`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS, INC.,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-00596 (Patent 7,134,505)
`Case IPR2016-00597 (Patent 7,543,634)
`Case IPR2016-00598 (Patent 7,861,774)
`Case IPR2016-00656 (Patent 8,657,009)
`Case IPR2016-00657 (Patent 9,074,451)
`___________________
`
`
`
`
`
`
`
`
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S REQUEST FOR
`ORAL ARGUMENT
`
`
`
`
`
`
`
`
`
`
`
`Exclusive Licensee, Rapid Completions LLC, by and through its attorneys,
`
`respectfully requests oral argument, currently scheduled for May 18, 2017.
`
`If the Board determines that live testimony from the parties’ declarants will
`
`assist the Board, Rapid Completions requests that the oral argument be structured
`
`as follows:
`
`• Each side is permitted ten minutes of attorney argument for an
`
`opening statement.
`
`• Each side is permitted 2-3 hours to divide up as each party sees fit
`
`between direct, cross, and redirect, etc. of the experts concerning the
`
`issues raised in IPR2016-00596, IPR2016-00597, IPR2016-00598.
`
`• Each side is permitted one hour of oral argument time to address the
`
`issues raised in IPR2016-00596, IPR2016-00597, IPR2016-00598,
`
`IPR2016-00656, and IPR2016-00657.
`
`If the Board determines that live testimony is unnecessary, Rapid
`
`Completions requests that each party be granted ninety minutes of oral argument
`
`time to address the issues raised in IPR2016-00596, IPR2016-00597, IPR2016-
`
`00598, IPR2016-00656, and IPR2016-00657.
`
`Rapid Completions respectfully requests that it be permitted to reserve up to
`
`fifteen (15) minutes of its’ oral argument time for after Petitioner’s reply to
`
`highlight issues in petitioner’s reply that exceed the proper scope of a reply.
`
`
`
`1
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.70, and without intending to waive any issue not
`
`specifically identified, Rapid Completions specifies the following issues to be
`
`argued:
`
`1.
`
`Petitioner failed to meet its burden of proving that the instituted claims
`
`are unpatentable under any grounds in the Petition;
`
`2.
`
`Petitioner’s Reply raises issues that go beyond the scope of a proper
`
`reply;
`
`3.
`
`4.
`
`decision.
`
`Any issues identified in Petitioner’s Request for Oral Argument;
`
`Any other issues the Board deems necessary for issuing a final written
`
`Rapid Completions requests that the Board provide audio-visual equipment
`
`to display demonstrative exhibits, including a projector to be connected to a laptop
`
`and a screen for displaying documents.
`
`
`
`Dated: April 14, 2017
`
`
`
`
` Respectfully submitted,
`
`Rapid Completions LLC
`
`
`By /Justin T. Nemunaitis/
`Hamad M. Hamad, Reg. No. 64,641
`Bradley W. Caldwell (pro hac vice)
`Justin T. Nemunaitis (pro hac vice)
`CALDWELL CASSADY CURRY, P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
`Telephone: 214.888.4848
`2
`
`
`
`
`
`
`
`Facsimile: 214.888.4849
`hhamad@caldwellcc.com
`bcaldwell@caldwellcc.com
`jnemunaitis@caldwellcc.com
`rapid@caldwellcc.com
`
`Dr. Gregory Gonsalves, Reg. No. 43,639
`GONSALVES LAW FIRM
`2216 Beacon Lane
`Falls Church, Virginia 22043
`Telephone: 571.419.7252
`gonsalves@gonsalveslawfirm.com
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`
`
`
`
`
`
`The undersigned hereby certifies that the foregoing document was
`
`served electronically via e-mail in its entirety on the following counsel of record for
`
`Petitioner:
`
`Mark T. Garrett (Lead Counsel)
`Eagle H. Robinson (Back-up Counsel)
`NORTON ROSE FULBRIGHT US LLP
`mark.garrett@nortonrosefulbright.com
`eagle.robinson@nortonrosefulbright.com
`
`
`
`
`
`
`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`
`
`
`
`
`Date: April 14, 2017
`
`
`
`
`
`3
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