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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`BAKER HUGHES INCORPORATED
`WEATHERFORD INTERNATIONAL,
`and BAKER HUGHES OILFIELD
`LLC; WEATHERFORD/LAMB, INC.;
`OPERATIONS LLC
`WEATHERFORD US, LP; and
`Petitioners
`WEATHERFORD ARTIFICIAL LIFT
`
`SYSTEMS, LLC
`
`Petitioners
`
`
`v.
`v.
`
`
`PACKERS PLUS ENERGY
`PACKERS PLUS ENERGY
`SERVICES INC.,
`SERVICES INC.,
`Patent Owner
`Patent Owner
`
`___________________
`
`Case IPR2016-00596 (Patent 7,134,505)
`Case IPR2016-00597 (Patent 7,543,634)
`Case IPR2016-00598 (Patent 7,861,774)
`Case IPR2016-01380 (Patent 9,303,501)
`Case IPR2016-01496 (Patent 7,134,505)
`Case IPR2016-01505 (Patent 7,543,634)
`Case IPR2016-01506 (Patent 7,861,774)
`Case IPR2016-01509 (Patent 7,861,774)
`Case IPR2016-01514 (Patent 7,543,634)
`Case IPR2016-01517 (Patent 7,134,505)
`___________________
`
`
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`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S REQUEST FOR
`ORAL ARGUMENT
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`Exclusive Licensee, Rapid Completions LLC, by and through its attorneys,
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`respectfully requests oral argument, currently scheduled for November 2, 2017.
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`If the Board determines that live testimony from the parties’ declarants will
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`assist the Board, Rapid Completions requests that the oral argument be structured
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`as follows:
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`• Each side (Weatherford and Baker Hughes are considered a single
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`“side”) is permitted ten minutes to make an opening statement.
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`• Each side is permitted 2-3 hours to divide up as it sees fit between
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`direct, cross, and redirect, etc. of the experts concerning the issues
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`raised in their respective declarations.
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`• Each side is permitted one hour of oral argument time to address the
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`issues raised in IPR2016-00596, IPR2016-00597, IPR2016-00598,
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`IPR2016-01380, IPR2016-01496, IPR2016-01505 and IPR2016-
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`01506, IPR2016-01509, IPR2016-01514 and IPR2016-01517.
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`If the Board determines that live testimony from the parties’ declarants is not
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`necessary, Rapid Completions requests that the oral argument be structured as
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`follows:
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`• Each side (Weatherford and Baker Hughes are considered a single
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`“side”) is permitted twenty-five minutes to address issues, evidence,
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`and testimony relevant to the proceedings as a whole in an opening
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`1
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`statement.
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`• Each side is permitted one hour and fifteen minutes of oral argument
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`time to address the issues raised in IPR2016-00596, IPR2016-00597,
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`IPR2016-00598, IPR2016-01380, IPR2016-01496, IPR2016-01505
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`and IPR2016-01506, IPR2016-01509, IPR2016-01514 and IPR2016-
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`01517.
`
`Pursuant to 37 C.F.R. § 42.70, and without intending to waive any issue not
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`specifically identified, Rapid Completions specifies the following issues to be
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`argued:
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`1.
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`Petitioners failed to meet their burden of proving that the instituted
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`claims are unpatentable under any grounds in the Petition;
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`Any issues identified in Petitioner’s Request for Oral Argument;
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`Any other issues the Board deems necessary for issuing a final written
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`2.
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`3.
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`decision.
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`Rapid Completions requests that the Board provide audio-visual equipment
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`to display demonstrative exhibits, including a projector to be connected to a laptop
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`and a screen for displaying documents.
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`2
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`Dated: September 28, 2017
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`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
`
`
`
`
`
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`
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`The undersigned hereby certifies that the foregoing document was
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`served electronically via e-mail in its entirety on the following counsel of record for
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`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
`
`
`
`3
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`
`
`
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`
`
`Jason Shapiro (Lead Counsel)
`Patrick Finnan (Back-up Counsel)
`EDELL,SHAPIRO & FINNAN, LLC
`js@usiplaw.com
`pjf@usiplaw.com
`epatent@usiplaw.com
`
`
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`
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`Date: September 28, 2017
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`
` /Hamad M. Hamad/
`
`Hamad M. Hamad, Reg. No. 64,641
`
`
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`4
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`
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