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UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`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 IPR2016-01496
`Patent 7,134,505
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`OBJECTIONS TO PETITIONERS’ EVIDENCE PURSUANT
`TO 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`Under the Federal Rules of Evidence and 37 C.F.R. § 42.64, Exclusive
`
`Licensee Rapid Completions LLC timely objects to evidence submitted with the
`
`Petitioners’ Reply. Rapid Completions serves Petitioners with these objections to
`
`provide notice that Rapid Completions may move to exclude the challenged
`
`exhibits under 37 C.F.R. § 42.64(c) unless Petitioners cure the defects associated
`
`with the challenged exhibits identified below.
`
`
`
`Exhibit 1024 – Davis-Nichols Affidavit
`
`
`
`Rapid Completions objects to this document as irrelevant under FRE 401
`
`and thus inadmissible under FRE 402 and 403, and untimely because it attempts to
`
`add new matter beyond the instituted grounds.
`
`
`Dated: August 23, 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
`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
`
`
`
`
`
`
`
`

`

`CERTIFICATION OF SERVICE
`
`
` 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
`
`
`Date: August 23, 2017
`
`
`
`
`
`
`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`
`
`
`
`
`
`
`
`

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