respectfully submitted:
`/JL Jennie Salazar/
`JL Jennie Salazar, Reg. No.:
`45,065
`THE JL SALAZAR LAW FIRM,
`PLLC
`1934 W. Gray, Suite 401
`Houston, Texas 77002
`Phone: 713-528-1200
`Fax: 713-528-1202
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`Date: November 30, 2015
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`Case IPR2015-01210
`Patent No. 6,431,294
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`The undersigned hereby certifies that on November 30, 2015 a copy of:
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`PATENT OWNERS LIST OF ANTICIPATED MOTIONS
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`was served on counsel for the Petitioner via email (according to paragraph I.D.,
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`page 2, of the Petition) to:
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`James P. Murphy and Andrew Weaver at Flotek-IPR@novakdruce.com.
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`/JL Jennie Salazar/
`JL Jennie Salazar,
`Reg. No. 45,065
`THE JL SALAZAR LAW FIRM, PLLC
`1934 W. Gray, Suite 401
`Houston, Texas 77002
`Email: jls@jlsalazar.com
`Tele: (713) 528-1200
`Fax: (713) 528-1202
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