UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01496
`Patent 7,134,505
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`RESPONSE TO PETITIONERS’ MOTION TO EXCLUDE
`
`
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`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`BAKER HUGHES INCORPORATED and
`BAKER HUGHES OILFIELD OPERATIONS LLC,
`Petitioners
`
`v.
`
`PACKERS PLUS ENERGY SERVICES INC.,
`Patent Owner
`
`___________________
`
`Case IPR2016-01496
`Patent 7,134,505
`___________________
`
`
`
`EXCLUSIVE LICENSEE RAPID COMPLETIONS LLC’S
`RESPONSE TO PETITIONERS’ MOTION TO EXCLUDE
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
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`“The party moving to exclude evidence bears the burden of proving that it is
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`entitled to the relief requested—namely, that the material sought to be excluded is
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`inadmissible under the Federal Rules of Evidence.” Petroleum Geo-Services Inc.
`
`v. Ion Geophysical Corp., IPR2014-00688, Paper 101 at 53 (PTAB Dec. 15, 2015)
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`(citing 37 C.F.R. §§ 42.20(c), 42.62(a)). Petitioners’ motion appears to disregard
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`this requirement as it seeks exclusion of several exhibits by merely referring to a
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`portion of the exhibit and stating a rule of evidence with minimal explanation. In
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`short, Baker Hughes has failed to meet its burden, and its arguments relate at most
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`to weight not admissibility.
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`Exhibit 2039—Weatherford Presentation
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`
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`Michael Delaney authenticated this exhibit (Ex. 2082 at ¶ 8) and counsel for
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`Weatherford has no objection to the authenticity of this document (Ex. 2103).
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`Moreover, the document has distinctive characteristics such as the Weatherford
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`logos and product marks. See Fed. R. Evid. 901(4),(7); see also Generico, LLC v.
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`Dr. Falk Pharma GMBH, IPR2016-00297, Paper 55 at (PTAB May 19, 2017)
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`(admitting website printouts based on appearance of the documents).
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`
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`To the extent Respondent relied on this document to demonstrate that
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`Weatherford offers an open hole multi-stage fracturing system for sale, this use is
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`not hearsay. Baker Hughes fails to identify a statement asserted for the truth of the
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`matter. Rather, the fact that Weatherford has creating marketing documents for an
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`1
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`
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`open hole ball drop system is itself evidence that it sells such a system. Liberty
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`Mutual Ins. Co., CBM2012-00010, Paper 59 at 37 (overruling hearsay objection to
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`industry publications because “[w]e have considered the statements therein not for
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`the truth of the matter asserted, but for the fact that such statements were made at
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`all.”); EMC Corp. v. Personal Web Technologies, LLC, IPR2013-00085, Paper 73
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`at 66 (PTAB May 15, 2014).
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`Moreover, even if the Board deems this exhibit inadmissible for any reason,
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`it may still be considered under Rule 703. See, e.g., SK Innovation Co. v. Celgard
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`LLC, IPR2014-00680, Paper 57 at 28 (PTAB Sept. 25, 2015) (admitting evidence
`
`of commercial success under Rule 703). Respondent’s expert Mr. McGowen
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`offered testimony based on this exhibit by using it as evidence that Weatherford
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`has practiced the claims at issue. See Ex. 2081 at 33-51. Under Rule 703, the
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`evidence underlying that testimony is also admissible subject only to concerns
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`related to jury trials that are inapplicable in IPRs.1
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`1 In district court, Rule 703, requires a proponent to show that any otherwise
`inadmissible evidence underlying an expert’s testimony has “probative value in
`helping the jury evaluate the opinion [that] substantially outweighs [its] prejudicial
`effect.” This provision is inapplicable in IPRs. 37 C.F.R. § 42.62(b) (portions of
`the Federal Rules of Evidence relating to juries do not apply). Even if it were
`applicable, “because the Board is not a lay jury, and has significant experience in
`evaluating expert testimony, the danger of prejudice in this proceeding is
`considerably lower than in a conventional district court trial.” SK Innovation Co.,
`IPR2014-00680, Paper 57 at 50.
`
`
`
`2
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`
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`Exhibit 2044—Vikram Rao Deposition
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`As an expert hired to opine on the obviousness of the very claims at issue in
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`this proceeding, Dr. Rao’s testimony meets the minimum threshold for relevance.
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`To the extent his testimony is inconsistent with assertions made by Baker
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`Hughes—despite having an incentive to testify favorably for Baker Hughes—his
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`testimony is highly relevant.
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`Moreover, sworn deposition testimony is not hearsay in an IPR. Petroleum
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`Geo-Services Inc. v. WesternGeco LLC, IPR2014-01475, Paper 71 at 61 (PTAB
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`July 11, 2016) (ruling prior deposition and trial testimony admissible for IPR
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`purposes). In an inter partes review, direct testimony is typically provided via
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`affidavit, with cross examination taken via deposition. 37 C.F.R. § 42.53(a). In
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`this respect, testimony via affidavit is considered in court testimony before the
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`Board, in contrast to affidavit testimony in district court cases where it is
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`considered out of court testimony. See Polaris Wireless, Inc. v. TruePosition, Inc.,
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`Case IPR2013-00323, slip op. at 41 (PTAB Nov. 3, 2014) (Paper 62). Testimony
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`submitted via deposition or trial transcript is no different from testimony submitted
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`in a written affidavit. Petroleum Geo-Services Inc., IPR2014-01475, Paper 71 at
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`61. Petitioners had an opportunity to cross examine Dr. Rao by seeking to depose
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`him in this proceeding. The fact that they chose not to do so does not render the
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`testimony inadmissible. Id.
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`
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`3
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`
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`Even if this were a district court proceeding, this testimony would be
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`admissible as testimony from an unavailable witness given that Dr. Rao is located
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`more than 100 miles from Washington DC and because the Board typically does
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`not allow live testimony. Fed. R. Ev. 804(b)(1); Fed. R. Civ. Proc. 32(a)(4)(B),(E).
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`This testimony is also admissible under Rule 807. It is already admitted in the
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`IPRs filed by Weatherford. Thus, it is trustworthy and evidence of material facts.
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`Moreover, given that Dr. Rao incentivized to give testimony favorable to
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`Weatherford, the fact that they did no do so is more probative than any other
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`evidence Rapid Completions could reasonably obtain. Finally, admitting this
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`exhibit serves the interests of justice by preventing inconsistent rulings on the same
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`patents being challenged by joint defense partners.
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`Exhibit 2047—Rystad Energy Report
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`
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`Petitioners admit that they produced this exhibit in litigation. “[D]ocuments
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`provided to a party during discovery by an opposing party are presumed to be
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`authentic, shifting the burden to the producing party to demonstrate that the
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`evidence that they produced was not authentic.” See, e.g., Lorraine v. Markel Am.
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`Ins. Co., 241 F.R.D. 534, 552 (D. Md. 2007). Thus, this exhibit is presumed
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`authentic, and Petitioners offer no evidence to rebut that presumption. Moreover,
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`the document contains distinctive characteristics such as the marking that the
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`document is owned by Rystad Energy and repeated references to Rystad Energy
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`4
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`
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`analysis. Petitioners offer no evidence that Baker Hughes fabricated a Rystad
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`Energy report or that it would have a reason to retain a fabricated Rystad Energy
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`report. Thus, they have failed to meet their burden.
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`
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`With regard to Petitioners’ hearsay objection this document falls under
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`hearsay exceptions (17) and (18). It is a market report relied upon by an expert in
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`the field—Mr. McGowen. Moreover, the exhibit is admissible for a purpose other
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`than proving the truth of the matter asserted. Namely, that persons in the field
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`expected the patented technology to have had a significant market share. Even if
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`the actual market share for this technology differed from the reported amount, the
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`fact that practitioners expected the technology to be increasingly competitive
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`against traditional plug and perf demonstrates that the technology has received
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`praise and success.
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`
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`Even if the Board deems this exhibit inadmissible, it may still be considered
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`under Rule 703. See, e.g., SK Innovation Co. v. Celgard LLC, IPR2014-00680,
`
`Paper 57 at 28 (PTAB Sept. 25, 2015) (admitting evidence of commercial success
`
`under Rule 703). Respondent’s expert Mr. McGowen testified:
`
`Rystad Energy noted that demand for open-hole ball drop systems had
`grown from less than $100 million per year in 2008 to nearly $500
`million per year in 2012. It also explained that the technology
`accounted for 70% of the completions installed in the Bakken formation
`and it projected significant growth in other plays. This report also
`credits Packers Plus with developing open-hole ball drop technology in
`2001. BH00364675.
`
`
`
`5
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`
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`Ex. 2051 at 49. Because this document underlies that testimony, it is admissible
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`under Rule 703.
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`Exhibit 2051—McGowen Declaration
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`Petitioners object to the portion of Mr. McGowen’s testimony where he lists
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`Baker Hughes product numbers that have been used over time and documents
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`produced by Baker Hughes that corroborate his opinions. For example, Mr.
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`McGowen testified: “The following Baker Hughes packers are used by Baker
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`Hughes as solid body packers with respect to this claim: OH Packers H40936 RE
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`Packers H30187 H30192 H30407.” Ex. 2034 at 81-82. But Petitioners had an
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`opportunity to cross examine Mr. McGowen regarding this opinion, thus, it is not
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`hearsay. Even if the referenced product numbers were considered hearsay, they are
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`admissible under Rule 703 as explained above.
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`Moreover, Petitioners do not dispute that Mr. McGowen has recited the
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`correct product numbers, nor do they assert that his testimony must be excluded as
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`unreliable under Rule 702. Thus, they fail to identify any substantive opinions that
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`would be affected by a ruling on this motion. For example, even if the Board were
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`to strike certain product numbers and source citations, this objection would have
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`no impact on Mr. McGowen’s opinions that FracPoint employs the patented
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`technology, or that FracPoint has been commercially successful. Petitioners have
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`not moved to exclude those opinions. Thus, Petitioners’ motion would lead to the
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`6
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`
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`bizarre result that an expert may testify as to the commercial success of a product
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`as long as he does not name the various components of the product.
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`Exhibit 2052 – Baker Hughes Development Documents
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`
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`Petitioners’ relevance objection to this exhibit goes to weight not
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`admissibility. First, Petitioners argue that Respondent failed to show that Baker
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`Hughes acquired the Packers Plus design drawing while it was developing its own
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`system. Petitioners are wrong.
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`Petitioners do not dispute that they obtained a Packers Plus design drawing
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`of its StackFRAC system, that the drawing is dated 2003, that they modified the
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`drawing to remove the Packers Plus logo, or that this modified drawing was
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`located within a collection of papers related to the early development of their
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`competing open hole ball drop system. Petitioners had an opportunity to confront
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`this document and offer conflicting evidence or testimony, but they offered
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`nothing. That fact alone indicates that the evidence of copying is strong—certainly
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`strong enough to overcome the minimal threshold of Rule 402.
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`Moreover, Petitioners fail to acknowledge that exhibit 2052 is a collection of
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`development documents for Baker Hughes’ open hole fracturing system. It
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`contains numerous references to the “Iso-Frac” system in development in 2004.
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`See Ex. 2052 at 6. It also labels the drawing of Packers Plus’s open hole ball drop
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`system as the “Iso-Frac System.” Id. at 13. Finally, it contains slides from a
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`7
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`
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`Power Point presentation regarding the development of “IsoFrac,” which identify
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`Packers Plus as the only competition with a “proven system.” Id. at 25-26.
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`Exhibit 2020 establishes that Baker Hughes actually sold its competing open hole
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`ball drop system under the name “FracPoint,” and that by 2005, it had sold only 4
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`such systems. Ex. 2020 at 6.
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`Given this background, consider the logical leaps one would need to make to
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`conclude that Baker Hughes obtained the Packers Plus drawing after it had
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`completed development of its FracPoint system. That would mean that, after
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`Baker Hughes had finalized its FracPoint system in late 2004 or 2005, someone at
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`Baker Hughes obtained a confidential Packers Plus design drawing from 2003.
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`That person decided to keep the document, and he or she then modified it to make
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`it look like a Baker Hughes document. But instead of applying the actual name of
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`Baker Hughes’s completed system, he or she applied the prototype name of the
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`system—Iso-Frac. Then that person stuffed the drawing into a stack of papers
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`created during the initial design period for Iso-Frac. The fact that Baker Hughes
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`would even attempt to imply this far-fetched scenario—without offering any
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`evidence to back it up—may be the strongest evidence yet that Baker Hughes
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`copied Packers Plus.
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`In fact, Rapid Completions made this exact same argument on April 28,
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`2017. IPR2016-00598, Paper 42 at 6. And although Baker Hughes decided to
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`
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`8
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`
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`submit additional testimony from its expert in this proceeding on August 17, 2017,
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`it did not submit testimony from a Baker Hughes employee on this issue. If Baker
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`Hughes had some plausible explanation for this exhibit, it could have backed it up
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`with evidence. The fact that it was unable to find a fact witness to swear to such an
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`explanation and sit for cross examination is further proof that this exhibit is
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`evidence of copying.
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`Second, Petitioners argue that the tools used in its Fracpoint system are
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`similar to the tools used in Lane-Wells. Petitioners fail to explain how this issue
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`relates to their relevance objection, but it appears to be a recitation of Petitioners’
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`“no nexus” argument from their reply. However, the Federal Circuit has already
`
`rejected Petitioners’ misinterpretation of the law:
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`Kohler’s argument relies on an incorrect interpretation of our case law.
`We have held that ‘[w]hile objective evidence of nonobviousness lacks
`a nexus if it exclusively relates to a feature that was ‘known in the prior
`art,’ the obviousness inquiry centers on whether ‘the claimed invention
`as a whole’ would have been obvious.’ Where the allegedly obvious
`patent claim is a combination of prior art elements, we have
`explained that the patent owner can show that it is the claimed
`combination as a whole that serves as a nexus for the objective
`evidence; proof of nexus is not limited to only when objective evidence
`is tied to the supposedly “new” feature(s).
`
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`WBIP, LLC v. Kohler Co., 829 F.3d 1317, 1331–32 (Fed. Cir. 2016) (internal
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`citations omitted, emphasis added). Here, the patented invention combines various
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`prior art tools such as packers and sliding sleeves in a new way—it uses them for
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`
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`9
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`
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`multi-stage open hole fracturing. Thus, there is a nexus between the claim and
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`Exhibit 2052 if the exhibit combines all of the elements of the claims. It does, it
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`depicts graduated ball-operated sleeves separated by solid body packers in an open
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`hole, horizontal well. Not even Baker Hughes contends that this combination of
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`elements is present in Lane-Wells as it has not even asserted an anticipation theory
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`based on Lane-Wells. Moreover, to the extent this document does not speak for
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`itself, Mr. McGowen’s testimony establishes the relevance of this document
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`rendering it admissible under Rule 703 as well. Ex. 2081 at 25-29.
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`Exhibit 2053 – Packers Plus Design Drawing
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`
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`Petitioners fail to mention that this document has been authenticated by
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`Packers Plus employee Ken Paltzat. Ex. 2101. Petitioners also recite the same
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`relevance objections asserted against exhibit 2052 which are addressed above.
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`Exhibit 2054—Article Regarding Schlumberger
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`
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`To establish authenticity, Rule 901 requires that “the proponent must
`
`produce evidence sufficient to support a finding that the item is what the proponent
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`claims it is.” Here, Respondent claims that exhibit 2022 is an online Rigzone
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`article. The exhibit itself contains distinctive marks such as the URL for the article
`
`and the layout of a Rigzone article. Accordingly, it is authentic under Rule
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`901(b)(4) and it is self-authenticating as a periodical under Rule 903(6). See, e.g.,
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`Generico, LLC v. Dr. Falk Pharma GMBH, IPR2016-00297, Paper 55 at (PTAB
`
`
`
`10
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`
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`May 19, 2017) (admitting website printouts based on the appearance of the
`
`documents); Ciampi v. City of Palo Alto, 790 F. Supp. 2d 1077, 1091 (N.D. Cal.
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`2011) (admitting Internet printouts that “contain sufficient indicia of authenticity,
`
`including distinctive newspaper and website designs, dates of publication, page
`
`numbers, and web addresses”). The testimony of Mr. Delaney also confirms that
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`the exhibit is a Rigzone article. Fed. R. Ev. 901(1); Ex. 2045. Although
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`Petitioners question the basis for this testimony, they have not shown it to be
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`inaccurate. Thus, they have not met their burden.
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`
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`With regard to Petitioners’ hearsay objection, this exhibit falls under
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`exception (18) for the same reasons as exhibit 2021 discussed above—it is a
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`periodical relied upon by Mr. McGowen. See Ex. 2051 at 50.
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`Moreover, even if the Board deems this exhibit inadmissible for any reason,
`
`it may still be considered under Rule 703. Mr. McGowen testified:
`
`Some of the best evidence of the commercial and technological
`
`significance of the 774 Patent/Invention is that Schlumberger, a
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`technology leader itself and one of the world’s largest oil and gas
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`service companies, purchased a stake in Packers Plus and negotiated
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`exclusive rights to deploy and market Packer Plus technology
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`worldwide, excluding North America.
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`11
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`
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`Ex. 2051 at 50. Again, Petitioners have not moved to exclude this testimony and
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`the evidence underlying this testimony is probative of commercial success and
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`praise and Petitioners identify no prejudicial effect from admitting the evidence.
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`Exhibits 2081 and 2084—McGowen Supplemental Declaration
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`Petitioners move to exclude McGowen’s testimony regarding commercial
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`success because they contend that Mr. McGowen provided insufficient evidence
`
`that the systems sold by Baker Hughes and Weatherford were actually used.
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`However, Mr. McGowen offered similar testimony in his original declaration (Ex.
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`2051), to which Petitioners have not objected. Thus, this objection is moot. It is
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`also incorrect.
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`Petitioners foundation objection is inapplicable because this rule applies to
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`fact witnesses testifying as to matters within their personal knowledge. Fed. R.
`
`602. This Rule “does not apply to a witness’s expert testimony under Rule 703.”
`
`Id. Similarly, 37 C.F.R. § 42.65 is not a valid basis for excluding expert testimony.
`
`Corning Inc. v. DSM IP Assets BV, IPR2013-0048, Paper 94 at 74 (PTAB May 9,
`
`2014) (“Whether a witness’s testimony fails to include underlying facts or data on
`
`which an opinion is based goes to the weight that should be accorded the
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`testimony, and not its admissibility.”).
`
`With regard to Petitioners’ relevance objection, Mr. McGowen’s testimony
`
`meets the minimal threshold of Rule 401. He relied on marketing documents,
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`
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`12
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`
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`technical papers, sales records, and in the case of Baker Hughes, records of jobs
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`actually performed. The fact that Baker Hughes and Weatherford have repeatedly
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`claimed to have performed open hole multi-stage fracturing, and actually generated
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`hundreds of millions of dollars in revenue from selling their systems is a very
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`strong indicator that they have actually done what they said they did. Indeed, it is
`
`difficult to imagine a plausible set of facts that would lead one to conclude that
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`Baker Hughes and Weatherford, or their customers, have not actually used their
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`advertised systems. Certainly, Baker Hughes offers no evidence to support that
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`theory. But even if Baker Hughes had generated hundreds of millions of dollars
`
`selling unused systems, the fact that it was able to do so by offering an infringing
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`use for sale is still probative of commercial success. Thus, Mr. McGowen’s
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`testimony that Baker Hughes and Weatherford have generated commercial success
`
`from the patented method is at least relevant to this proceeding.
`
`Exhibit 2082—Michael Delaney Declaration
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`Baker Hughes criticizes Mr. Delaney’s testimony as lacking foundation (and
`
`thus irrelevant), but this is merely an authentication affidavit. As a paralegal for
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`Respondent’s outside counsel, he is fully capable of accessing the Internet and
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`identifying documents produced by the parties. Petitioners offer no plausible basis
`
`to conclude otherwise, and thus they have failed to meet their burden.
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`Exhibits 2074, 2078, 2079, 2092, 2093, 2098, 2099—Various Articles
`
`
`
`13
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`
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`As technical articles, these articles are offered to show what information
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`they would have conveyed to a person of ordinary skill in the art, and the
`
`background knowledge and expectations of such a person. The truth of the
`
`contents of these articles is not relevant to this inquiry. HTC Corp. v. Advanced
`
`Audio Devices, LLC, IPR2014-01156, Paper 36 at 27 (PTAB Dec. 29, 2015); EMC
`
`Corp. v. Personal Web Techs., LLC, Case IPR2013-00085, slip op. at 66 (PTAB
`
`May 15, 2014) (Paper 73) (“a prior art document submitted as a ‘printed
`
`publication’ under 35 U.S.C. § 102(b) is offered simply as evidence of what it
`
`described, not for proving the truth of the matters addressed in the document.”);
`
`see also Fed. R. Evid. 801(c) 1997 Adv. Comm. Note (“If the significance of an
`
`offered statement lies solely in the fact that it was made, no issue is raised as to the
`
`truth of anything asserted, and the statement is not hearsay.”).
`
`Indeed, Respondent is expressly not relying on statements from several of
`
`these articles for the truth of the matter, because the patented invention requires
`
`them to be false. For example, Owens states: “A horizontal well that is to be
`
`fracture stimulated over multiple zones must be cased and cemented.” Ex. 2099 at
`
`2. Abass states: “Casing and cementing a horizontal well is essential to provide
`
`zone selectivity and isolation during fracture stimulation.” Ex. 2078 at 9. Today,
`
`these statements are recognized to be false. Inventor Dan Themig and his
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`StackFRAC system have been credited with proving them false. Ex. 2045 at 1
`
`
`
`14
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`
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`(“StackFRAC was the first ball drop system created for open hole horizontal
`
`wells” that is “partly responsible for creating access to vast reservoirs of oil and
`
`natural gas in North America that were previously considered uneconomic to
`
`produce.”) Respondent has relied on these statements to demonstrate that, prior to
`
`2001 when these statements were made, they were believed to have been true by
`
`persons of skill in the art. And not just believed to be true, but recited with such
`
`certainty that the authors did not even feel the need to justify the statements. This
`
`is evidence that the claimed invention would not have been obvious in 2001. Thus,
`
`this hearsay objection should be overruled. At any rate, to the extent Mr.
`
`McGowen offered similar testimony about these articles, they are admissible under
`
`Rule 703. Ex. 2081 at 23-25.
`
`Exhibit 2100—Murray
`
`
`
`While Respondent did not cite this article in its response, it did rely on Mr.
`
`McGowen’s testimony that a person of ordinary skill in the art would have avoided
`
`open hole multi-stage fracturing prior to 2001. Mr. McGowen cited this article to
`
`support that testimony. Ex. 2081 at 24. Thus, it is admissible under Rule 703.
`
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`15
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`
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`Dated: October 12, 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, Re. 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
`
`
`
`16
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`
`
`mark.garrett@nortonrosefulbright.com
`eagle.robinson@nortonrosefulbright.com
`
`
`
`
`Date: October 12, 2017
`
`
`
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`/Hamad M. Hamad/
`Hamad M. Hamad, Reg. No. 64,641
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